PRIVACY POLICY

Equalise Ltd
Last updated: 10/12/1977

1. Introduction

Equalise Ltd (“Equalise”, “we”, “us”, “our”) is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we collect, use, store and protect personal information in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and all applicable data protection laws.

This Policy applies to:
• Individuals participating in Equalise assessments (including employees, school pupils, and other participants)
• School clients, corporate clients and their staff
• Website visitors
• Third-party partners and service providers

By using our services or visiting our website, you agree to the practices described in this Policy.

2. Data Controller

Equalise Ltd is the data controller for the personal data described in this Privacy Policy.

Company Name: Equalise Ltd
Registered Address: 45 Fitzroy St, London W1T 6EB
Contact Email: lh@equalise.life

3. What Personal Data We Collect

We may collect the following categories of personal data depending on the services provided:

3.1 Participant Data (Workplace Programmes)

• Name
• Email address
• Job role or team
• Self-reported wellbeing information
• Assessment responses (e.g., energy, confidence, mood)
• Non-medical physical assessment data (e.g., simple movement or fitness indicators)
• Engagement or usage data related to the programme

3.2 Pupil Data (Healthy Schools Programmes)

• Name (or anonymised ID where appropriate)
• Age or school year group
• Self-reported wellbeing information
• Simple physical or wellbeing assessment results
• Pastoral or support information provided by the school

3.3 School and Corporate Contact Data

• Names of staff members
• Email addresses
• Phone numbers
• Role or job title
• Communication preferences

3.4 Website and Technical Data

• IP address
• Browser information
• Device information
• Cookies and usage analytics
(See Cookie Notice for more details.)

3.5 Special Category Data

Equalise does not collect clinical, diagnostic or medical data.
Where wellbeing assessments involve sensitive personal information (e.g., emotional wellbeing), such processing is carried out under Article 9(2)(a) UK GDPR (explicit consent) or Article 9(2)(g) for safeguarding/public interest where applicable.

4. How We Use Personal Data

We process personal data for the following purposes:

4.1 Delivery of Assessments and Programmes

• Conducting wellbeing and performance assessments
• Generating insights and reports for individuals, schools or corporate clients
• Providing support recommendations

4.2 Programme Administration

• Scheduling sessions
• Managing participation and engagement
• Communicating with schools and corporate clients

4.3 Safeguarding and Duty of Care

Where necessary, data may be used to highlight wellbeing concerns to authorised staff (e.g., safeguarding leads), always in line with safeguarding requirements.

4.4 Business Operations

• Account management
• Monitoring service quality
• Improving programme design and effectiveness

4.5 Legal and Regulatory Compliance

• Meeting safeguarding requirements
• Complying with UK GDPR and legal obligations
• Responding to lawful requests from authorities

We only use personal data for the purposes for which it was collected unless we reasonably consider that we need to use it for another compatible purpose.

5. Legal Basis for Processing

We rely on the following lawful bases under UK GDPR:

• Consent — for pupil data and sensitive wellbeing assessments
• Legitimate Interests — delivering workplace programmes, improving services
• Contractual Necessity — providing services to corporate or school clients
• Legal Obligation — safeguarding, regulatory compliance
• Public Interest / Safeguarding Grounds — where required by law or safety protocols

Where consent is used, it can be withdrawn at any time.

6. Data Sharing

We do not sell personal data.

We may share data with:

• Schools (for pupil reports and wellbeing insights)
• Corporate clients (for aggregated workforce wellbeing insights)
• Authorised safeguarding personnel where required
• Service providers (e.g., secure hosting, analytics) bound by data processing agreements
• Regulators or authorities if legally required

All shared data is limited to what is necessary and is shared securely.

7. International Transfers

Equalise stores data primarily within the UK.
If data is transferred outside the UK, we ensure appropriate safeguards, such as:

• UK-approved adequacy decisions, or
• International Data Transfer Agreements (IDTAs)

8. Data Retention

We retain personal data only for as long as necessary:

• Participant wellbeing data — up to 24 months unless otherwise agreed
• School reports — up to 24 months
• Corporate programme data — up to 36 months
• Contact / administrative data — as long as required for service delivery
• Legal or safeguarding records — retained according to statutory requirements

Data is securely deleted when no longer necessary.

9. Data Security

We implement appropriate technical and organisational measures, including:

• Encryption in transit and at rest
• Access controls and role-based permissions
• Regular security reviews
• Secure cloud hosting
• Staff training and confidentiality obligations

Only authorised Equalise staff and trained partners may access personal data.

10. Your Rights

Under UK GDPR, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion (“right to be forgotten”)
• Restrict processing
• Object to processing
• Request data portability
• Withdraw consent (where applicable)
• Raise a complaint with the ICO

To exercise any of these rights, contact:
lh@equalise.life

11. Children’s Data

Equalise works with schools and young people.
We only process children’s data:

• With explicit school authorisation, and
• Under appropriate safeguarding, privacy and data minimisation rules

Children’s data is never used for marketing or non-programme purposes.

12. Cookies and Website Tracking

We use cookies and standard analytics tools to improve website functionality and understand usage.
You may manage your cookie preferences through your browser settings.

See our Cookie Policy (if separate) for details.

13. Changes to This Policy

We may update this Privacy Policy to reflect legal or operational changes.
The latest version will always be available on our website.

14. Contact Us

For questions about this Policy or your rights, contact:

Equalise Ltd
Email: lh@equalise.life