BACKGROUND:

sondevelopment Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our my clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

sondevelopment Ltd – Registered in England under company number 16315170

Registered Address: 2A Torrington Road, Portsmouth, Hampshire PO2 0TP

Registered with the Information Commissioner’s Office. ZB088136

Data Protection Lead: Steve O’Neill, Managing Director 

All Data enquiries: contact@sondevelopment.com

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 and other applicable legislation relating to data protection and privacy (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which I will always work to uphold:

a) The right to be informed about my collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way

For more information about our use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep me informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to complain to us using the contact details provided in Part 11 (or by any other method). We will do our best to resolve your complaint. We will acknowledge your complaint within 30 days and will respond to it without undue delay.

You also have the right to lodge a complaint with the Information Commissioner’s Office. You may wish to raise your concerns with us first, so that we can try to resolve them. If you are not satisfied with our response, you can complain to the Information Commissioner’s Office. 

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data OR personal data relating to children OR data relating to criminal convictions and/or offences.

Data Collected	How I Collect the Data
Identity Information including Name, Title, Date of Birth, Gender	Training records from attendance at our training activities. Records of completion of online or virtual training activities. Supplied to us by you or your organisation in regard to attendance or completion of one or more of our training activities. Electronically (e-mail, cookie identifiers, IP addresses) as a result of your enquiry online or in person regarding interest in the various services we provide.
Contact information including address, e-mail address, telephone number.	Training records from attendance at our training activities. Records of completion of online or virtual training activities. Supplied to us by you or your organisation in regard to attendance or completion of one or more of our training activities. Electronically (e-mail, cookie identifiers, IP addresses) as a result of your enquiry online or in person regarding an interest in the various services we provide.
Business information including business name, job title, profession.	Training records from attendance at our training activities. Records of completion of online or virtual training activities. Supplied to us by you or your organisation in regard to attendance or completion of one or more of our training activities. Electronically (e-mail, cookie identifiers, IP addresses) as a result of your enquiry online or in-person regarding interest in the various services we provide.
Payment information including card details, bank account numbers.	BACS/Direct payment into our bank account. Invoices and written communication you may send to us as part of an ongoing business or commercial transaction.
Imagery including still photos and moving video imagery. Audio records.	Use of proprietary meeting software such as (but not limited to) Zoom, Skype, Teams, Zencastr and similar. Supplied directly to us by you using the above, or alternative asynchronous methods of image and audio transfer. Imagery collected at online or in-person events either specifically for the completion of the activity, or as a record of completion of the event.  For the production of digital and online courses, including those we are commissioned to complete for you.

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and my lawful basis for doing so:

What I Do	What Data I Use	My Lawful Basis
Administering our business.	Name, title, gender, job title, profession.	Legitimate Interest: Recording attendance at training for your or your organisation’s benefit For the proper keeping of business records To analyse and create statistical reports to measure the quality and performance of our services
Supplying our products AND/OR services to you.	Name, Address, E-mail, Telephone number, messaging service details.	Legitimate Interest: Supplying electronic training content Delivering training to you or people in your organisation Contacting you to arrange supply or delivery of products or services
Managing payments for our products AND/OR services.	Name, Address, E-mail, Bank Details, Card Details	Legitimate Interest: Contacting you to arrange payment Supplying invoices Transacting payment Keeping records of payments and invoices for business records and tax purposes.
Personalising and tailoring our products AND/OR services for you.	Name, title, gender, job title, profession, job experience	Legitimate Interest: Creating training and learning content and/or activities that suit your needs Bespoke content where it is helpful to personalise it to improve the service to you
Communicating with you.	E-mail, Address, Telephone Number, Messaging service details.	Legitimate Interest: To make contact where it is reasonable and necessary in the running of the business and delivery of the products and/or services.
Supplying you with information by email AND/OR post that you have opted-in to (you may opt-out at any time by contacting steve@sondevelopment.com, or selecting the ‘unsubscribe’ option on any relevant marketing emails or other communication.)	Email, Name and Address details.	Legitimate Interests: Supplying information about content, services or activities which may be of interest or use to you. We use tracking technologies (such as tracking pixels and link tracking) in our marketing emails to measure open rates and engagement, helping us understand which content is useful to you; this data is processed on the basis of our legitimate interest in improving our communications, and you can opt out at any time by unsubscribing or adjusting your email client’s image settings.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out.

We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We do not use automated systems for carrying out decision-making OR profiling.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. In some cases, the law may treat certain further uses of personal data as compatible with the original purpose, subject to appropriate safeguards. If we rely on compatibility this way and you want us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows me to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long I Keep It
Identity Information including name, title, date of birth, gender.	For the duration of any contract we have with you, any service we provide for you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.
Contact information including address, email address, telephone number.	For the duration of any contract we have with you, any service we provide for you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.
Business information including business name, job title, profession, length of experience in the role.	For the duration of any contract we have with you, any service we provide for you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.
Payment information including card details, bank account numbers.	For the duration of any contract we have with you, any service we provide for you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.

8. How and Where Do You Store or Transfer My Personal Data?

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

AND/OR

We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

AND/OR

We may store some of your personal data in countries outside of the UK. These are known as “third countries”. We will take steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office. 

Please contact us using the details in Part 11 for further information about the particular data storage safeguards used by us when transferring your personal data to a third country. 

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
• where data is stored electronically, all associated equipment will remain password and/or encryption protected at all times.

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

When responding to a subject access request, we will carry out reasonable and proportionate searches for the personal data covered by your request.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Steve O’Neill)

Email address: contact@sondevelopment.com

Registered Address: 2A Torrington Road, Portsmouth, Hampshire. PO2 0TP

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change my business in a way that affects personal data protection.

Any changes will be made available by email to contact@sondevelopment.com. This Privacy Notice was last updated on 30th July 2026