Privacy Policy

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice explains how we collect and process your personal data:

• through your use of our website;
• when you sign up to our mailing list, newsletter or to download our resources;
• when you are, or have been, or intend to become, or are an individual connected to, one of our clients;
• when you apply for, are, or have been, our associate partner.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any such other notices and is not intended to override them.

CONTROLLER

Nudge Limited is the controller and responsible for any personal data provided to us. It is collectively referred to as Nudge, we, us or our in this privacy notice.

The Managing Director is responsible for this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Nudge Limited

Names of directors: Fran Pestana

Email address: fran@nudgeconsult.com 

Postal address: 2 Lord Scarsdale Court, Hall Farm Road, Duffield, Belper, Derbyshire, DE56 4FJ

Telephone number: 07771634731

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last significantly updated on 19 May 2025 and historic versions can be obtained by contacting us. We reserve the right to update this privacy notice from time to time to address changes in data protection law or its interpretation, or to update you with details of third parties appointed by us who may process your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, job title, job function and company name.
• Contact Data includes contact address, email address, shipping and billing address and telephone numbers.
• Account Data includes details about payments to and from you (including details of disbursements paid to a third party on your behalf) and details of services you have purchased from us.
• Financial Data includes bank account details and information contained in any document that you provide to us in order to provide our services for you.
• Transaction Data includes details about payments to and from you, other details of services you have purchased from us and, in the case of an individual connected with an organisation which is a client of ours, details of how you are connected to our client organisation.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Marketing and Communications Data includes your preferences in receiving marketing information from us and your communication preferences.
• Usage Data includes information about how you use our website and services.

Unless you agree to participate in any data collection for research purposes, we do not collect any Special Category Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial and Marketing and Communications Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• ask us to provide services to you;
• are appointed as a director or become a member or person with significant control in relation to an organisation to which we provide services;
• subscribe to our mailing list; or
• provide us with feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and/or other similar technologies. Please see our cookie policy below for further details.

Publicly available sources and third parties. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
  • analytics providers such as Google based outside the EEA;
  • advertising networks based inside the UK or EEA; and
  • search information providers based inside the UK or EEA;
• Contact Data from company websites;
• Identity, Contact and Transaction Data from an organisation which is a client of ours, where you are an individual connected with that organisation;
• Identity and Contact Data from data brokers or aggregators;
• Identity and Contact Data from publicly availably sources such as Companies House based in the UK; company registries in other jurisdictions, where relevant, which may be based in the EEA and outside the EEA, the Financial Conduct Authority or a similar regulatory body based in the UK or EEA; the London Stock Exchange based in the UK; regulated stock markets in other jurisdictions, where relevant, which may be based in the EEA and outside the EEA; and/or the Electoral Register based in the UK.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or post where you are not and never have been our client. You have the right to withdraw any such consent at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

If you are a user of our website

Our website contains information about us, including details of our team, our services and how we can help you. Its main purpose is therefore to provide users with information, rather than to collect or process users’ data. We may, however, collect and use some personal data for the following purposes:

(a)    To manage our relationship with you which will include notifying you about changes to our terms or privacy notice 

(b)    To analyse data to improve our website, services, marketing, customer relationships and experiences. 

(c)    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). 

If you are on our mailing list

Whilst we do not usually rely on consent as a legal basis for processing personal data, we do rely on consent in relation to sending direct marketing communications to you via email or post, where you are not and have never been our client.  In such (i.e. non-client direct marketing) circumstances, you have the right to withdraw consent to such marketing at any time by contacting us. Our contact details are generally on the email footers of each of our employees. In addition, an unsubscribe option is always included on bulk email communications which are sent out to those on our mailing list.

The purposes for which we may collect and use your personal data are:

(a)    To share news and bulletins with you (where you, or the organisation with which you are connected, are not and have never been a client) by email and/or post, which we believe will be relevant to you or the organisation with which you are connected. 

If you are a client or an individual connected with our client in the case of an organisation

(a)    To enable us to provide consulting, coaching and other services where you are an individual and as such, our client; or an individual connected to an organisation which is our client. This includes communicating with you prior to and during the course of our engagement, taking your instructions, providing advice and services and invoicing our fees and disbursements. 

(b)    To manage our client relationship with you where you are an individual who is our client, or an individual connected to an organisation which is our client, which will include ensuring that we meet appropriate service levels, asking for feedback and monitoring your level of satisfaction with our services. 

(c)    To share news and bulletins with you by email and/or post, which we believe will be relevant to you or to an organisation with which you are connected. 

(d)    To manage our relationship with you, or an organisation with which you are connected, which may include notifying you about changes to our terms or privacy notice. 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage Data and, where you are or have been our client, information about your relationship with us, to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which briefings and services may be relevant for you, for marketing purposes.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you met one of our staff and have not opted out of receiving those communications.

Third party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services we provide to you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.

• Service providers acting as processors based in the European Economic Area (EEA) and/or the UK, who provide IT and system administration services, including Diligent Entities, who provide the software that we use to maintain clients’ statutory registers;
• Service providers acting as processors based outside both the UK and the EEA who provide cloud IT and system administration services, such as Microsoft and Xero. Note that such processors nevertheless commonly store personal data on servers based within the UK or EEA;
• Professional advisers acting as processors or controllers-in-common including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services;
• HM Revenue & Customs (HMRC) and Companies House (in respect of statutory information required to be reported on clients’ behalf), HMRC and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice or otherwise in the manner set out in their own privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Save to the extent that such providers are also controllers of your personal data, with direct responsibilities to you under data protection legislation, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to associate partners, contractors and other third parties who have a business need to know. Save to the extent that such third parties are themselves controllers of your personal data (and accordingly have direct obligations to you under data protection laws), they will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, taxation or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We are required to retain personal data that you provide for the purposes of complying with ECCTA for a minimum period of seven years. In some circumstances you can ask us to delete your data. Please see below for further information.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have rights to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you feel that our processing on this ground impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please Contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.