Privacy Policy

1. Introduction

1.1 HumanCorps is a company that focuses on driving human-centered business transformation. We work with clients across the public and private sectors. At HumanCorps, we are committed to protecting and respecting your privacy. We will only use your personal information to provide the products and services you have requested from us. In some circumstances, if we would like to engage you in any research, we will seek your permission before doing so.

1.1 This Policy explains when and why we collect personal information about people who we work with or who visit our website, how we use it, and how we keep it secure. We collect, use, and are responsible for certain personal data about you. When we do, we are subject to the UK General Data Protection Regulation (UK GDPR).

1.2 We may change this Policy from time to time, so please check this page occasionally to ensure that you’re happy with any changes.

1.3 Any questions regarding this Policy and our privacy practices should be sent by email to andrew.lopianowski@humancorps.co.uk or by writing to 74a Station Road, East Oxted, Surrey, RH8 0PG.

2. Who Are We?

2.1 HumanCorps Limited is a company registered in England and Wales with company number 14831415 whose registered office is at 74a Station Road, East Oxted, Surrey, RH8 0PG (collectively referred to as “HumanCorps” “we” “us” or “our” in the Policy). HumanCorps is the controller and responsible for your personal data.

2.2 Although we are not required to appoint a statutory Data Protection Officer, we have nominated a data privacy contact. For all questions regarding your personal data or your rights, please contact Andrew Lopianowski at andrew.lopianowski@humancorps.co.uk.

2.3 Our website and services are not intended for children under the age of 16. We do not knowingly collect personal information from anyone under 16. If you become aware that a child has provided us with their personal information, please contact us and we will take steps to remove such information from our systems.

3. What Type of Information Is Collected From You?

3.1 Personal data means any information about an individual from which that person can be identified.

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

(a) Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

(b) Contact Data includes billing address, delivery address, email address and telephone numbers.

(c) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

(d) 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, device ID and other technology on the devices you use to access this website.

(e) Profile Data includes your interests, preferences, feedback and survey responses.

(f) Usage Data includes information about how you interact with and use our website and services.

(g) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3.3 We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3.4 If you engage us to provide services to you, we will also collect personal information for any participants in the project or intervention as well as supporting documentation to enable us to deliver our services (e.g., strategy documents, CVs, job descriptions).

4. How Do We Collect Information From You?

4.1 We obtain information about you when you engage with any of our services or if you use our website, for example, this includes when you:

(a) contact us about our potential projects;

(b) send a request for information to our website;

(d) subscribe to our service or publications;

(e) request marketing to be sent to you;

(f) enter a competition, promotion or survey; or

(g) give us feedback or contact us.

4.2 As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

4.3 Identity and Contact Data is collected from publicly available sources such as Companies House and LinkedIn.

5. Sensitive or Special Category Data

5.1 We do not typically collect “special category” (sensitive) personal data (such as data relating to health, ethnicity, or political opinions), unless required for a specific project and only where necessary and with appropriate safeguards. If such data is required, we rely on a lawful basis under Article 9 of the UK GDPR and will notify you before collecting such information.

6. How Is Your Information Used?

6.1 The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

(a) Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

(b) Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

(c) Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

(d) Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

6.2 We have set out below a description of the ways we plan to use your personal data:

(a) Providing and Managing Requested Services or Products

To deliver the products and services you have requested from HumanCorps, including project management, business transformation interventions, and associated client communications. This may involve collection and processing of relevant supporting documentation (e.g., strategy documents, CVs, job descriptions), contacting you following an enquiry and contacting you with information on services.

(b) Providing and Managing Requested Services

To deliver the products and services you have requested from HumanCorps, including project management, business transformation interventions, and associated client communications. This may involve collection and processing of relevant supporting documentation (e.g., strategy documents, CVs, job descriptions, undertaking interviews with employees and contractors).

To fulfil contractual obligations arising out of any contracts entered into with you or your organisation, and to comply with legal or regulatory obligations (including where data must be disclosed for legal reasons).

(d) Marketing, Communications, and Events

To send you communications you have requested or that may be of legitimate interest, including information about services, campaigns, blogs, newsletters, or event invitations.

(e) Obtaining Feedback and Improving Services

To seek your views, comments, or evaluations on the services provided, and to use your responses to improve and tailor HumanCorps offerings as well as to notify you of any changes to our services.

(f) Profiling and Personalization

To analyse your personal information for the purpose of creating a profile of your interests and preferences—enabling HumanCorps to provide more relevant or tailored information, and to supplement profiles with external data (e.g. from public LinkedIn profiles).

(g) Website Management, Analytics, and Security

To use cookies and similar technologies for statistical analytics (without direct identification), enhance website functionality, personalize the digital experience, and implement necessary security precautions to protect the website and user data.

(h) Engaging Individuals in Research (with Consent)

To invite you to participate in research activities, but only after obtaining your specific consent.

(i) Business Operations and Administrative Purposes

To retain and manage data for reasonable business needs, internal recordkeeping, management of relationships, and general operations in line with legal and regulatory retention periods.

(j) Complying with Regulatory or Statutory Requirements

To respond to lawful requests from public authorities, comply with applicable laws, and cooperate with regulators as required by the UK GDPR and the DPA 2018

6.3 You may opt-out of receiving marketing communications from us at any time by following the unsubscribe link in our emails or by contacting us directly.

7. Profiling

7.1 We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.

7.2 We do not currently make decisions based solely on automated processing, including profiling, which produces legal effects or significantly affects you. If this changes, we will notify you and explain your rights in that regard.

8. Use of ‘Cookies’

8.1 Like many other websites, the HumanCorps website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. This helps us to improve our website and deliver a better, more personalised service.

8.2 It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using our website.

9. Links to Other Websites

9.1 Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website, so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

9.2 In addition, if you linked to our website from a third-party site, we are not responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

10. Who Has Access to Your Information?

10.1 We will not sell or rent your information to third parties.

10.2 Save as set out below, we will not share your information with third parties for any purpose, unless agreed in advance with you.

10.3 We may transfer your personal information to a third party:

(a) associate who is working on our behalf to deliver our solutions specifically to you;

(b) if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation;

(c) 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 policy.

10.4 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 policy.

11. Data Retention

11.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

11.2 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, regulatory, tax, accounting or other requirements.

11.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

11.4 In some circumstances you can ask us to delete your data: see below for further information.

11.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. What Are Your Rights Under Data Protection Laws?

12.1 Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not.

(a) Request access to your personal data (commonly known as a "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.

(b) 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, though we may need to verify the accuracy of the new data you provide to us.

(c) Request erasure of your personal data in certain circumstances. 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.

(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

(e) You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.

(f) 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g) 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.

(h) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

(i) If you want us to establish the data's accuracy;

(ii) Where our use of the data is unlawful but you do not want us to erase it;

(iii) 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

(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

12.2 If you want to exercise any of the rights above, please contact us by email.

12.3 You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

13. Security Precautions in Place to Protect the Loss, Misuse or Alteration of Your Information

13.1 When you give us personal information, we take steps to ensure that it’s treated securely.

13.2 All of the systems and tools we use at HumanCorps are UK GDPR compliant and we have appropriate measures in place to prevent personal data from being accidentally lost or used/ accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

13.3 Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

14. International Transfers

14.1 Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the we use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us by email.

15. Review of This Policy

15.1 We keep this Policy under regular review. This Policy was last updated in August 2025.