Privacy Notice

1. Background

Agar Management Consultancy understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information about us

Agar Management Consultancy Ltd is registered in England under company number 0957145.

Registered address:	Sigma House Oak View Close, Edginswell Park, Torquay, Devon, United Kingdom, TQ2 7FF
VAT Number:	222 3133 63
Email Address:	admin@agarmanagementconsultancy.co.uk
Telephone Number:	07730516664
Postal Address:	Agar Management Consultancy Ltd., Sigma House Oak View Close, Edginswell Park, Torquay, Devon, United Kingdom, TQ2 7FF

1. What does this notice cover?

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

1. What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we collect is set out in section 6, below.

1. What are my rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

1. 1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in section 12.
   2. The right to access the personal data we hold about you. Section 11 tells you how to do this.
   3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in section 12 for more information.
   4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in section 12 for more information.
   5. The right to restrict (i.e. prevent) the processing of your personal data.
   6. The right to object to us using your personal data for a particular purpose or purposes.
   7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
   8. Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 12.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

1. What personal data do you collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Name;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• Results from psychometric testing or other personality profiling.

1. How do you use my personal data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:

• Providing and managing your account.
• Supplying our products / services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and / or services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email and / or post that you have opted in to (you may opt-out at any time by contacting us on admin@agarmanagementconsultancy.co.uk

With your permission and / or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and / or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

1. How long will you keep my personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Legal and Regulatory Requirements

• UK GDPR and Data Protection Act 2018 compliance requirements
• HMRC requirements for financial records (typically 6 years)
• Employment law requirements for staff records
• Professional indemnity insurance policy requirements

Business Relationship Duration

• Length of active client contracts and engagements
• Duration of associate relationships
• Ongoing executive coaching commitments

Contractual Obligations

• Service level agreements with clients
• Associate contractor agreements
• Psychometric testing data handling requirements

Business Needs

• Need to demonstrate training outcomes and impact
• Maintaining continuity for repeat clients
• Historical reference for coaching journeys
• Evidence for quality assurance and accreditation

Type of Personal Data

• Psychometric assessment results and reports
• Coaching notes and development plans
• Contact and communication records
• Financial transaction details
• Staff employment records vs. associate contractor records

Legitimate Interests vs. Individual Rights

• Whether data is necessary for ongoing service delivery
• The sensitivity of the data being retained

Sector-Specific Considerations

• Educational sector expectations around professional development records

1. How and where do you store or transfer my personal data?

We share your data with external third parties, as detailed below in section 10, that are based outside of the EEA. The following safeguard is applied to such transfers:

We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.

Please contact us using the details below in section 12 for further information about the particular data protection mechanism used by us when transferring your personal data to external third parties.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• We store all of our data on Google Drive. Access to Google Drive is password protected and employees only have access to the files that are relevant and necessary for their job role.
• All Agar employees and associates are contractually obligated to adhere to GDPR regulations.

1. 10.   Do you share my personal data?

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply products or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Zoho CRM: This is a cloud-based software application from Zoho Corporation that helps us to manage sales, marketing, and client support activities. Client name, email address, role and company name are stored on our Zoho CRM application. Zoho Corporation was founded in the USA and it is headquartered in India. Zoho CRM is equipped to comply with the GDPR as a data processor. Zoho CRM provides many options that are designed to help us safeguard your data and meet the security and privacy standards set in GDPR.

• Profiling Tools: We use various profiling tools which provide a questionnaire service which, once completed, automatically produces a profile / report for our clients. We share client name, email address and company name on these platforms. The profiling tools we use adhere to GDPR legislation.

If any of your personal data is required by a third party, as described above we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in section 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in section 9.

1. 11.   How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in section 12. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

1. 12.   How do I contact you?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: [(for the attention of Jack Orchard, Director)]:

For the attention of:	Jack Orchard, Joint CEO
Email Address:	admin@agarmanagementconsultancy.co.uk
Telephone Number:	07730516664
Postal Address:	Agar Management Consultancy Ltd., Sigma House Oak View Close, Edginswell Park, Torquay, Devon, United Kingdom, TQ2 7FF

1. 13.   Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on this page of our website.

Last reviewed: December 2025