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Privacy Policy

1. Who We Are

Achord Foundation is a charity registered with the Charity Commission for England & Wales (Charity No. 1189169), with its registered address at Kingfisher House, Hurstwood Grange, Hurstwood Lane, Haywards Heath, West Sussex, RH17 7QX. This policy also applies to services delivered through The 4 Habits Institute (trading under Soulmates Academy Ltd, UK Co. No. 10742386), under a licensing
agreement.

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2. Our Commitment to Privacy
We are committed to protecting your personal data and respecting your privacy. This policy outlines what data we collect, how we use it, and your rights under UK GDPR and the Data Protection Act 2018.

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3. Lawful Basis for Processing
We only process personal data where we have a lawful basis to do so, including:

  • Consent (e.g. email sign-ups)

  • Contractual necessity (e.g. course enrolment)

  • Legitimate interests (e.g. improving services)

  • Legal obligation

 

4. What Data We Collect
Depending on your interaction with us, we may collect:

  • Identity data (e.g. name, email address)

  • Contact data (e.g. phone number, address)

  • Technical data (e.g. IP address, browser type)

  • Profile data (e.g. course progress, survey responses)

  • Marketing preferences

 

5. How We Collect Your Data
We collect data:

  • When you register for courses via Thinkific

  • When you subscribe to newsletters or contact us

  • Through cookies and analytics tools

 

6. Use of Third-Party Platforms
Our online courses are delivered via Thinkific, a third-party learning management system. We remain the data controller and Thinkific acts as our data processor under a GDPR-compliant Data Processing Agreement.

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Thinkific uses Amazon Web Services (AWS) for hosting, with data potentially processed outside the UK/EEA under Standard Contractual Clauses and the UK Addendum.

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7. Subprocessors & Integrations
We may use subprocessors (e.g. Mailchimp, Stripe) to provide communications, payment processing, and analytics. All subprocessors are bound by contractual obligations to protect your data.

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8. Children’s Data
We do not knowingly collect data from children under 16 without parental consent. If you are under 16, please do not submit personal data unless a parent or guardian does so on your behalf.

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9. Retention
We retain your data for up to four years after your last interaction unless required longer by law. After that, data is securely deleted or anonymised.

 

10. Your Rights
You have the right to:

  • Access your data

  • Request correction or deletion

  • Object to processing

  • Withdraw consent

  • Lodge a complaint with the ICO (ico.org.uk)

 

11. Cookies and Analytics
We use cookies to understand site usage and improve performance. You can manage cookie preferences via your browser.

 

12. Data Security
We use industry-standard security measures including encryption, secure hosting, and access controls. We regularly review our security posture.

 

13. Updates
We may update this policy from time to time. The latest version will always be available on our website. If you have subscribed to our emails, we will notify you of significant changes.

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14. Data Protection Officer
Our Data Protection Officer is Jonathan Taylor-Cummings. You can contact him at jonathan.tc@achordfoundation.org or by post at Achord Foundation, Kingfisher House, Hurstwood Grange, Hurstwood Lane, Haywards Heath, West Sussex, RH17 7QX.

 

15. Contact Us
For any questions, or to exercise your rights, contact us at: hello@achordfoundation.org

 

​This Privacy Policy was last updated in September 2025.

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