1. About this policy

This policy explains how Authentic Change Solutions Ltd (ACS, we, us, our) collects and uses personal data when you visit our programme website https://www.globalleadershiphypothesis.com/ (the Site), sign up for our content, take part in a survey or contact us. It covers our programmes, including The Global Leadership Hypothesis and Finance Inspired 4 Success.

We are the controller of your personal data, which means we decide how and why it is used. We process it in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 as amended by the Data (Use and Access) Act 2025, and the Privacy and Electronic Communications Regulations 2003 (PECR).

Our Site is built and hosted on ClickFunnels, which also runs our sign-up forms and email. 

Some pages may link to our course platform or to other websites, which have their own policies (see section 11).

2. Who we are and how to contact us

Item Details

Legal entity Authentic Change Solutions Ltd, registered in England and Wales, company number 10294599

Registered office 2 Turbary Road, Fleet, Hampshire GU51 1GH, United Kingdom

ICO data protection fee registration ZA242099

Data Protection Officer Marcus Holtzhausen

Privacy contact email enquiries@authenticityresolved.com (mark your email "Privacy")

Telephone +44 (0)1252 623899

Please tell us if your details change so we can keep our records accurate.

3. The personal data we collect

We collect only what we need for the purposes in section 5. Depending on how you deal with us, this may include:

• Identity data: first name, last name and title.

• Contact data: email address and, if you give it, telephone number.

• Professional data: job title, organisation and sector, where you choose to give them (for example, in a survey or enquiry).

• Survey and feedback data: your answers to our pulse surveys, questionnaires and feedback forms.

• Marketing and communications data: your preferences about hearing from us, and records of your consent or opt-out.

• Email engagement data: whether our emails were delivered and opened and which links were clicked (see section 7).

• Technical and usage data: IP address, browser and device type, pages visited and how you arrived at the Site, collected through cookies and similar technologies (see section 10).

Special category data. We do not ask for information about your health, ethnicity, religion or beliefs, sexual orientation, political opinions, trade union membership, genetic or biometric data, or criminal offences. Please do not include it in free-text survey answers or messages. If you do, we will use it only to deal with your message or delete it.

Anonymised data. We may combine survey results or Site statistics so that no one can be identified, and use that for research and to improve our programmes. Anonymised data is not personal data.

4. How we collect your data

• Directly from you: when you fill in a form on the Site, download a resource (for example our knowledge gifts or the Tali Ho Toolkit), sign up for our emails, register for an event or webinar, complete a pulse survey or contact us.

• Automatically: when you use the Site or open our emails, through cookies, pixels and similar technologies, subject to your choices (see sections 7 and 10).

We do not buy personal data from data brokers or list providers.

5. How we use your data and our lawful bases

We must have a lawful basis for each use of your data. The table below sets out what we do and why.

What we do Data used Lawful basis

Send you a resource, toolkit or download you asked for Identity, contact Contract (or steps you asked us to take before one)

Send you our newsletter and information about our programmes, events and services Identity, contact, marketing, email engagement Consent. For existing customers, our legitimate interests in telling you about similar services, with an opt-out in every email

  

Reply to your enquiries and manage our relationship with you, including telling you about changes to this policy Identity, contact, professional Legitimate interests in responding to you and running our business

Keep a suppression list so we do not email you after you opt out Email address, opt-out record Legal obligation (PECR) and legitimate interests

Run, secure and fix the Site and prevent misuse or fraud Technical, usage Legitimate interests in keeping our Site and systems secure and preventing crime

Understand how visitors use the Site through non-essential cookies Technical, usage Consent, given through our cookie banner

Keep business and tax records and meet our legal and regulatory duties Identity, contact, transaction Legal obligation

Where we rely on legitimate interests, we have weighed our interests against yours. You can ask us for details, and you can object at any time (section 9).

New purposes. We will use your data for a new purpose only if it is compatible with the original one or the law allows it. If it is not compatible, we will tell you first and explain the lawful basis.

Automated decisions. We do not make decisions about you based solely on automated processing that have a legal or similarly significant effect on you.

6. Email marketing

• We send marketing emails only where you have opted in, or where you are an existing customer and we are telling you about similar services, and you have not opted out.

• Every email includes an unsubscribe link. You can also email enquiries@authenticityresolved.com with "Unsubscribe" in the subject line.

• Opting out of marketing does not stop service emails you need, such as confirmation of a download or an event you have registered for.

• We do not sell your data or share it with other organisations for their own marketing.

7. Email tracking

Our emails are sent through ClickFunnels and may contain small tracking pixels and tracked links. These tell us whether you opened an email and which links you clicked, so we can see what content is useful and remove contacts who no longer engage. You can stop this by disabling images in your email program or by unsubscribing.

8. Who we share your data with

We share personal data only where needed for the purposes above. The organisations we use act on our instructions as processors under written contracts, except where stated.

Recipient Purpose Location and safeguard

ClickFunnels (Etison, LLC) Hosting the Site, forms, contact management and email delivery United States. UK Addendum to the EU standard contractual clauses

Thinkific Labs Inc. Our course platform, if you choose to enrol on a course Canada (UK adequacy) and its sub-processors under the UK Addendum

  

Professional advisers Accountants, lawyers and insurers, where needed United Kingdom

HMRC, regulators and law enforcement Where the law requires or allows us to United Kingdom

A buyer or successor of our business If we sell, transfer or merge all or part of our business. Your data would remain protected by this policy As applicable

9. Transfers outside the UK

Some of our providers store or access data outside the UK. Where they do, we make sure your data stays protected by at least one of the following:

• a UK adequacy regulation for the destination country (for example Canada for commercial organisations and the EU/EEA);

• for US providers certified to the UK Extension to the EU-US Data Privacy Framework (the "UK-US data bridge"), that certification;

• otherwise, the ICO-approved International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses.

Contact us if you would like more information about the safeguard used for a particular provider.

10. Cookies and similar technologies

The Site uses cookies and similar technologies. Cookies that are strictly necessary for the Site to work are set automatically. We set analytics or other non-essential cookies only if you agree through our cookie banner, and you can change your choice at any time. Full details of the cookies we use, and how to manage them, are in our Cookie Policy at https://www.globalleadershiphypothesis.com/home-page-glhypo.

11. Links to other websites

The Site may link to other websites, such as our course platform, Amazon (for our books), YouTube or LinkedIn. Those sites have their own privacy policies, and we are not responsible for how they use your data. Please read their policies before giving them any information.

12. How long we keep your data

Data How long we keep it

Email subscribers Until you unsubscribe. If you do not open or click any of our emails for [24] months, we will ask whether you want to stay subscribed and remove you if you do not reply

Suppression list (email address and opt-out date only) For as long as we send marketing, so we do not contact you again

Enquiries and correspondence [2] years after our last contact with you

Survey responses linked to you [3] years after the survey closes. Anonymised results may be kept indefinitely

Customer and financial records 6 years after the end of the financial year they relate to, to meet tax and company law requirements

Technical and cookie data As set out in our Cookie Policy

When data is no longer needed, we delete it securely or anonymise it.

13. How we keep your data secure

We use appropriate technical and organisational measures to protect your data, including access controls, strong passwords with multi-factor authentication on our accounts, encrypted connections and processors who meet recognised security standards. Card details are handled by our payment providers to the PCI-DSS standard and are never stored by us.

No system is completely secure. If a personal data breach occurs, we will report it to the ICO within 72 hours where required and tell you without undue delay if it is likely to put your rights and freedoms at high risk.

14. Your rights

You have the following rights over your personal data:

• To be informed about how we use your data, which is what this policy does.

• Access: to ask for a copy of your data.

• Rectification: to have inaccurate or incomplete data corrected.

• Erasure: to have your data deleted in certain circumstances.

• Restriction: to ask us to limit how we use your data.

• Objection: to object to processing based on our legitimate interests. You have an absolute right to object to direct marketing.

• Portability: to receive data you gave us in a commonly used format, or have it sent to another organisation, where processing is based on consent or contract and carried out by automated means.

• Withdraw consent at any time, where we rely on it. This does not affect processing already carried out.

• Rights about automated decision-making. We do not make solely automated decisions about you, as explained in section 5.

• To complain to us and to the ICO (section 15).

Making a request

Email enquiries@authenticityresolved.com or write to us at the address in section 2. There is no fee unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse it.

• We may need to confirm your identity first. If so, or if we need you to clarify a request, the time limit starts once we have what we need.

• We will respond within one month. For complex or multiple requests, we may extend this by up to two further months and will tell you why within the first month.

• For access requests, we will carry out a reasonable and proportionate search for your data.

15. Complaints

If you are unhappy with how we have handled your personal data, please contact our Data Protection Officer first using the details in section 2. We will acknowledge your complaint within 30 days, look into it without undue delay and tell you the outcome.

You also have the right to complain to the ICO, the UK regulator for data protection:

• Website: ico.org.uk/make-a-complaint

• Telephone: 0303 123 1113

• Post: ICO, 4th Floor, No.3 Circle Square, 5 Hawkshaw Street, Manchester M1 7BL

The regulator usually expects you to raise your complaint with us first.

16. Children

Our programmes and the Site are intended for adults in professional roles and are not aimed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, please contact us, and we will delete it.

17. Changes to this policy

We review this policy at least once a year and when our practices or the law change. The date at the top shows when we last updated it. If we make significant changes, we will tell subscribers by email or put a notice on the Site.