Privacy Policy

The Developing Leaders Partnership/Gyre®: Privacy Policy

Last Update: January 2024

The Developing Leaders Partnership Limited (“DLP”) respects the privacy of every person who interacts with The Developing Leaders Partnership Limited and our Gyre services, and we are committed to ensuring high standards of data protection compliance in everything we do.

1. What is the purpose of this Notice?

1.1. This privacy notice applies to all services we provide across the web, social media, apps and elsewhere (the “Gyre Services”). It explains our approach to how we use any personal information that is provided to or collected by us in connection with your use of the Gyre Services or any other interaction you have with DLP / Gyre.

1.2. This privacy notice also sets out the legal basis on which we are permitted to process your personal information, your rights in respect of our use of your personal information, how you can verify what personal information is collected by us, and how you can request that we delete, update or transfer it.

1.3. This privacy notice is intended to assist you in making informed decisions when using the Gyre Services. Please read it thoroughly.

1.4. The privacy notice covers various groups of people about whom we collect and process data:

Visitors to our website, and others with whom we have contact – see section 4

Users of our app.gyreteams.com platform (which is subject to a separate services contract with The Developing Leaders Partnership Limited) – see section 5
Other feedback providers/invitees on our app.gyreteams.com platform– also see section 5

2. Who are we?

2.1. The Gyre Services are operated by The Developing Leaders Partnership Limited (“DLP”, “Gyre”, “we” “us” or “our”).

2.2. The Developing Leaders Partnership Limited is registered at the UK Information Commissioner’s Office with registration number: ZA211962

2.3. The Developing Leaders Partnership Limited is an English company with registered company number: 10357459 and whose registered address is Floor 2, 201 Great Portland Street London W1W 5AB.

3. How to contact us?

3.1. If you have any questions about this privacy notice or want to exercise your rights, please contact us by: sending an email to support@gyreteams.com or writing to us at Gyre, Floor 2, 201 Great Portland Street London W1W 5AB

4. Visitors to our Website / Other contacts

a) What personal information do we collect about Visitors to our Website (or others that we have contact with) and how do we collect it?

When you visit and/or register your details on app.gyreteams.com (or other website or app we provide, other than the app.gyreteam.com platform services below), or we otherwise have contact with you, personal information may be collected from you in the following ways:

Information you voluntarily provide to us directly.

We collect and maintain personal information that you voluntarily submit to us for example when you sign up for a newsletter, enter a survey or competition, respond to a questionnaire, post comments or make other contact with us.

This may include:

Name;

Email Address;

Address;

Phone number;

Job title;

Employed industry sector;

Records of our correspondence or communications.

We collect, through our use of cookies or other technologies, information about your use of and navigation around the Gyre website, including information regarding your mobile device or the computer hardware and software used to access the Gyre Services.

This may include the following:

IP address of device(s) used;
browser type; operating system and device type;
approximate location (e.g. London);
access times and dates; referring website addresses;
navigation around the site;
links followed, including in emails;
time spent on pages or viewing content;
types of content viewed and shared.

Please see the Data Analytics, Insight and Profiles section below and our Cookie Section below for further information.

b) How do we use the personal information about Visitors to our Website and Others we have contact with?

We use the personal information for the following purposes:

Sending you newsletters or other communications (from DLP) for which you have subscribed.

Where you have requested that we send you newsletters and other marketing materials about Gyre or DLP products and services which we think might be of interest to you.

What is our legal basis for this?

We rely on your consent to be able to do this – given at the time that you request the newsletter or other marketing.

Running surveys, questionnaires, competitions and/or promotions.

We may collect and use your personal information in connection with any survey, competition and/or promotion that you enter.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to operate the survey, questionnaires, promotion and/or competition.

Data Analytics, Insight and Profiles.

We analyse your personal information including that which we observe about you from your interactions with the Gyre website and our email communications with you.

This information is used to create insights about usage habits across our website. By using this information, we are able to measure how visitors use the Gyre website.

What is our legal basis for doing this?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will not constitute

“personal information” that is regulated under data protection laws. However, our collection and use of such anonymised personal information may still be subject to other laws where your consent is required. Please see our Cookie Section below for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best content and services to you and our other users.

5. app.gyreteams.com – Registered Users of OUR VIEWPOINTS Platform

a) What personal information do we collect about our app.gyreteams.com?

When you register with or log in to the app.gyreteams.com platform, personal information may be collected from you in the following ways. This applies whether you are an employee or other authorised user or invitee under another’s account (such as your employer or coach), or have your own individual account and contract with DLP.

Information you voluntarily provide to us directly.

We collect and maintain personal information that you voluntarily submit to us, for example when you register, log in or make other contact with us.

This may include:

Name;

Email Address;

Job Title ;

And any other data you submit to us.

Viewpoints information we collect through your use of the app.gyreteams.com platform.

We collect and maintain personal information that you submit to us, or others submit about you, as part of the review service.

This may include:

Name;

Role;

Viewpoints review information.

Other technical information we collect through your use of the app.gyreteams.com platform.

We collect, through our use of cookies or other technologies, information about your use of and navigation around the app.gyreteams.com platform.

This may include the following:

IP address of device(s) used;
browser type;
operating system and device type;
approximate location (e.g. London);
access times and dates;
navigation around the platform;
links followed, including in emails;
time spent on pages or viewing content;
types of content viewed and shared.

Please see the Data Analytics, Insight and Profiles section below and our Cookie Section below for further information.

b) How do we use the personal information about app.gyreteams.com platform Users?

We use the personal information we collect from or about app.gyreteams.com platform Users for the following purposes:

Provision of the Gyre Service.

We need to use your information to log you in, verify who you are, provide you or the account holder (such as the employer or coach) with the contracted service, and ensure you get the service that you have registered for.

We will also share relevant information between the relevant authorised account holder / entity (which may be the employer or coach) and the reviewer or feedback person, to facilitate the feedback and review services we provide.

What is our legal basis?

It is necessary for the performance and fulfilment of the contract between us and the account holder / entity authorising you to access the platform, and to provide you with services for which you have registered.

Sending you suggestions about your use of the service, newsletters or other communications (from DLP).

Where you are a registered user we may use your personal information to send you tips, suggestions, newsletters and other materials about the Gyre Services which we think you might be of interest to you.

What is our legal basis for this?

It is in our legitimate interest to process your information in this way to improve our service and grow our business.

Running surveys, questionnaires, competitions and/or promotions.

We may collect and use your personal information in connection with any survey, competition and/or promotion that you enter.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to operate the survey, questionnaires, promotion and/or competition.

Data Analytics, Insight and Profiles.

We analyse your personal information, including that which we observe about you from your interactions with the app.gyreteams.com platform, and our email communications with you and/or the products and services you may have purchased or used.

This information is used to create insights about usage habits across our services. By using this information, we are able to measure the effectiveness of our services and how users use the Gyre Services.

What is our legal basis for doing this?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will not constitute “personal information” that is regulated under data protection laws. However, our collection and use of such anonymised personal information may still be subject to other laws where your consent is required. Please see our Cookie Section below for further details.

6. Gyre Recommends – An advanced search feature.

Gyre Recommends is an advanced search feature that uses Artificial Intelligence (AI) including use of OpenAI to provide personalised search results to registered users of the app.gyreteams.com platform. This feature allows users to input prompts and receive targeted recommendations for team and personal development resources based on their role, industry, experience level, and other factors.

To provide this service, Gyre collects and analyses personal information, including that submitted by users and that observed through their interactions with the app.gyreteams.com platform. This information is used to create insights about usage habits across our services, measure the effectiveness of our services, and improve the user experience.

The use of Gyre Recommends is entirely optional and users can choose not to use this feature. However, if a user does choose to use this feature, their personal information will be used to generate the personalised search results. Gyre takes data privacy seriously and only uses personal information in accordance with our privacy policy and applicable data protection laws.

By using our services, you acknowledge and agree that Gyre may use AI to conduct analysis on data that you have submitted to us. This analysis may involve machine learning and natural language processing techniques to identify patterns and insights in the data. Gyre will use this analysis to improve our services and develop new features and products. Please note that Gyre will take all reasonable measures to ensure the confidentiality and security of your data during this analysis. However, Gyre cannot guarantee that the analysis will be error-free or produce accurate results. By submitting your data to us, you grant Gyre a non-exclusive, royalty-free, worldwide, perpetual, and irrevocable licence to use, modify, and distribute the data for the purposes of conducting this analysis. If you do not agree with these terms, please do not use our services or submit any data to us.

7. Other use of your data that applies to all groups of people about whom we process data

Service Administration.

We may also use your personal information to:

help improve the Gyre Services; and
contact you to answer any queries you may have sent to us.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

Sharing information with third party processors.

We may share your personal information with third party processors in order to provide the Gyre Services and associated products and services to you. This includes companies that for example, host our servers or manage our databases for us. They have no independent rights to use your data and are strictly controlled by us under contract.

What is our legal basis for doing this?

It is in our legitimate interests to share your personal information in such a way to ensure that we provide the very best service we can to you.

Business administration, record keeping and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

to comply with our legal obligations;
to enforce our legal rights;
protect rights of third parties; and
in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Use in this way may involve us sharing your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

It is in our legitimate interest to ensure that we keep our records up-to-date and use them in connection with a business transition, enforce our legal rights, or to protect the rights of third parties. Otherwise, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us or other regulations that we are subject to.

8. How do we obtain your consent?

8.1. Where use of your personal information by us requires your consent, you may provide such consent: at the time we collect your personal information by following the instructions we give; or by informing us using the contact details set out in this privacy notice.

9. Use of cookies

9.1. The Gyre Services may use certain cookies and other technologies of which you should be aware.

WHAT ARE COOKIES?

Cookies and similar technologies are very small text documents or pieces of code, which often include an anonymous unique identifier. When you visit a website or use an application, a computer asks your computer or mobile device for permission to store this file on your computer or mobile device and access information from it. Information gathered through cookies and similar technologies may include the date and time of visits, preferred country of residence and how you are using the particular website or application. Cookies are used by us as part of our services and they are also used by some of our third party partners.

For more details on cookies and similar technologies please visit All About Cookies. For the purposes of the remaining sections of this Cookie Policy we will refer to all technologies using the above features as “cookies”.

CONSENT TO OUR USE OF COOKIES

By using the services, you acknowledge that we may store and access cookies on your computer or other device including consenting to certain cookies that are not essential to the operation of our services but allow us to provide additional functionality or to gather additional information about your use of our services. You are not obliged to give consent to our use of non-essential cookies.

If you wish to block or delete cookies, or you would like to withdraw consent to our use of non-essential cookies, you can find out how to do so below.

WHAT DO WE DO WITH COOKIES?

Essential Cookies

We use cookies where they are essential for the operation of the services, for example to remember that you are signed in to the service.

Session Cookies

We use cookies to allow the service to uniquely identify your browsing session on our services, which allows us to coordinate this information with data from our server.

Analytics Cookies

We use “analytics” cookies. These, along with other information, allow us to calculate the aggregate number of people using the services and which features of our services are most popular.

We use this information to improve the services. We do not generally store any information that you provide to us in a cookie.

Social Media

We use cookies to personalise your interaction with social media, such as Twitter, Facebook, Tumblr and YouTube. Such cookies recognise users of those social media sites when you view social media content on our services. They also allow you to quickly share content across social media, through the use of simple ‘sharing’ buttons.

Our services also contain features that enable you to use your Facebook account to sign in and create/maintain an account with us and to enable us to store your content. This involves the use of cookies.

WHAT HAPPENS WHEN YOU REFUSE, BLOCK OR DELETE COOKIES?

In order to use some parts of our services you will need to accept cookies. If you choose to withhold consent to our use of cookies, or you subsequently block or delete cookies, some aspects of our services may not work properly, and you may not be able to access all or part of our services.

CAN YOU BLOCK COOKIES?

You can block the use of cookies altogether by activating the relevant settings in your browser or by following the link below. For more information on cookie management and blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.

10. Third Party Links and Services

10.1. The Gyre Services may contain links to third party websites and services. Please remember that when you use a link to go from the Gyre Services to another website or you request a service from a third party, this privacy notice no longer applies.

10.2. Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

10.3. We do not monitor, control, or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

11. Transfers outside the EEA

11.1. We may transfer your personal data outside the EEA to processors outside the EEA including in the USA, in connection with our business or for legal reasons. We will ensure that the transfer is lawful and that there are appropriate security arrangements.

11.2. If the European Commission has decided that a country does not provide an adequate level of protection in relation to data that is transferred there, we will enter into an agreement ensuring appropriate and suitable safeguards with our group member, processors or other transferee. This may be via binding corporate rules or on standard terms adopted by the Information Commissioner and approved by the European Commission.

12. How long do we keep your personal information for?

12.1. We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.

13. Confidentiality and security of your personal information

13.1 We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect it from loss, misuse or alteration.

13.2 We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.

13.3 All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Gyre Services.

14. How to access your information and your other rights?

14.1. You have the following rights in relation to the personal information we hold about you:

Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability.

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we’re:

relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing
processing your personal information for direct marketing; or
processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of a contract between you and us.

Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information for certain uses, you have the right to withdraw that consent at any time for those uses.

Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

15. Change to this privacy notice

15.1. We may make changes to this privacy notice from time to time.

15.2 To ensure that you are always aware of how we use your personal information, we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.