Privacy Policy

1. Data controller

The data controller responsible for your personal data is:

Newbery Advisory [or FULL LEGAL NAME ONCE CONFIRMED] [Legal form, if applicable] [Business or registered address] [Country] Privacy contact email: customerservice@newberyadvisory.com

In this Privacy Policy, “Newbery Advisory”, “we”, “us” or “our” refers to the entity identified above.

2. Personal data we may collect

We may collect and process the following personal data:

- Full name. - Job title or professional role. - Company, firm or organisation. - Professional email address. - Telephone number, if provided. - Country or professional location. - Approximate organisation size. - Sector or type of firm. - Information submitted through contact or enquiry forms. - Information shared during calls, meetings or communications. - Responses to tests, diagnostics, assessments or surveys. - Scores, results, reports or recommendations generated from those responses. - Communication preferences. - History of interactions with Newbery Advisory. - Billing, payment or contracting information, where relevant. - Basic technical information about your use of our website, such as IP address, browser, device information or cookies, where applicable.

We do not intentionally request special category data or highly sensitive personal data. Please do not include confidential client information, legally privileged information, sensitive personal data or highly confidential internal information in open form fields unless it is strictly necessary and you are entitled to share it.

3. How we collect your data

We may collect personal data when you:

- Complete a form on our website. - Request information about a service. - Request a conversation or meeting. - Download a resource. - Subscribe to communications from Newbery Advisory. - Complete a test, diagnostic, assessment or survey. - Purchase or request a service. - Communicate with us by email, phone, video call or other means. - Browse or interact with our website.

4. How we use your data

We use your personal data to:

- Respond to your enquiries or requests. - Contact you about the service you have requested. - Arrange conversations, meetings or calls. - Send you resources, guides, reports or materials you have requested. - Manage proposals, proforma invoices, invoices and payments. - Deliver purchased services. - Process tests, diagnostics, assessments or surveys. - Generate indicative scores, results, reports or recommendations. - Internally review results in order to prepare communications, recommendations or possible next steps. - Maintain internal records of contacts, leads, clients and opportunities. - Send you marketing communications, resources or information about Newbery Advisory where we have a lawful basis to do so. - Improve our website, methodology, materials, services and client experience. - Comply with legal, tax, accounting or regulatory obligations. - Protect the security of our website, systems and professional activity.

5. Lawful basis for processing

We process your personal data under one or more of the following lawful bases:

- Your request or consent, for example where you contact us or agree to receive communications. - Steps prior to entering into a potential contract, for example where you request information, a conversation, a proposal or a service. - Performance of a contract, where you purchase our services. - Our legitimate interests in managing professional enquiries, B2B relationships, commercial follow-up, service improvement and system security. - Compliance with legal, tax, accounting or regulatory obligations.

Where we rely on consent, you may withdraw your consent at any time.

6. Marketing communications

We will only send you marketing communications, newsletters, resources, invitations or information about Newbery Advisory services where we have an appropriate lawful basis to do so.

Where required, our forms will include a separate checkbox allowing you to agree to receive communications. This checkbox will not be ticked by default.

You can unsubscribe from our communications at any time using the unsubscribe link in our emails or by contacting customerservice@newberyadvisory.com

If you unsubscribe from marketing communications, we may still contact you where necessary to respond to an enquiry, manage a service, proposal, invoice, contractual relationship or legal obligation.

7. Tests, diagnostics and results

If you complete a test, diagnostic, assessment or survey provided by Newbery Advisory, your responses may be processed to generate an indicative score, result, report or preliminary recommendation.

These results are for information purposes only and do not constitute legal, regulatory, financial, tax, technical or cybersecurity advice.

We do not make decisions with legal or similarly significant effects based solely on automated processing.

Newbery Advisory may internally review responses and results in order to deliver the requested service, prepare recommendations, identify possible next steps or improve its methodology.

8. Who we share your data with

We do not sell your personal data.

We may share data only with providers required to operate our website, forms, email, CRM, database, storage, analytics, calendar, document generation, automation, billing, payment or internal systems.

These providers must process data in accordance with our instructions and, where applicable, under appropriate data protection arrangements.

We may also share data where required by legal, tax, accounting, administrative, judicial or regulatory obligations.

9. International transfers

Newbery Advisory may use technology providers located in Spain, the European Union, the United Kingdom or other countries.

Where personal data is transferred outside the European Economic Area or the United Kingdom, we will take appropriate safeguards required by applicable data protection law, such as adequacy decisions, standard contractual clauses or other legally recognised mechanisms.

10. Data retention

We keep your personal data only for as long as necessary for the purposes for which it was collected.

In general:

- Contact form data will be kept while we manage your enquiry and for a reasonable period of professional follow-up. - Data relating to proposals or services will be kept while there is a professional, commercial or contractual relationship. - Billing and payment data will be kept for the applicable legal periods. - Test or diagnostic data will be kept while necessary to deliver the service, maintain the professional relationship history or improve the methodology. - Marketing data will be kept until you withdraw consent, unsubscribe or object to processing. - Data required for legal, tax or accounting obligations will be kept for the period required by law.

When data is no longer required, it will be deleted, anonymised or restricted in accordance with applicable law.

11. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure or destruction.

These measures may include access controls, passwords, limited permissions, backups, supplier reviews and internal security procedures.

No online system is completely risk-free. We recommend that you do not send highly confidential information, sensitive data or client information through open website forms unless strictly necessary.

12. Your rights

Depending on the applicable law, you may have the right to:

- Access your personal data. - Request correction of inaccurate data. - Request deletion of your data. - Request restriction of processing. - Object to processing. - Request data portability. - Withdraw consent. - Object to direct marketing.

To exercise your rights, please contact:

customerservice@newberyadvisory.com

We may ask for additional information to verify your identity before responding.

13. Complaints

If you have concerns about how we process your personal data, please contact us first at customerservice@newberyadvisory.com

You may also have the right to lodge a complaint with the Spanish Data Protection Agency where Spanish or EU data protection law applies.

Where UK data protection law applies, you may also have the right to contact the UK Information Commissioner’s Office.

14. Cookies and similar technologies

Our website may use cookies or similar technologies to function properly, analyse website usage, improve user experience or support communication or measurement activities.

More information about cookies, their purpose, duration and your choices will be available in our Cookie Policy.

15. Third-party links

Our website may contain links to third-party websites, resources, platforms or services.

We are not responsible for the privacy practices, content or security of third-party websites. We recommend reviewing their own privacy policies before providing them with personal data.

16. Changes to this policy

We may update this Privacy Policy from time to time to reflect legal, technical, operational or service changes.

The current version will be available on our website and will show the date of the latest update.