Privacy Notice
1.About us and this notice
This notice explains how GGI Partners Limited ("we", "us", "our"), trading as Global Growth Institute and World Class Manager, collects and uses personal data in connection with The World Class Manager Coach (the "Coach"). We are committed to protecting your personal data and to being clear about how it is handled.
We are a company registered in the United Kingdom under company number 08327042, with our registered office at 45 Beaufort Court, London, E14 9XL. We are registered with the Information Commissioner's Office under registration number ZA265528.
If you have any questions about this notice or about how we use your data, please contact our data protection contact, Rose Leach, Client Director, at rose@the-ggi.com.
2.What this notice covers
This notice covers the Coach: an AI thinking partner that helps managers reflect on real situations and decide how to act, built on the World Class Manager method. It is provided to managers at organisations that have chosen to make it available to their people. It does not cover any separate websites, products or services, which have their own notices where applicable.
3.Our role: controller and processor
Where we provide the Coach to an organisation for use by its managers, that organisation is usually the data controller for the conversations its people have, and we act as a processor on its documented instructions under a written agreement. We act as an independent controller for our own limited purposes, such as operating, securing and maintaining the service. Where your employer is the controller, its own privacy notice will also apply, and you can raise questions with it directly.
4.The personal data we process
The Coach is deliberately designed to collect as little personal data as possible. The data involved is:
- Conversation content. Anything you type into the Coach during a session. Please avoid entering more personal or sensitive information than you need to, and avoid identifying other people by name where it is not necessary.
- Your email address. Only if you choose to email yourself a copy of your conversation. You enter this yourself, at the point you ask us to send it.
- Language and display preferences. The language you choose, so the Coach can respond to you appropriately.
- Limited technical data. Basic information needed to deliver a secure web service, such as that handled by our hosting provider to route and protect requests.
The wider insight the Coach draws on from World Class Manager cohorts, including any insight specific to your organisation, is anonymised and aggregated before it is used. It contains no raw personal data, and no individual can be identified from it.
5.How and why we use your data, and our legal basis
We use personal data only for the purposes set out below. Where we act as a processor for your organisation, we do so on its instructions and it determines the legal basis.
| Purpose | Data used | Legal basis |
|---|---|---|
| To provide the Coach and generate responses to you | Conversation content, language preference | Performance of a contract, and our legitimate interests in delivering the service requested. Where we act as a processor, on our client's instructions. |
| To email you a copy of your conversation, when you ask us to | Your email address, conversation content | To carry out your request. We only do this when you actively choose it. |
| To keep the service secure, reliable and available | Limited technical data | Our legitimate interests in running a safe and dependable service. |
| To meet our legal and regulatory obligations | The minimum data necessary | Compliance with a legal obligation, and our legitimate interests. |
6.How the AI works
To generate each reply, your conversation is sent to our AI model provider, Anthropic, which processes the text and returns a response. Anthropic does not use data submitted through its business interface to train its models. The Coach gives you guidance and coaching to inform your own thinking. It does not make automated decisions that produce legal or similarly significant effects about you. Any decisions you take remain yours.
7.Third parties and sub-processors we work with
We use a small number of established providers to deliver the Coach. Each handles a defined, limited function under a data processing agreement:
- Cloudflare hosts and secures the application as an isolated edge service.
- Anthropic provides the underlying AI model that generates responses.
- Resend delivers email, used only when you choose to email yourself a copy of your conversation.
- Cloudinary hosts static brand assets such as logos. No personal data passes through it.
We do not sell your personal data, and we do not use it for advertising.
8.International transfers
Some of our providers may process data outside the UK and the European Economic Area. Where this happens, we ensure appropriate safeguards are in place, such as UK and EU approved standard contractual clauses or an adequacy decision, so that your data continues to be protected.
9.How long we keep your data
The Coach holds no database or store of its own, so we do not build a standing record of your conversations. In practice:
- A conversation exists only in your own browser for that session, and is cleared when you close or refresh the page.
- When you send a message, the text passes through our service in memory only, to reach the AI model and return the reply. Nothing is written to disk by us.
- If you choose to email yourself a summary, your email address is used only to send that email and is not retained by us afterwards. The email then sits in your own inbox, under your control.
- Our providers retain data only for limited periods under their own terms, for example to process requests and maintain security and delivery logs.
10.How we protect your data
We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and keeping the Coach isolated from our other systems. We work only with reputable providers who offer strong security assurances.
11.Automated decision-making and profiling
We do not use your personal data to make solely automated decisions that produce legal or similarly significant effects about you, and we do not use it to profile you.
12.Cookies and similar technologies
The Coach uses only what is strictly necessary for the service to function. It does not use advertising or tracking cookies.
13.Your rights
Subject to certain conditions, you have the right to access your personal data, to have it corrected or erased, to restrict or object to its use, to data portability, and to withdraw consent where processing is based on consent. Because the Coach does not retain your conversations, in most cases there is no standing record for us to locate. Where your employer is the controller, please direct requests to it, and we will support it in responding. To exercise a right in respect of data we control, contact us using the details in section 15.
14.How to complain
We would always prefer the chance to resolve any concern directly, so please contact us first. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority, at ico.org.uk, or to your local data protection authority.
15.Contact us
For any question about this notice or your personal data, please contact Rose Leach, Client Director, at rose@the-ggi.com, or write to us at 45 Beaufort Court, London, E14 9XL.
16.Changes to this notice
We may update this notice from time to time. When we make material changes, we will update the date at the top and, where appropriate, let you or your organisation know. The current version is always the one published on our website.