Engage to Succeed

Privacy Policy

Privacy Policy for Engage to Succeed

Last Updated: June 2026

1. Who We Are

This privacy policy explains how Engage to Succeed Ltd collects, uses, stores, and protects your personal data when you use our website, platform, or services.

Company name: Engage to Succeed Ltd

Company number: 13420979

Registered address: 5 Downview Avenue, Ferring, West Sussex, England, BN12 6QN

Incorporated: 26 May 2021

Trading as: Engage to Succeed

Email: james@engagetosucceed.com

Website: www.engagetosucceed.com

Platform: app.engagetosucceed.com

Engage to Succeed Ltd is the data controller for personal data collected through our website and platform. Where we process personal data on behalf of corporate clients (for example, processing employee assessment data), we act as a data processor and the client organisation acts as the data controller.

2. Regulatory Registration

Engage to Succeed Ltd is registered with the Information Commissioner's Office (ICO) as required under UK data protection law. Our ICO registration number is C1949854.

You have the right to make a complaint at any time to the 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.

3. Personal Data We Collect

We may collect, use, store, and transfer the following categories of personal data:

3.1 Identity Data

Full name
Job title and seniority level
Company or organisation name

3.2 Contact Data

Email address
Telephone number (if provided)
Postal address (if provided)

3.3 Assessment and Platform Data

Responses to engagement and performance assessments
Quadrant positioning data generated by the Engage to Succeed model
Individual scores, trend data, and historical assessment results
Goals, reflections, and commentary submitted within the platform
Team and organisational grouping data (as configured by the employer)

3.4 Technical Data

Internet Protocol (IP) address
Browser type and version
Device type and operating system
Session identifiers and authentication tokens
Time zone setting and geographical location (country/region level)

3.5 Usage Data

Pages and features accessed within the platform
Time and duration of visits
Actions taken within the platform (e.g. assessments completed, reports viewed)
Clickstream and navigation data

3.6 Communications Data

Emails, messages, and support queries you send to us
Records of consent to marketing communications
Call notes or meeting summaries from sales or onboarding conversations

3.7 Financial Data

Invoice and payment records (billing name, company, and reference)

Note: We do not store card payment details directly. Payment processing is handled by our payment provider(s) and is subject to their own privacy policies.

We do not intentionally collect any Special Category data (such as health, ethnicity, religion, political opinion, or biometric data). If you believe we have inadvertently received such data, please contact us at james@engagetosucceed.com so we can delete it.

4. How We Collect Your Personal Data

We collect data through the following means:

Directly from you — when you register for an account, complete an assessment, contact us, or sign up for communications
Automatically — through your use of our website and platform (via cookies, server logs, and similar technologies)
From your employer — where your organisation has subscribed to our platform and configured your access as part of an employee engagement programme
From third parties — such as LinkedIn or referral partners, where you have given consent for your data to be shared

5. Legal Basis for Processing

We are required under UK GDPR to have a lawful basis for processing your personal data. Our lawful bases are as follows:

Contractual necessity — to create and manage your account, deliver the platform service, provide assessments and reports, and manage billing relationships.
Legitimate interests — to improve our platform and services, conduct analytics, monitor security, and communicate service-related updates. We have assessed that our legitimate interests do not override your rights and freedoms.
Consent — where you have opted in to receive marketing communications. You may withdraw this consent at any time.
Legal obligation — to comply with applicable laws, including financial record-keeping, responding to lawful requests from regulators or law enforcement, and data breach notifications.

6. How We Use Your Personal Data

We use your personal data only for the purposes for which it was collected, including:

Creating and managing your user account on the platform
Delivering, maintaining, and improving the Engage to Succeed assessment platform and its features
Generating individual, team, and organisational engagement reports
Providing customer support and responding to your queries
Sending service-related notifications (e.g. assessment reminders, platform updates)
Sending marketing communications where you have consented to receive them
Conducting product analytics and usage monitoring to improve the platform
Meeting our legal and regulatory obligations
Preventing fraud, abuse, and unauthorised access

7. Who We Share Your Data With

We do not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients:

7.1 Sub-Processors and Service Providers

We use trusted third-party service providers who process data on our behalf under data processing agreements. These currently include:

Amazon Web Services (AWS): Cloud infrastructure, hosting, and data storage (EU/UK region)

Microsoft (Outlook 365): Email communications and business operations

Wix: Website platform and content management

All sub-processors are required to process your data only under our instruction, in accordance with this policy, and to maintain appropriate security measures.

7.2 Your Employer (B2B Clients)

Where you access the platform as an employee through your organisation's subscription, aggregated or individual engagement data may be visible to your employer's nominated administrators, as configured by your organisation. The scope of this access is governed by the Data Processing Agreement between Engage to Succeed Ltd and your employer.

7.3 Legal and Regulatory Disclosure

We may disclose your personal data where required to do so by law, court order, or at the request of a regulatory authority. We will notify you of any such request where we are legally permitted to do so.

8. International Data Transfers

Your personal data is hosted and processed within the United Kingdom and European Union using AWS infrastructure in the EU/UK region.

Where any of our sub-processors transfer data outside of the UK or EEA (for example, for technical support or analytics purposes), we ensure that appropriate safeguards are in place, including the use of UK International Data Transfer Agreements (IDTAs) or EU Standard Contractual Clauses (SCCs), or transfers to countries with an adequacy decision.

You may request further information about our international transfer mechanisms by contacting us at james@engagetosucceed.com.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our retention periods are as follows:

Active account data: Retained for the duration of your account plus 12 months following account closure

Assessment and platform data: Retained for the duration of the contract plus 2 years, unless deletion is requested earlier

Financial records: Retained for 7 years in accordance with UK accounting and tax requirements

Marketing consent records: Retained until consent is withdrawn, plus 2 years

Support communications: Retained for 3 years from last contact

Server and technical logs: Retained for up to 12 months for security and diagnostic purposes

At the end of the applicable retention period, personal data is securely deleted or anonymised. You may request early deletion of your data subject to the conditions set out in Section 10 below.

10. Your Rights Under UK GDPR

Under UK data protection law, you have the following rights in relation to your personal data:

Right of access — the right to request a copy of the personal data we hold about you (Subject Access Request).
Right to rectification — the right to request correction of inaccurate or incomplete personal data.
Right to erasure — the right to request deletion of your personal data ('the right to be forgotten'), subject to legal retention obligations.
Right to restriction — the right to request that we restrict the processing of your data in certain circumstances.
Right to data portability — the right to receive your data in a structured, commonly used, and machine-readable format.
Right to object — the right to object to processing based on legitimate interests or for direct marketing purposes.
Rights related to automated decision-making — the right not to be subject to a decision made solely by automated processing that produces significant legal or similar effects.
Right to withdraw consent — where processing is based on consent, the right to withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at james@engagetosucceed.com. We will respond within 30 days. We may need to verify your identity before processing a request. There is no charge for exercising your rights in most circumstances.

11. Cookies and Tracking Technologies

Our website (www.engagetosucceed.com) and platform (app.engagetosucceed.com) use cookies and similar tracking technologies. Cookies are small text files placed on your device to help us provide and improve our services.

11.1 Types of Cookies We Use

Strictly necessary cookies — required for the platform to function, including authentication, session management, and security. These cannot be disabled.
Functional cookies — remember your preferences and settings to improve your experience.
Analytics cookies — help us understand how the site and platform are used so we can improve them (e.g. page visit frequency, navigation patterns).

11.2 Managing Cookies

You can control and manage cookies via your browser settings. Disabling non-essential cookies will not affect your ability to use the core platform functionality. For more information on managing cookies, visit www.allaboutcookies.org.

12. Security of Your Data

We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit using TLS (HTTPS)
Encryption of data at rest on AWS infrastructure
Role-based access controls, ensuring staff and administrators can only access data necessary for their role
Regular security reviews and vulnerability assessments
Secure software development practices
Staff training on data protection obligations

Whilst we take all reasonable precautions, no method of transmission over the internet is completely secure. We cannot guarantee absolute security, but we will notify you and the ICO promptly in the event of a breach that poses a risk to your rights and freedoms.

13. Data Breach Notification

In the event of a personal data breach, we will:

Notify the ICO within 72 hours of becoming aware of the breach, where the breach is likely to result in a risk to the rights and freedoms of individuals
Notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms
Maintain a record of all data breaches, including those which do not require regulatory notification

If you believe your data has been compromised, please contact us immediately at james@engagetosucceed.com.

14. Children's Data

Our platform and services are not directed at, or intended for use by, individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will take prompt steps to delete it.

15. Automated Decision-Making and Profiling

Our platform uses your assessment responses to automatically generate a quadrant positioning result as part of the Engage to Succeed model. This is a facilitative tool designed to support personal and organisational development conversations — it does not produce legally significant decisions or outcomes, and it is always accompanied by human interpretation and support.

You have the right to request human review of any output produced by the platform that you believe has had a significant impact on you.

16. Third-Party Links

Our website and platform may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

17. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

Posting the updated policy on our website with a revised 'Last updated' date
Sending an email notification to registered users where the changes are significant

We encourage you to review this policy periodically. Continued use of the platform following notification of changes constitutes your acknowledgement of the updated policy.

18. Contact Us

If you have any questions, concerns, or requests relating to this privacy policy or how we handle your personal data, please contact us:

Name: James Lambert

Role: Director, Engage to Succeed Ltd