Privacy Policy

No More Ifs Or Buts (Trading as Alpha Lupa)

Last updated: January 2026
 
Alpha Lupa (“Alpha Lupa”, “we”, “our”, “us”) is committed to protecting and respecting your privacy.
This policy explains how we collect, use and store personal data when you interact with Alpha Lupa, including when you visit our website, participate in our programmes, complete assessments or communicate with us.
We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

Alpha Lupa provides leadership development, management training, diagnostics and coaching services to organisations and individuals.
 
Alpha Lupa is the data controller for the personal data described in this policy.
 
If you have any questions about this policy or how your data is handled, please contact:
 
Email: hi@alphalupa.co.uk
Registered address: 41 Blakes Lane, New Malden, Surrey, KT3 6NS
 
Alpha Lupa is registered in England and Wales.

2. Personal Data We Collect

We collect personal data that you provide directly to us or that is generated through your participation in our services.

Contact Information

This may include:
 
  • name
  • email address
  • job title
  • organisation
  • phone number (where provided)

Programme Participation Data

If you participate in Alpha Lupa programmes (such as Lessons, Labs, Academies or Coaching), we may collect information relevant to programme delivery, including:
 
  • session attendance
  • feedback or survey responses
  • reflections or exercises completed as part of learning activities

Assessment Data

Some Alpha Lupa programmes include professional development assessments and reflective learning tools. These may include:
 
  • pre and post programme assessments
  • DISC behavioural profile assessments (provided via PeopleKeys)
  • self-reflection tools and exercises
  • other learning or diagnostic tools used within leadership development programmes
 
These tools are designed to support self-awareness, reflection and professional development.
 
They are not psychological, medical or clinical assessments and are used solely within the context of learning and development programmes.
 
DISC profiles are behavioural preference indicators designed to support understanding of working styles and team dynamics. They do not measure ability, personality traits or psychological health.
 
Individual assessment results are primarily shared with the participant to support personal reflection and development.
In some programmes, such as DISC workshops, participants may choose to share or discuss aspects of their results within the learning group as part of facilitated activities.
 
Where DISC or similar assessments are used, the client organisation may receive a group-level report summarising overall behavioural patterns or team dynamics. Individual reports remain with the participant unless explicit consent is provided for them to be shared.

Contract and Transaction Data

If you or your organisation work with Alpha Lupa, we process information required to manage our contractual relationship. This includes:
 
  • contract details
  • invoice information
  • payment records
  • contact details for billing and administration

Website Usage Data

When you visit our website we may collect information including:
 
  • IP address
  • browser type
  • device information
  • pages visited and time spent on the site
 
This information helps us understand how our website is used and improve the user experience.

3. How We Use Personal Data

We process personal data in order to:
 
  • deliver leadership development programmes and coaching
  • provide assessments and learning tools
  • manage programme logistics and communication
  • support learner development through pre-session preparation, follow-up communication and post-programme reflection
  • respond to enquiries or requests
  • improve our services and learning materials
  • manage contracts and payments
  • send occasional updates about programmes, resources or events
 
Marketing communications are sent only where we have a lawful basis to do so, such as consent or an existing professional relationship. You can opt out of these communications at any time by using the unsubscribe link included in our emails.

4. Programme Communication

Where leadership programmes, workshops, coaching or learning sessions are delivered through an organisation, Alpha Lupa may contact participants directly as part of the learning experience.
This may include communication:
 
  • before sessions (for example preparation materials or assessments)
  • between sessions (reflection activities or follow-up resources)
  • after sessions (feedback, development insights or post-programme assessments)
 
These communications are designed to support participant learning and development and form part of the programme being delivered.

5. Legal Basis for Processing

Under UK GDPR we rely on the following lawful bases:
 
Contract
Processing necessary to deliver services requested by you or your organisation.
 
Legitimate Interests
Processing necessary to operate and improve our services, manage client relationships and deliver learning programmes.
 
Where we rely on legitimate interests, we assess and balance our interests against the rights and freedoms of individuals to ensure that personal data is handled fairly and transparently.
 
Consent
In some cases we rely on consent, such as when sending marketing communications or providing optional assessments. Consent can be withdrawn at any time.

6. How We Store and Manage Data

We use secure professional platforms to manage communications, documents and programme delivery. These may include:
 
  • ActiveCampaign – email communication and marketing
  • Google Drive / Google Workspace – document storage and collaboration
  • PandaDoc – contracts and digital signatures
  • PeopleKeys – DISC behavioural profile assessments
  • Microsoft systems – administration and communication
  • Adobe tools – document management and learning materials
  • AI tools – used to support content development
 
Personal data is only entered into systems where appropriate safeguards are in place.
These providers may process personal data on our behalf as data processors. Where this occurs, we ensure appropriate data protection agreements and safeguards are in place in accordance with UK GDPR.

7. Data Sharing

We do not sell personal data.
We may share personal data with trusted service providers where necessary to deliver our services, including the platforms listed above.
Where programmes are delivered through an organisation, we may provide aggregated or anonymised insights to support organisational learning and development.

8. International Data Transfers

Some of the technology providers we use operate internationally. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place such as:
 
  • UK adequacy regulations
  • standard contractual clauses
  • equivalent data protection safeguards

9. Data Retention

We retain personal data only for as long as necessary for the purposes outlined in this policy.
Typical retention periods include:
 
  • programme participation data retained for programme evaluation and development
  • assessment data retained only for the duration necessary to deliver the programme and provide follow-up insights unless a longer retention period is agreed with the client organisation
  • contract and financial records retained for legal and accounting requirements
  • marketing communications retained until you unsubscribe
 
When data is no longer required it is securely deleted or anonymised.

10. Cookies and Website Analytics

Our website uses cookies and similar technologies to improve the user experience and understand how visitors use the site.
We use Google Analytics to collect information such as:
 
  • pages visited
  • time spent on the site
  • device and browser type
  • general geographic location
 
This information is collected in aggregated form where possible and helps us improve the website and our services.
You can control or disable cookies through your browser settings.

11. Your Rights

Under UK GDPR you have the right to:
 
  • request access to the personal data we hold about you
  • request correction of inaccurate information
  • request deletion of your data where appropriate
  • restrict or object to certain processing
  • withdraw consent where processing relies on consent
  • request transfer of your data to another provider
 
To exercise any of these rights please contact us at:
Email: hi@alphalupa.co.uk

12. Complaints

If you have concerns about how your data is handled, please contact us so we can try to resolve the issue.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
 

13. Updates to This Policy

We may update this privacy policy from time to time to reflect changes in our services, technology or legal obligations. The latest version will always be available on our website.

Questions about your data?

At Alpha Lupa, we believe clarity is the foundation of high performance—and that includes how we handle your information. If you have questions about this policy or your data rights, our team is ready to help.