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Our Privacy Policy

Your privacy matters to us.

 

 

Exceptional Individuals' Privacy Notice

Effective Date: 04 April 2017 (Last Updated: July 18, 2025)

1. Introduction

Exceptional Individuals (“us”, “we”, or “our”) operates https://exceptionalindividuals.com/ (the Exceptional Individuals “Site”). 

This page informs you of our policies regarding the collection, use, and disclosure of Personal Information we receive from users of the Site. We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

At Exceptional Individuals, we are committed to protecting the privacy and security of your personal data. As experts in neurodiversity, we understand the importance of trust and transparency, especially when handling sensitive information. This Privacy Notice explains how we collect, use, store, and share your personal data, and outlines your rights regarding your information.

This notice applies to all individuals whose personal data we process, including our clients, candidates, employees, contractors, website visitors, and business contacts.

2. Who We Are

Exceptional Individuals (referred to as "we", "us", or "our" in this notice) is dedicated to supporting neurodivergent individuals to thrive. We are the data controller responsible for your personal data.

Our Contact Details:

  • Name: Exceptional Individuals Ltd (registered number 09414017)
  • Address: Exceptional Individuals, 27 Old Gloucester St, Holborn, London WC1N 3AX
  • Email (General): admin@exceptionalindividuals.com
  • Data Protection Lead/Officer: Kinga Kubiak, Head of Operations 
    • Email: admin@exceptionalindividuals.com

3. What Personal Data Do We Collect?

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data: Includes first name, last name, title, date of birth, gender, and neurotype. While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your name (“Personal Information”).
  • Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
  • Employment Data: Includes job title, work history, qualifications, performance reviews, salary, bank details, and emergency contact information (for employees/contractors).
  • Special Category Data: This includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health (e.g., specific neurodivergent conditions, diagnoses, support needs, access requirements), data concerning a person's sex life or sexual orientation. We only collect this data where strictly necessary, with your explicit consent, or where a legal basis permits.
  • Technical Data (Log Data): We collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
  • Usage Data: Includes information about how you use our website, products, and services.
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.

In addition, we may use third-party services such as Google Analytics that collect, monitor and analyse this Log Data.

4. How Do We Collect Your Personal Data?

We use different methods to collect data from and about you, including through:

  • Direct interactions: You may give us your Identity, Contact, Employment, and Special Category Data by filling in forms, corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
    • Apply for our services (e.g., coaching, assessments, training).
    • Apply for a job or contract with us.
    • Communicate with us for support or information.
    • Subscribe to our newsletters or publications.
    • Participate in our events or surveys.
  • Automated technologies or interactions (Cookies): Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, such as recruitment agencies, publicly available professional profiles, or referral partners, with your consent where required.

5. Lawful Basis for Processing Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., providing coaching services, employment contract, facilitating virtual employability workshops).
  • Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., improving our services, preventing fraud, contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you).
  • Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., tax compliance, health and safety).
  • Consent: You have given us explicit consent to process your personal data for a specific purpose. For example, by submitting your application for the virtual employability workshops, you consent to the collection and use of your personal data by Exceptional Individuals Ltd for the express purpose of reviewing your application and suitability for the virtual employability workshops. You can withdraw your consent at any time.

When processing Special Category Data, we will only do so under specific conditions, such as:

  • With your explicit consent.
  • Where it is necessary for employment, social security, or social protection law.
  • Where it is necessary for reasons of substantial public interest.
  • Where it is necessary for the provision of health or social care.

Your personal data will at all times be processed according to the retained EU law version of the General Data Protection Regulation 2016/679 (the “UK GDPR”), the Data Protection Act 2018 and other applicable laws.

6. How We Use Your Personal Data

We use your personal data for various purposes, including:

  • Providing our services: To deliver coaching, assessments, training, recruitment support, and other services you have requested. For example, to facilitate the virtual employability workshops.
  • Managing our relationship with you: Including communicating with you, providing customer support, and managing your account.
  • Recruitment and HR management: To process job applications, manage employment contracts, payroll, and benefits (for employees/contractors).
  • Improving our services: To understand how our services are used, conduct research, and enhance our offerings. This includes using your Personal Information for providing and improving the Site.
  • Marketing and communications: We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.
  • Compliance with legal obligations: To meet our legal, regulatory, and ethical responsibilities.
  • Ensuring security: To protect our systems, prevent fraud, and ensure the safety of our data and operations.

7. Sharing Your Personal Data

We may share your personal data with third parties in the following circumstances:

  • Service Providers: We may share data with trusted third-party service providers who assist us in operating our business (e.g., IT support, cloud storage providers, payment processors, HR/payroll platforms, and analytics services like Google Analytics). These providers are contractually bound to keep your data confidential and secure.
  • Clients/Employers: When providing recruitment services, we may share relevant candidate data with potential employers, always with your consent.
  • Legal and Regulatory Bodies: We may disclose your personal data if required by law, court order, or to cooperate with regulatory investigations.
  • Professional Advisors: Such as lawyers, accountants, or consultants, where necessary for professional advice.
  • Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring entity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International Transfers

We may transfer your personal data outside of the UK and the European Economic Area (EEA) to countries that may not provide the same level of data protection. Where we do so, we ensure appropriate safeguards are in place, such as:

  • Transferring data to countries deemed to provide an adequate level of protection by the UK Government or European Commission.
  • Using specific contracts approved for use in the UK/EEA that give personal data the same protection it has in the UK/EEA (e.g., Standard Contractual Clauses).



9. Data Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We have implemented appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. How Long Do We Keep Your Personal Data

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

For example, personal data submitted for the virtual employability workshops is deleted as soon as it is no longer required and always within 18 months.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data (commonly known as a "data subject access request").
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of these rights, please contact our Data Protection Lead using the contact details provided in Section 2.

12. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us directly by contacting our Data Protection Lead.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

13. Changes to This Privacy Policy

This Privacy Policy is effective as of 04 April 2017, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time, and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgement of the modifications and your consent to abide by and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website.

14. Contact Us

If you have any questions about our Privacy Policy, please contact us.