Privacy Policy.

Last Updated: 14.07.2026

Implicit Advisory Limited respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website or use ourservices, and tells you about your privacy rights and how the law protects you.

We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018(DPA 2018), and the Privacy and Electronic Communications Regulations 2003 (PECR), together referred to in this policy as Data Protection Law.

Please read this policy together with any other privacy notice we provide on specific occasions when wecollect or process personal data about you. This policy supplements those notices and is not intended toreplace them.

1. Purpose of this Privacy Policy

This policy informs you how Implicit Advisory Limited collects and processes your personal data throughyour use of our website and in the provision of our coaching, mentoring, and business advisory services. It covers:
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• the types of personal data we collect
• how we use it and the legal basis for doing so
• who we share it with
• how long we keep it
• your rights in relation to it
• how to contact us with questions or requests

2. Controller
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Implicit Advisory Limited is the data controller responsible for your personal data (referred to as "Implicit", "we", "us", or "our" in this policy).

We are not legally required to appoint a Data Protection Officer. All data protection matters are handleddirectly by the director. Contact details are set out in Section 3 below.

3. Contact details

If you have any questions about this privacy policy or our privacy practices, or wish to exercise any of your legal rights, please contact us:

Full name of legal entity: Implicit Advisory Limited

Email address: info@theimplicit.co.uk

Postal address: C/O AJ Fleet; Co., Hyde Park House, Hyde, SK14 4EH

You 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 opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.

4. Your Legal Rights

Under Data Protection Law, you have the right to:

Right to access. You may request a copy of the personal data we hold about you (commonly known as a“subject access request”).

Right to correction. You may ask us to correct inaccurate or incomplete personal data, thought we may need to verify the accuracy of new data provided.

Right to erasure. In certain circumstances, you may ask us to delete your personal data. If we have alawful reason to retain it, we will notify you and explain our decision.

Right to object. You may object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the lawful 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. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.

Right to restrict processing. You may ask us to temporarily limit the way we use your personal data, for example whilst you verify its accuracy.

Right to data portability. You may ask us to provide you, or another organisation, with an electronic copy of your personal data.

Right to withdraw consent. Where we process your personal data on the basis of your consent (forexample, for marketing communications), you may withdraw that consent at any time by contacting us atinfo@theimplicit.co.uk. Withdrawal does not affect the lawfulness of any processing carried out beforewithdrawal.

Rights in relation to automated decision-making. We do not make decisions about you using solelyautomated processing. If this changes, we will update this policy and notify you as required by law.

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

To exercise any of these rights, please contact us at info@theimplicit.co.uk.

5. Verifying Your Identity

To protect your personal data, we may need to verify your identity before fulfilling a request. This is asecurity measure to ensure that personal data is not disclosed to any person who has no right to receiveit. We will ask for reasonable information to confirm who you are - we will not request excessive documentation.

There is no charge for making a request. However, we may charge a reasonable fee if your request is manifestly unfounded or excessive (for example, because it is repetitive). We may also decline to complyin such circumstances, or where we are unable to verify your identity. We will write to you to explain ourreasoning if this occurs.

6. Changes to the Policy

We keep this privacy policy under regular review. This version was last updated in June 2026.
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We will notify you of material changes by updating this policy on our website and, where appropriate, by contacting you directly. Please keep us informed if your personal data changes during your relationship with us so we can keepour records accurate, for example a new address or email address.

7. The Personal Data We Collect About You

Identity Data: first name, last name, professional title, previous names, date of birth, gender or similaridentifier.

Contact Data: email address, billing address and telephone numbers.

Transaction Data: details about prices quoted, services used or purchased, costs applicable, sumsowed, and payment history.

Technical Data: IP address, your login data, browser type and version, time zone, browser plug-in typesand versions, operating system and platform, and other technology on the devices you use to access ourwebsite.

Usage Data: information about how you use our website, products, and services.Enquiry Data: your email address, details of your enquiry, and any other details you provide whencontacting us.

Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences.

Other Data: any other personal data you share with us in the course of our coaching, mentoring, or business advisory services - whether in person, by telephone, or by email. This data will be used inaccordance with this privacy policy. Whilst we do not seek to collect Special Category data (see below),you may voluntarily share sensitive personal information during sessions. Any such information will betreated with the same care and used only to support the delivery of services to you.

Special Category data. We do not deliberately collect Special Category data, which includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,trade union membership, health, or genetic and biometric data. We also do not collect information aboutcriminal convictions or offences.

If you fail to provide personal data. Where we need to collect personal data by law, or under a contract with you, and you do not provide it, we may be unable to deliver our services. We will notify you if this isthe case.

8. How We Collect Your Personal Data

We collect personal data through the following methods:

Direct interactions. You may provide us with Identity Data and Contact Data by completing our contactform, corresponding with us by email, telephone, or post, or by:
- applying for or enquiring about our services including registration for our learning management system
- subscribing to our newsletter or publication
- requesting marketing communication
- giving us feedback or contacting us directly.

We also collect personal data in the course of carrying out work for you (or your business).

We may collect personal data when we communicate with you by email or other electronic correspondence, by telephone, or through video conferencing software.

We may also collect personal data through networking activities, including at in person or virtual events.

Website and third parties and publicly available sources

We also collect data from and about you via our website:

- Through your actions (for example, when submitting an enquiry form).

- Through automated technologies or interactions. 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. See our cookie policy for further details.
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- Through third parties or publicly available sources. We will receive personal data about you fromvarious third parties and public sources.
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- Technical Data is collected from analytics providers; advertising networks; and search information providers;
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- Contact, Financial and Transaction Data from providers of technical, payment and deliveryservices;

- Identity and Contact Data from publicly available sources such as Companies House and address and identity verification sources.

9. How We Use Your Personal Data

We will only use your personal data where the law permits. We most commonly rely on the following legal bases:
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• Performance of contract where processing is necessary to perform or enter into a contract withyou.
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• Legitimate interests where it is necessary for our legitimate business interests, provided thoseinterests are not overridden by your rights.
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• Legal obligation where we must process your data to comply with a legal or regulatory requirement.
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• Consent where you have given us clear consent to process your data for a specific purpose, suchas receiving marketing communications.

Where we rely on legitimate interests, we have assessed that our interests do not override yourfundamental rights and freedoms.

10. Purposes For Which We Will Use Your Personal Data

The table below sets out the purposes for which we use your personal data and the legal basis we rely onin each case.
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11. Change Of Purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that using it for another reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and, where required by law, seek your consent.

12. Marketing

You will receive marketing communications from us if you have requested information from us or contracted with us for services and you have not opted out of receiving that marketing.

Testimonials. If we ask you to provide a testimonial for publication, we will always seek your express permission beforehand and ask whether you would prefer it to be anonymous.

Third-party marketing. We will obtain your express opt-in consent before sharing your personal data with any third party for marketing purposes.

Opting out. You may ask us to stop sending marketing communications at any time by contacting us at info@theimplicit.co.uk. Opting out of marketing will not affect data we process in connection with delivering our services to you (for example, for billing or service-related communications).

13. Sharing Your Personal Data

We share personal data only where necessary to operate our business, deliver our services, or comply with legal obligations. We do not sell your personal data.

Service providers acting as our processors

We use trusted third‑party service providers to support our operations. These include:

- website hosting and analytics providers
- CRM, email marketing, and lead‑generation platforms
- meeting scheduling, video‑conferencing, transcription, and communication tools
- cloud storage, document creation, and collaboration platforms
- accounting, invoicing, and payment processing providers
- online learning and programme‑delivery platforms
- AI‑assisted tools used for research, drafting, and advisory work

These providers process personal data only on our instructions and only for the purposes described in this policy. They are contractually required to apply appropriate security measures and must not use your personal data for their own purposes.

Consultants and associates

We work with consultants and associates who assist in delivering our services. These individuals act under our direction and are required to follow our data protection policies, confidentiality obligations, and security standards. They do not process personal data for their own purposes.

Professional advisers

We may share personal data with professional advisers acting as independent controllers, including accountants, lawyers, insurers, and bankers, where necessary for accounting, legal, insurance, or consultancy purposes.

Regulators and authorities

We may disclose personal data to HM Revenue & Customs, regulators, law‑enforcement bodies, or other authorities acting as controllers where required to comply with legal or regulatory obligations.

Business transfers

If we sell, merge, or restructure all or part of our business, personal data may be disclosed to the relevant third party. Any new controller will be required to use your personal data in accordance with this policy.

Updates

We may engage additional service providers from time to time. Where this results in material changes to how we process personal data, we will update this section accordingly.

14. Cookies

Our website uses cookies in accordance with PECR and UK GDPR. Our cookie banner allows you to accept or decline non-essential cookies when you first visit our website. You can also manage cookies through your browser settings at any time, though disabling certain cookies may affect how the website functions.

For full details of the cookies we use, their purposes, and how to manage your preferences, please see our Cookie Policy

15. Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

16. International Transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
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- We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, EEA countries or Canada.
- We may use specific standard contractual terms approved for use in the UK whichgive the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

Please contact us at info@theimplicit.co.uk if you would like further information on the specific mechanism used when transferring your personal data outside the UK.

17. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed without authorisation. Access to your personal data is limited to those who have a business need to know it. They process your personal data only on our instructions and are subject to a duty of confidentiality.

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

18. Data Retention

We retain your personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain data for longer if there is a complaint or if we reasonably anticipate litigation.

In determining the appropriate retention period, we consider the volume, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it,and whether we can achieve those purposes by other means and the applicable legal, regulatory, tax,accountancy or other requirements.

For the purposes of defending or bringing a legal claim, we keep basic information about clients (including Contact, Identity, and Transaction Data) for seven years after the end of our contract for services.

In some circumstances, you may ask us to delete your data earlier please see Section 4 (your right to erasure) and contact us at info@theimplicit.co.uk.

Glossary:

Legitimate interests means the interests of our business in conducting and managing our business in order to provide the best service and secure experience to you. We consider and balance any potential impact on you and your rights before processing your personal data for our legitimate interests. We do notuse your personal data for activities where our interests are overridden by the impact on you, unless wehave your consent or are otherwise required or permitted by law.

Performance of contract means processing your personal data where it is necessary for theperformance of a contract to which you are a party, or to take steps at your request before entering intosuch a contract.

Legal obligation means processing your personal data where it is necessary for compliance with a legalor regulatory obligation to which we are subject.

Consent means any freely given, specific, informed, and unambiguous indication of your wishes by whichyou signify agreement to the processing of your personal data for a specific purpose. You have the right to withdraw consent at any time.