Privacy Policy

1. Data Controller

ManagerMate Ltd is the data controller responsible for your personal data.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the details above.

2. Information We Collect

We collect several types of information to provide and improve our Service:

Personal Information You Provide

• Account Information: Name, email address, password, job title, company name, and phone number (optional)
• Profile Information: Management experience level, team size, industry, areas of interest
• Communications: Messages you send to our support team or through feedback forms

Information from Your Use of the Service

• Learning Activity: Training modules completed, time spent on platform, progress through courses, assessment results
• AI Coach Interactions: Questions asked, scenarios practised, conversations with Hilary (our AI coach)
• Usage Data: Pages visited, features used, session duration, click patterns
• Device Information: IP address, browser type, operating system, device identifiers
• Performance Data: Skill development tracking and team insights

Automatically Collected Information

• Cookies and Similar Technologies: We use cookies to enable essential functionality, remember your preferences, and understand how you use our Service
• Analytics Data: Information about how you interact with our Service to help us improve user experience

3. How We Use Your Information

We use the information we collect for the following purposes and on the legal bases set out below:

Purpose	Description	Legal Basis
Service Delivery	Provide access to training, AI coaching, and personalised recommendations	Performance of contract
Personalisation	Customise content and learning paths based on your needs and progress	Performance of contract / Legitimate interests
Service Improvement	Analyse usage patterns and improve our Service (including AI models) using de-identified and aggregated interaction data	Legitimate interests
Communication	Send service updates, respond to enquiries, and (where you have opted in) marketing	Performance of contract / Consent
Security	Detect, prevent, and address fraud, abuse, and security issues	Legitimate interests / Legal obligation
Legal Compliance	Comply with legal obligations and enforce our Terms	Legal obligation / Legitimate interests

4. Legal Basis for Processing (UK GDPR)

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, we must have a lawful basis for processing your personal data. Depending on the context, we rely on the following bases:

• Performance of a Contract: Processing necessary to provide the Service you have requested and to fulfil our contractual obligations to you
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our Service, preventing fraud, and ensuring security. We balance these interests against your rights and will not process data where the impact on you outweighs our interests
• Consent: Where you have given explicit consent for specific processing activities (e.g., marketing communications). You can withdraw consent at any time
• Legal Obligation: Processing necessary to comply with laws and regulations (e.g., tax and financial reporting requirements)

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

We work with carefully selected third-party companies to provide essential services:

• Cloud Hosting: To host and operate our platform (e.g., AWS, Google Cloud)
• Analytics Tools: To understand usage patterns and improve our Service
• Email Services: To send transactional emails and communications
• Customer Support Tools: To help us provide customer assistance

These providers act as data processors on our behalf and are contractually obligated to protect your data and use it only for the specified purposes.

Business Transfers

If ManagerMate Ltd is involved in a merger, acquisition, reorganisation, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a different privacy policy.

Legal Requirements

We may disclose your information where required by law or where we reasonably believe disclosure is necessary to:

• Comply with legal processes, court orders, or government requests
• Enforce our Terms & Conditions
• Protect our rights, property, or safety, or that of our users or the public
• Prevent fraud, security threats, or illegal activity

Business Plan Administrators

If your access to ManagerMate is provided through a Business plan by your employer or organisation:

6. International Data Transfers

Some of our service providers may process your data outside the United Kingdom. Where this occurs, we ensure appropriate safeguards are in place to protect your data, including:

• Transfers to countries recognised by the UK government as providing adequate data protection
• Standard Contractual Clauses (SCCs) approved for use in the UK
• Other appropriate safeguards as permitted under UK data protection law

You may contact us for more information about the specific safeguards in place.

7. Data Security

We take the security of your information seriously and implement appropriate technical and organisational measures to protect it, including:

• Encryption: Data is encrypted in transit using TLS/SSL and encrypted at rest
• Access Controls: We operate strict access controls and limit access to personal data to employees and contractors who need it to perform their roles
• Secure Infrastructure: Our platform is hosted in secure, certified data centres with appropriate physical and logical security measures
• Security Assessments: We conduct regular security assessments and vulnerability testing
• Staff Training: Our team receives regular training on data protection and security best practices
• Incident Response: We maintain procedures to detect, report, and respond to personal data breaches

While we implement robust security measures, no system is completely secure. In the unlikely event of a data breach affecting your personal data, we will notify you and the relevant authorities as required by law.

8. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to:

• Provide you with our Service
• Comply with legal, accounting, and regulatory obligations
• Resolve disputes and enforce our agreements

Our specific retention periods are as follows:

• Account Information: Retained while your account is active and for 90 days after deletion to allow for account recovery and complete backup deletion
• Learning Activity: Retained while your account is active and for up to 2 years after account deletion for analytics and service improvement purposes
• AI Coach Interactions: We use de-identified and aggregated interaction data to improve our AI models. Original conversation content associated with your account is deleted within 1 year of your last interaction or upon account deletion
• Communications: Support correspondence retained for 3 years to maintain service quality and resolve any ongoing issues

When retention periods expire, we securely delete or de-identify your data.

9. Automated Decision-Making

We use algorithms and AI to provide personalised recommendations, learning paths, and coaching responses. These systems help tailor your experience but do not make decisions that produce legal effects or similarly significant effects on you without human involvement.

If you have concerns about how automated systems affect your use of the Service, please contact us.

10. Your Rights

Under UK data protection law, you have the following rights regarding your personal information:

Exercising Your Rights

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

We will respond to your request within one month. In complex cases or where we receive multiple requests, we may extend this by a further two months, but we will inform you if this is necessary.

We may ask you to verify your identity before processing your request.

11. Opting Out

• Marketing Emails: You can unsubscribe from marketing communications at any time using the link in any email or through your account settings. You will continue to receive essential service communications.
• Analytics and Non-Essential Cookies: You can manage your cookie preferences through our cookie settings or your browser settings. Please note that refusing certain cookies may affect functionality.
• Google Analytics: You can opt out of Google Analytics using the Google Analytics Opt-out Browser Add-on.

12. Cookies and Similar Technologies

We use cookies and similar technologies as follows:

• Essential Cookies: Required for basic site functionality, such as maintaining login sessions and security features. These cannot be disabled.
• Analytics Cookies: Help us understand how users interact with our Service so we can improve it. These are only used with your consent where required by law.
• Preference Cookies: Remember your settings and preferences to enhance your experience.
• Marketing Cookies: Used to deliver relevant advertisements and measure campaign effectiveness. These are only used with your consent.

You can manage non-essential cookies through our cookie settings. Refusing analytics and marketing cookies does not affect your ability to use the Service.

13. Children's Privacy

ManagerMate is not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal data from someone under 18, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us.

14. Third-Party Links

Our Service may contain links to third-party websites or services that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of any third-party sites you visit.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes:

• We will update the "Last Updated" date at the top of this policy
• For material changes, we will notify you by email or through a prominent notice on our platform before the changes take effect
• Where required by law, we will obtain your consent to material changes

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes become effective indicates your awareness of the updated policy.

16. Complaints

If you are unhappy with how we have handled your personal data, we encourage you to contact us first so we can try to resolve the issue:

Email: info@managermate.co.uk

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

MANAGERMATE LTD
Company Number: 17527841
Email: info@managermate.co.uk
Data Protection Contact: info@managermate.co.uk