Achieve Breakthrough Limited Privacy Policy

Achieve Breakthrough Limited specialises in organisational and people development, helping businesses and leaders to grow, transform and thrive. We understand that your privacy is important to you, whether communicating with us, engaging Us to provide Services or using Our Site, and that you care about how your Personal Data is used and shared online and elsewhere. We respect and value your privacy and will only collect and use your Personal Data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

  • “Cookie” - means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 10, below;
  • “Cookie Law” - means the relevant parts of PECR;
  • “Data Protection Legislation” – means the Data Protection Act 2018 (“DPA”), the General Data Protection Regulation EU Regulation 2016/679 (“GDPR”), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”) and all other applicable laws, regulations, guidance and codes of practice (including any successor or replacement to any of the foregoing) relating to the processing of personal data and privacy;
  • “Our Site” – means our website at www.achievebreakthrough.com;
  • “Personal Data” - means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us when communicating with us, engaging with Our Services or using Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Legislation;
  • “Services” – means Our organisational and leadership coaching and consultancy Services, whether provided directly by Us or by independent associates on Our behalf; and
  • “We/Us/Our” - means Achieve Breakthrough Limited, a limited company registered in England and Wales under company number4738497, whose registered and trading address is The Long Barn, Sulis Down Business Village, Southstoke, Bath BA2 7PQ.

2. Information About Us

Our Site is owned and operated by Us.

Our VAT number is 190343812.

Our Data Protection Administrator can be contacted by email at info@achievebreakthrough.com, by telephone on 01225 852863, or by post at Our trading address above.

We will always comply (and be able to demonstrate Our compliance) with the Data Protection Legislation, when processing your Personal Data. Further details on the Data Protection Legislation can be found at the Information Commissioner’s Office website (www.ico.gov.uk).

You may also contact the Information Commissioner's Office (“ICO”) at :

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

https://ico.org.uk/concerns/ 0303 123 1113

For the purposes of the Data Protection Legislation, We will be the “controller” or “data controller” of all Personal Data processed in accordance with this Privacy Policy. We are registered with the ICO as a data controller - registration number ZA553248

We may from time to time engage independent associates to help provide Our Services to you on Our behalf. Where We do this, We will need to share your personal data with the independent associates in question as set out in this Privacy Policy. We will continue to be the controller, and the associates will act as a “processor” or “data processor”.

3. What Does This Privacy Policy Cover?

This Privacy Policy applies to use, by Us or on Our behalf, of any Personal Data in connection with communicating with you, providing Our Services and/or making Our Site available. Our Site may contain links to third party websites. Please note that We have no control over how these third parties collect, store or use yourPersonal Data and We advise you to check their privacy policies before providing any data to them.

4. Your Rights

As a data subject, you have the following rights under the Data Protection Legislation, which this Policy and Our use of Personal Data have been designed to uphold:

  • The right to be informed about Our collection and use of Personal Data (NB this information is set out in this Privacy Policy);
  • The right of access to the Personal Data We hold about you;
  • The right to rectification if any Personal Data We hold about you is inaccurate or incomplete;
  • The right to be forgotten – i.e. the right to ask Us to delete any Personal Data We hold about you (NB We only hold your Personal Data for a limited time, as explained in section 6);
  • The right to restrict (i.e. prevent) the processing of your Personal Data;
  • The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation);
  • The right to object to Us using your Personal Data for particular purposes; and
  • Rights with respect to automated decision making and profiling.

If you would like to exercise any of these rights or you have any cause for complaint about Our use of your Personal Data, please contact Our Data Protection Administrator.

5. What Personal Data Do We Collect?

We may collect some or all of the following data including Personal Data (please also see section 10 for Our policy on Our use of Cookies and similar technologies ):

  • your name;
  • your date of birth;
  • your business/company name
  • your job title;
  • your profession;
  • details about your organisation/business such as:
    • any business challenges you are experiencing,
    • the number of people employed by your business,
    • details of your business structure
    • details of your business’ turnover and profitability;
  • your contact information such as postal addresses, email addresses and telephone numbers;
  • your IP address;
  • your web browser type and version;
  • your operating system;
  • a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

6. How Do We Use Your Personal Data?

All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see section 7, below.

Our use of your Personal Data will always have a lawful basis including:

  • because it is necessary for Our performance of a contract with you
  • because you have consented to Our use of your Personal Data (e.g. by subscribing to emails)
  • because it is in Our legitimate business interests.

Specifically, We may use your Personal Data for the following purposes:

  • Supplying Our Services to you;
  • Communicating with you;
  • Supplying you with emails and other communications with your consent and/or where permitted by the Data Protection Legislation, specifically PECR;
  • Providing and managing your access to Our Site;
  • Personalising and tailoring your experience on Our Site;
  • Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience.

You have the right to withdraw your consent to Us using your Personal Data at any time; please note however that We may nevertheless be entitled and/or obliged to process your Personal Data in accordance with another lawful basis and/or for another purpose.

We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. We will also ensure that Our independent associates comply with this obligation. Data will therefore be retained (in accordance with Our internal data retention policies) for the following indicative periods or for as long as We have your permission to keep it:

  • Personal Data provided in connection with Us supplying a service will be kept for up to six calendar months after the end of the Services or Our last communication with you (whichever is later).
  • Personal Data provided in connection with feedback, testimonials and referrals will be kept for up to 6 years.
  • Personal Data provided in connection with direct marketing or newsletter subscriptions will be retained as long as your subscription remains active and your consent is considered to be valid.
  • Personal Data connected with analysing the use of Our Site will be kept for up to 2 years and anonymised where appropriate.

7. How and Where Do We Store Your Personal Data?

Some or all of your Personal Data may be stored and/or processed outside of the UK or European Economic Area (the “EEA”) (the EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If We do transfer or store Personal Data outside the UK or EEA, We will take all reasonable steps to ensure that your Personal Data is treated as safely and securely as it would be within the UK and under the Data Protection Legislation including ensuring that any overseas companies have appropriate security and privacy policies in place. This will usually be achieved by implementing standard data protection clauses (“Standard Contractual Clauses”) which We will adopt with the relevant recipient of the data; We will inform you in advance if other safeguards are to apply.

Data security is very important to Us, and to protect your Personal Data We have taken appropriate organisational and technological measures to safeguard and secure Personal Data collected when communicating with us, engaging with Our Services or using Our Site.

8. Do We Share Your Personal Data?

We may sometimes contract with third parties including independent associates to supply Services to you on Our behalf. In some cases, such third parties may require access to some or all of your Personal Data. Where any of your Personal Data is required for such a purpose, We will take all reasonable steps to ensure that your Personal Data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any Personal Data. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances, We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

We may, from time to time, seek to expand or reduce Our business and this may involve the sale and/or the transfer of control of, or an investment into, all or part of Our business. Any Personal Data that you have provided may where relevant be disclosed under terms of confidentiality to the potential purchaser or investor and may be transferred with any part of Our business on condition that the new owner or newly controlling party will, under the terms of this Privacy Policy, use that Personal Data only for the same purposes for which it was originally collected by Us.

9. How Can You Control Your Personal Data?

In addition to your rights under the Data Protection Legislation, set out in section 4, when you submit Personal Data in the course of communicating with us, engaging Our Services or using Our Site, you may be given options to restrict Our use of your Personal Data. In particular, We aim to give you strong controls on Our use of your Personal Data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

10. Our Use of Cookies


Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our Services. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, Services, and/or parties other than Us. Third party Cookies are used on Our Site for displaying content from other websites, e.g. YouTube or Twitter. In addition, Our Site uses analytics Services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site.

11. Data Breaches

A data breach is any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. We have industry-standard measures and procedures in place to detect, prevent and minimise such breaches. However, should any breach occur, We will evaluate its scope and impact and notify the ICO and any affected individuals as required by Data Protection Legislation within 72 hours.

12. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first communication with Us or your first use of Our Services or Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.