The Confident Manager Academy Privacy Policy
Last updated: 8 September 2026
1. About this Privacy Policy
The Confident Manager Academy is operated by Aspirin Business Solutions Limited, trading as Aspirin Business Solutions ("ABS").
Company number: 05126742
Registered office:
Faulkner House
31 West Street
Wimborne
Dorset
BH21 1JS
United Kingdom
Privacy enquiries can be sent to:
ABS is registered with the UK Information Commissioner's Office.
This Privacy Policy explains how personal information is collected, used, shared and protected when someone visits, joins or takes part in The Confident Manager Academy ("the Academy").
It applies specifically to the Academy and its learning platform. ABS operates a separate privacy notice for its main website and other business activities.
The Academy is designed for managers and workplace professionals. It is not designed or marketed specifically to children.
2. Who is responsible for personal information?
For the personal information described in this Privacy Policy, Aspirin Business Solutions Limited is normally the data controller.
The Academy is hosted using Thinkific. For personal information Thinkific processes on behalf of ABS to provide the learning platform, Thinkific acts as a data processor.
Where an employer or another organisation pays for or arranges a participant's Academy place, that organisation will normally be a separate data controller for its own purposes. This may include deciding who is enrolled and using agreed progress information supplied by ABS.
Other service providers may also act as processors or, in some circumstances, as separate controllers for particular activities.
3. Information the Academy may collect
The information collected will depend on how the Academy is used.
Account and identity information
This may include:
name
email address
username
organisation or employer
job title or role
telephone number
country or location
billing address where relevant
profile photograph
other information added to an Academy profile
Enrolment and employer information
Where an employer or another organisation arranges Academy access, information may include:
the participant's name and work email address
employer or organisation
team, department or cohort
information needed to administer the organisation's Academy places
the identity of the organisation sponsoring the participant
Learning and progress information
This may include:
date of enrolment
login and activation information
lessons or resources accessed
course progress and completion
challenges completed
quiz or assessment results
submitted work
reflection exercises
survey responses
masterclass attendance
certificates, badges and recognition levels
completion or graduation information
Community information
The Academy includes an online community.
Information may include:
profile name
profile photograph
posts
comments
replies
reactions
questions
other content shared with the Academy community
Academy members should expect their profile and community contributions to be visible to other Academy members.
Live session information
Live lessons and masterclasses may be delivered through Thinkific and connected video-conferencing technology.
This may include:
participant name
attendance
audio
video
questions
chat messages
contributions to discussions
Sessions may be recorded.
Participants will be told where a session is being recorded. Anyone who does not wish to appear visually in a recording should keep their camera switched off.
Participants should avoid sharing confidential, sensitive or identifiable information about employees, colleagues, clients or other third parties during recorded sessions.
Payment and transaction information
For individual purchases this may include:
purchase details
payment status
billing information
transaction information
refunds or chargeback information
VAT or tax information where relevant
Payment information may be processed by Thinkific Payments or another payment provider.
Payment providers may process information under their own privacy terms and legal obligations.
Communications information
This may include:
emails
support requests
complaints
enquiries
feedback
communication preferences
records of relevant conversations with ABS
Technical and usage information
This may include:
IP address
login information
browser type
device information
operating system
time zone
approximate location
Academy pages and resources accessed
dates and times of activity
cookie and similar technology information
platform analytics
Marketing information
This may include:
marketing preferences
previous interactions with ABS
relevant products or services of interest
whether marketing emails have been opened or interacted with where the email service provides this information
unsubscribe or objection records
Assessment and development information
Some Academy activities may include or link to tools such as Motivational Maps, surveys, development assessments or related ABS services.
Where these are used, information generated through them may be processed to provide the relevant activity, feedback or development support.
The availability of particular assessments may differ between Academy memberships, cohorts and organisational agreements.
4. Sensitive information
The Academy does not normally require participants to provide special category personal information, such as detailed health information, religious beliefs, political opinions, sexual orientation or other highly sensitive personal information.
Some Academy topics cover stress, wellbeing, grievances, bullying, conflict and difficult workplace situations.
Participants must not upload or share:
identifiable employee records
medical or health records
grievance or disciplinary documentation
confidential HR information
information about another person's health or personal life
other sensitive third-party information
unless ABS has specifically requested it and there is a proper lawful basis for doing so.
Where sensitive information is supplied unexpectedly, ABS may remove, restrict or otherwise handle that information as necessary and in accordance with applicable data protection law.
Where sensitive information is genuinely required for a particular purpose, additional information or consent may be requested where appropriate.
5. Where personal information comes from
Information may be obtained:
directly from the participant
from an employer or organisation arranging Academy access
automatically through the Thinkific platform
through Academy community activity
through live sessions and recordings
through surveys, assessments and submitted work
from payment providers
from integrated Academy services
from communications with ABS
from facilitators or administrators where they record participation or completion information
When an employer provides a participant's details, the Academy invitation or onboarding process may identify the organisation as the source of that information.
6. How information is used and the lawful basis
ABS only processes personal information where there is a lawful reason to do so.
Providing Academy access
Information may be used to:
create and manage accounts
enrol participants
release Academy content
provide lessons, tools and resources
administer challenges and submissions
provide community access
deliver live sessions
provide certificates or recognition
respond to support requests
The lawful basis will normally be performance of a contract or legitimate interests in providing the Academy and administering sponsored participants.
Administering employer-sponsored places
Information may be used to:
enrol participants whose details have been supplied by an employer
place participants into the appropriate cohort
administer organisational licences
provide agreed progress information to the sponsoring organisation
The lawful basis will normally be ABS's legitimate interests and the legitimate interests of the sponsoring organisation in administering and evaluating management development.
Progress reporting to employers
Where an employer or organisation sponsors a participant, ABS may provide relevant information such as:
enrolment or activation status
participation
progress
completion
challenge completion status
live-session attendance
certificate or recognition level
Named information may be provided where relevant and necessary.
Aggregate information may also be provided to help organisations understand participation, completion and development themes.
ABS will not normally provide an employer with the detailed content of:
private reflections
submitted exercises
individual community discussions
live-session questions
individual free-text survey comments
unless the participant has been clearly informed that this will happen, permission has been obtained where required, or disclosure is necessary for legal, regulatory or serious safety reasons.
Payments and financial administration
Information may be processed to:
take and record payments
issue invoices
administer refunds
maintain financial records
prevent fraud
comply with tax and accounting requirements
The lawful bases may include performance of a contract, legal obligation and legitimate interests.
Improving and managing the Academy
Information may be used to:
monitor engagement
understand how Academy resources are used
improve content
manage capacity
troubleshoot problems
maintain security
develop future Academy features
The lawful basis will normally be ABS's legitimate interests in operating and improving the Academy.
Where non-essential cookies or tracking technologies require consent, consent will be obtained separately.
Communications
Information may be used to send necessary communications relating to:
enrolment
access
lessons
Academy changes
live sessions
certificates
payments
support
security
service administration
These are service communications and may still be sent where a participant has opted out of marketing.
The lawful basis will normally be performance of a contract or legitimate interests.
Marketing
ABS may send relevant information about the Academy and other ABS products, services, events and development opportunities where permitted by law.
Depending on the recipient and the law that applies, the lawful basis may be:
legitimate interests, or
consent
Consent will be obtained where required.
Every electronic marketing communication will provide a way to unsubscribe or object.
A person who objects to direct marketing will no longer receive that marketing. A minimal suppression record may be retained so that the preference can be respected.
Everyone has the right to object to the use of their personal information for direct marketing at any time.
Testimonials, case studies and promotional material
Academy submissions, graduation videos, photographs, quotes or success stories will not be used for promotional purposes simply because they have been submitted as part of the Academy.
Separate, explicit permission will be obtained before identifiable participant material is used for marketing, testimonials, publicity or case studies.
Where consent is relied upon, it can be withdrawn for future use.
Legal and security purposes
Information may be processed to:
protect Academy users and ABS
investigate misuse or breaches of the Academy Terms
prevent fraud
establish, exercise or defend legal claims
comply with court orders or legal obligations
respond to regulators or law enforcement where legally required
The lawful bases may include legitimate interests and legal obligation.
7. Community privacy
The Academy community is a shared member space.
Other Academy members may be able to see:
a participant's name
profile photograph
profile information
posts
comments
replies
reactions
questions and contributions
The community may contain participants from different employers and organisations.
It should not be treated as a private communication channel between a participant and ABS.
Participants must anonymise workplace examples and avoid identifying colleagues, employees, customers or other third parties.
ABS moderates the community and may remove material that is inappropriate, unlawful, confidential, discriminatory, abusive, misleading or contrary to the Academy Terms.
ABS cannot guarantee that another Academy member will keep information confidential once it has been voluntarily posted within the community. Participants should therefore only share information they are comfortable sharing with other Academy members.
8. Live session recordings
Some Academy masterclasses and live lessons may be recorded.
A recording may capture:
participant names
voices
images
questions
chat contributions
presentation material
group discussion
Recordings may be made available to Academy members as learning resources.
They may normally remain available for as long as the Academy or relevant learning platform continues to operate, unless removed earlier.
Requests relating to personal information contained in recordings will be considered in accordance with applicable data protection law and the rights of other people appearing in the recording.
Participants who contribute to recorded sessions should not disclose confidential or sensitive third-party information.
9. Artificial intelligence and automated features
Thinkific and other services used by ABS may make artificial intelligence or automated features available from time to time.
If such features are enabled, personal information entered into or required by the feature may be processed by the relevant technology provider and its authorised service providers.
Participants should not enter confidential employee information, special category personal information or other sensitive third-party data into an AI feature unless specifically asked to do so.
AI-assisted features may provide suggestions, summaries or learning support. They should not be treated as professional advice.
ABS does not use Academy AI features to make decisions based solely on automated processing that produce legal or similarly significant effects for participants.
10. Who information may be shared with
Personal information may be shared where necessary with:
Thinkific, which hosts and supports the Academy platform
video-conferencing providers used for Academy live sessions
payment providers
email and marketing service providers, including Zoho
IT, hosting, security and technical support providers
providers of Academy assessments or development tools, where those services are used
professional advisers such as accountants, insurers or lawyers
a participant's employer or sponsoring organisation, within the reporting boundaries described in this notice
regulators, courts, law enforcement or public authorities where legally required
other service providers reasonably needed to operate the Academy
Service providers are given access only to information reasonably required for their role and are expected to handle information in accordance with applicable data protection requirements.
Where a third party acts as a separate controller, its own privacy notice may also apply.
11. Thinkific and international processing
Thinkific Labs Inc. is based in Canada.
Thinkific currently hosts production systems used for its platform in the United States and uses service providers in a number of countries.
This means Academy personal information may be processed outside the United Kingdom.
Thinkific's data-processing arrangements identify ABS as controller and Thinkific as processor for Academy personal information processed on ABS's behalf.
Where a transfer of personal information from the UK requires additional protection, appropriate legal safeguards may include:
UK adequacy regulations
the UK International Data Transfer Agreement
the UK Addendum to approved Standard Contractual Clauses
other approved contractual or legal safeguards
Other Academy service providers may also process information outside the UK. Appropriate safeguards will be used where required by applicable law.
Information about relevant transfer safeguards can be requested from [email protected].
12. Security
ABS and its service providers take reasonable technical and organisational measures to protect personal information from:
accidental loss
unauthorised access
misuse
alteration
disclosure
destruction
No internet-based service can guarantee complete security.
Participants must:
keep account credentials confidential
use a secure password
not share Academy accounts
report suspected unauthorised access promptly
take reasonable care when sharing information within the community or live sessions
13. How long information is kept
Information is kept only for as long as reasonably required for the purpose for which it was collected, including legal, accounting and reporting requirements.
Typical retention arrangements are:
Financial and contractual records
Relevant invoices, transaction information and contractual records will normally be kept for six years, or longer where required by law or an active dispute.
Academy account and completion records
An Academy account is not automatically deleted when paid Academy access ends.
Essential account, progress, certificate and completion information may continue to be retained so that a participant can access their learning history or certificate.
Inactive accounts and records may be reviewed, anonymised or deleted when they are no longer reasonably needed.
Community content
Community posts and contributions may remain available while the participant's Academy account remains active or retained.
Content may be removed earlier where:
the participant validly exercises a data-protection right
moderation is required
the content breaches Academy rules
retention is no longer appropriate
Submitted work
Submitted work will be kept for as long as reasonably necessary to administer the Academy, confirm completion, provide support or deal with relevant queries.
Live recordings
Academy recordings may remain available while the Academy or platform continues to operate where they continue to serve a legitimate learning purpose.
Marketing information
Marketing information will be kept while relevant marketing is being sent and there remains a lawful basis for doing so.
Where someone unsubscribes or objects, a minimal suppression record may be retained so that ABS can respect that preference.
Legal claims
Information relevant to an actual or reasonably anticipated legal claim may be retained for longer where necessary.
14. Cookies and similar technologies
The Academy platform uses cookies and similar technologies.
Some cookies are necessary to:
allow users to sign in
maintain sessions
provide security
remember essential settings
operate the platform
Other cookies or technologies may be used for analytics and service improvement.
Where applicable law requires consent for a non-essential cookie, that cookie should not be placed until the appropriate consent has been obtained.
Cookie choices may be managed through the cookie preference tools made available on the Academy site and, where appropriate, through browser settings.
15. Individual rights
Depending on the law that applies and the circumstances, individuals may have rights including:
access to personal information
correction of inaccurate information
deletion of information
restriction of processing
objection to processing
data portability
withdrawal of consent where processing is based on consent
objection to direct marketing
rights relating to certain automated decision-making
These rights are not absolute and may be subject to legal conditions or exemptions.
Requests should be sent to:
ABS may need to verify the identity of the person making the request.
Where an employer acts as a separate controller for information it receives or provides, requests concerning the employer's own processing should normally be made directly to that employer.
16. Complaints
Anyone who has concerns about the handling of personal information should contact:
ABS will aim to resolve privacy concerns directly.
UK individuals also have the right to complain to the Information Commissioner's Office (ICO).
People in other countries may have the right to complain to the relevant data-protection or privacy regulator in their location.
17. International users
The Academy may be available to participants outside the United Kingdom.
This Privacy Policy is based primarily on UK data-protection requirements.
Depending on where a participant lives, additional rights or requirements may apply under local privacy law.
Nothing in this Privacy Policy is intended to remove rights that cannot lawfully be excluded.
18. Third-party links and services
Academy content may link to third-party websites, tools, books, assessments, services or resources.
Those third parties may collect personal information under their own privacy notices.
ABS is not responsible for the privacy practices of independent third-party services.
19. Changes to this Privacy Policy
This Privacy Policy may be updated to reflect:
changes to the Academy
changes to service providers
new platform features
changes in the law
changes in data-protection guidance
The latest version will be published on the Academy platform.
Where a change materially affects how participants' personal information is used, reasonable steps will be taken to bring the change to their attention.
20. Contact
Questions, complaints and data-protection requests relating to The Confident Manager Academy should be sent to:
Aspirin Business Solutions Limited
Faulkner House
31 West Street
Wimborne
Dorset
BH21 1JS
United Kingdom
Company number: 05126742
Email: [email protected]