Privacy and Spam Policy

Brentfield Consultancy Ltd (“EBW Global”, “we”, “us”) is a leading provider of psychometric assessments, consulting, and related services. We are committed to safeguarding your personal data and handling it in accordance with applicable data protection laws, including the UK GDPR, the EU GDPR (2016/679) where applicable, and industry-recognised security standards.

This Privacy Policy explains what information we collect, why we collect it, how we use it, and how we keep it secure. It also explains your rights and how to exercise them.

This policy applies to:

ebwlogin.com
ebwglobal.com
ebwonline.co.uk
ebwonline.com
ebwsalesmentor.com

This Privacy Policy may be updated from time to time. The latest version will always appear on this page. Continued use of our websites constitutes acceptance of any updated terms.

1. Who Controls Your Data?

EBW Global processes personal data in different roles depending on the service being used. This is required under the UK GDPR and EU GDPR, which distinguish between a Data Controller and a Data Processor.

1.1 When EBW Global acts as a Data Processor (B2B Assessment Users)

Most EBW Assessments are issued by an EBW Assessment Partner (e.g., coach, consultant, employer, HR team). In these cases:

  • the EBW Assessment Partner is the Data Controller, and

  • EBW Global processes data strictly under their documented instructions

EBW Global processes personal data as a Data Processor in accordance with Articles 28 and 29 of the UK GDPR and, where applicable, the EU GDPR (2016/679).

Examples of when we act as Processor:

  • when scoring assessments

  • when generating reports

  • when delivering services under a Partner’s lawful basis

1.2 When EBW Global acts as a Data Controller (B2C Users)

If you purchase EBW services directly — such as:

  • EBW consultancy

  • EBW training

  • a Self-Directed Report

  • the EBW Sales Mentor App

— EBW Global is the Data Controller and determines how your personal data is processed.

2. What Information We Collect

2.1 Information you provide directly

  • Name

  • Email address

  • Preferred pronouns (he, she, or they)

  • Assessment responses

  • Information needed to generate personalised reports

  • Customer enquiries and support requests

  • Training, purchase, and account details

  • Information provided in forms, surveys, or optional services

2.2 Information generated through your use of our services

  • IP address

  • Device and browser type

  • Log data

  • Cookies

  • Site usage and interaction data

2.3 Cookies

Cookies help us personalise your experience and improve the site. You can disable cookies in your browser, but this may affect site functionality.

3. What We Do With the Information You Provide

We use your information to:

  • Provide access to the EBW Assessment Platform

  • Generate EBW assessment reports

  • Personalise reports using your name and pronouns

  • Maintain and administer account information for both EBW Partners and B2C users

  • Monitor training status, credits, and purchasing history

  • Provide customer support

  • Improve our websites and services

  • Conduct internal research to enhance the accuracy and fairness of EBW assessments

  • Ensure compliance with legal and contractual obligations

By using this site, and supplying us with your information, you acknowledge that EBW Global processes your information in accordance with this Privacy Policy and, where applicable, under the lawful basis determined by your EBW Assessment Partner or EBW Global (for direct users).

4. Equal Opportunities Monitoring Form

Before beginning an EBW Assessment, you may be invited to complete an Equal Opportunities Monitoring Form. This information:

  • is used only by EBW’s research team

  • helps ensure EBW assessments remain fair, reliable, and culturally neutral

  • is stored securely and separately from your assessment

  • is not shared with EBW Assessment Partners or employers

  • is anonymised in all research outputs

  • does not influence report scoring or feedback

Completion is voluntary and does not affect your assessment.

5. Where We Obtain Your Information

We obtain your information:

  • directly from you

  • through EBW Assessment Partners

  • via training, subscriptions, events, or EBW promotions

  • from our websites

  • from third-party marketing lists

5.1 Marketing and Mailing Lists

If EBW Global uses third-party marketing lists in future, we will only use reputable suppliers who comply with data protection and marketing laws. Such lists remain separate from EBW’s internal databases and are used solely for promotional mailings. Each mailing is coded to identify the source list.

6. How We Keep Your Information Secure

We use industry-standard security controls including:

  • SSL encryption

  • Secure hosting via Rackspace Tier 1 data centres

  • Compliance with PCI DSS, ISO27001, and ISAE 3402 Type II

  • Access controls for authorised personnel

  • Continuous monitoring and auditing

  • Secure backup and redundancy systems

While no system is completely secure, we take all reasonable measures to safeguard your data.

7. Optional EBW Services

Some EBW services, such as the EBW Sales Mentor App, offer additional optional features. These services:

  • are not activated by default

  • may require separate consent or transparency notices

  • only process your data when you choose to use them

  • may operate using different technology environments than the EBW Assessment Platform

Your assessment data is never transferred to optional services unless you choose to use them or, in B2B cases, unless your EBW Assessment Partner authorises this.

7A. Optional Services and Additional Processing

EBW Global provides optional services that require additional processing of assessment data beyond that carried out on the EBW Assessment Platform. These services, including the EBW Sales Mentor App, will only process personal data when the user elects to use the service or, for B2B users, when the relevant EBW Assessment Partner has authorised its use. Each optional service has its own transparency or consent requirements. Full privacy terms for the EBW Sales Mentor App are set out in Appendix 1.

8. International Transfers

The core EBW Assessment Platform is hosted on secure infrastructure located within the UK/EEA. EBW Global does not transfer personal data internationally for standard assessment services.

Optional EBW services may operate on secure systems located outside the UK/EEA. Personal data is only transferred internationally when:

  • you choose to use an optional service, or

  • your EBW Assessment Partner authorises its use (B2B)

Where such transfers occur, EBW Global applies:

  • International Data Transfer Agreements (IDTA)

  • EU Standard Contractual Clauses (SCCs)

  • supplementary organisational and technical safeguards.

9. Data Subject Rights

EBW Global supports all rights under UK GDPR and EU GDPR, including rights of access, correction, deletion, restriction, portability, and objection. EBW Global also supports the Right of Access (Article 15) and assists Data Controllers in responding to rights requests as required under Articles 28 and 29.

9.1 B2B Users

If your assessment was issued by an EBW Assessment Partner, they are the Data Controller. All rights requests must be directed to them. EBW Global will support the Controller in fulfilling the request.

9.2 B2C Users

If you purchased EBW services directly, EBW Global is the Data Controller. You can exercise your rights by contacting:

info@ebwglobal.com

EBW Global may require identity verification.
Initial requests are free of charge.
We aim to respond within 30 days.

9.3 Your Right to Complain to a Supervisory Authority

If you have concerns about how your personal data has been handled, you have the right to lodge a complaint with your national data protection authority.

If you are in the United Kingdom:

Information about contacting the Information Commissioner’s Office (ICO) is available at:

https://www.ico.org.uk/

If you are located in the EU:

Details for your local supervisory authority can be found at:

https://ec.europa.eu/newsroom/article29/items/612080

If you are located outside the United Kingdom or European Union (including the United States and other international regions), you may raise any privacy concerns directly with EBW Global using the contact details in this policy.

If your country has a national or regional data protection authority, you may also have the right to submit a complaint to that authority in accordance with your local laws.

We would appreciate the opportunity to address your concerns directly first, but you are not required to contact us before approaching a regulator.

10. Retention of Data

Assessment data is retained for 18 months. After this period:

  • personal identifiers are permanently removed

  • anonymised assessment data may be retained for research, benchmarking, or quality assurance

  • EBW cannot regenerate personalised reports once data has been anonymised

11. Who We Share Information With

We only share personal data where necessary:

  • EBW Assessment Partners (for assessments they issue)

  • authorised EBW Global personnel

  • approved sub-processors

Sub-processors include:

  • Rackspace (secure hosting)

  • OpenAI (for App-specific generative AI guidance)

  • Mandrill (Mailchimp Transactional Email) for App-related emails

We do not sell data or share it for advertising.

12. Changes to This Policy

We may update this policy to reflect legal, technical, or operational changes. Updates will be posted on this page.

13. Contact Information

Privacy and Data Protection Lead
Brentfield Consultancy Ltd
The Joiners Shop
The Historic Dockyard
Chatham, Kent, ME4 4TZ
United Kingdom

Info@ebwglobal.com

Appendix 1
Sales Mentor App Privacy Addendum

(This Appendix forms part of the EBW Global Privacy Policy.)

1. Purpose of this Addendum

This Appendix explains how personal data is processed when you choose to use the EBW Sales Mentor App (“the App”).
It supplements the main EBW Global Privacy Policy and ensures compliance with the UK GDPR, EU GDPR (2016/679), and the EU AI Act (2024).

The App is an optional service.
Your assessment data is not transferred unless you choose to use the App.

2. What the App Does

The App provides optional digital features based on your EBW Sales Compass Report:

  • Meeting preparation guidance

  • Instant meeting analysis (based on User-submitted text)

  • Behavioural improvement suggestions

The App does not:

  • score or modify your EBW assessment

  • generate psychometric results

  • make employment or performance predictions

Its purpose is developmental only.

3. When Your Data is Transferred to the App

Your EBW Sales Compass Report is transferred to the App only when you explicitly consent via the App’s pre-login transparency screen.

If you do not consent:

  • your report will not be transferred

  • you will not be able to access the App

  • your assessment data remains solely on the EBW Assessment Platform

For B2B users, your EBW Assessment Partner confirms they have a lawful basis to offer the App as an optional service.

4. Personal Data Processed in the App

4.1 Data that may be processed

  • Your EBW Sales Compass Report (narrative + numerical outputs)

  • User-submitted text (e.g., meeting notes, summaries, or questions)

  • App usage metadata (feature usage, timestamps)

  • Device-level technical logs (for security)

4.2 Data that is not processed

  • Raw assessment item responses

  • Equal Opportunities Monitoring Form data

  • Payment information

  • Any other sensitive category data

Processing is limited strictly to the App’s functions.

5. International Processing and Sub-Processors

The App operates on secure systems that may be located outside the UK/EEA.
Where this occurs, EBW Global applies appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs)

  • UK IDTA

  • Technical and organisational security measures

  • Additional protections required under the EU AI Act

Sub-processors supporting the App may include:

  • Cloud hosting providers

  • AI model providers (e.g., OpenAI)

  • App infrastructure platforms (e.g., Replit)

  • Email delivery services (e.g., Mandrill/Mailchimp)

A full list is maintained in Appendix 2 — Sub-Processor Register.

No sub-processor is permitted to:

  • train AI models on EBW data

  • use data for advertising or analytics

  • retain data beyond EBW’s instructions

6. AI Transparency

The App uses generative AI to produce developmental guidance only.

AI systems used in the App:

  • do not influence EBW scoring

  • do not produce behavioural or hiring predictions

  • may generate variable outputs

  • must be interpreted with human judgement

AI outputs must not be used as the sole basis for employment or organisational decisions.

7. Prohibited Uses of the App

The App must not be used to:

  • make employment decisions without human review

  • conduct clinical or psychological diagnosis

  • train external AI systems

  • provide third-party access to User content

  • extract or repurpose App-generated content for other tools

Misuse may result in suspension of access.

8. Data Retention and Deletion

  • Data in the App is retained only as long as necessary to provide the service.

  • The App’s retention schedule is separate from the EBW Assessment Platform’s 18-month retention period.

  • Users may request deletion of App-specific data at any time.

  • After deletion or anonymisation, the data cannot be re-identified.

9. Your Rights

Users have all rights under UK GDPR and EU GDPR, including:

  • Right of access

  • Right to rectification

  • Right to erasure

  • Right to restrict processing

  • Right to data portability

  • Right to object

If your assessment was issued by an EBW Partner, they remain the Data Controller and must handle your request.

If you purchased directly from EBW Global, you may contact: info@ebwglobal.com

10. Contact Details for App-Related Privacy Questions

Privacy and Data Protection Lead
Brentfield Consultancy Ltd (EBW Global)
The Joiners Shop
The Historic Dockyard
Chatham, Kent, ME4 4TZ
United Kingdom
info@ebwglobal.com

Appendix 2
EBW Global Sub-Processor Register

(This Appendix forms part of the EBW Global Privacy Policy.)

This register lists the third-party service providers (“sub-processors”) authorised by Brentfield Consultancy Ltd (EBW Global) to process personal data on its behalf for:

  • the EBW Assessment Platform, and

  • optional Digital Services, including the EBW Sales Mentor App.

All sub-processors are contractually bound to:

  • comply with UK GDPR and EU GDPR

  • provide security equivalent to EBW Global standards

  • use data only for the purpose of delivering EBW services

  • delete or return data upon termination

  • never train AI models on EBW data

  • maintain confidentiality

Updates to this register will be made in accordance with the EBW Global Privacy Policy and/or DPA terms.

1. Core EBW Assessment Platform Sub-Processors

(All located inside the UK/EEA unless stated otherwise)

1.1 Rackspace Ltd (UK/EU)

Role: Secure cloud hosting for the EBW Assessment Platform
Purpose: Stores encrypted assessment data, personal identifiers, and report outputs
Location: UK/EU data centres
Legal Basis: Processor under GDPR
Safeguards: ISO27001, PCI DSS, ISAE 3402 Type II

1.2 Mandrill (Mailchimp Transactional Email)

Role: Automated transactional email delivery
Purpose: Sends EBW Reports and system notifications to EBW Assessment Partners
Location: United States
Safeguards: Standard Contractual Clauses (SCCs) + supplementary measures
Notes:

  • Processes only the necessary email content for delivery

  • Does not store assessment data long-term

  • Does not train models on EBW data

1.3 Rackspace Cloud Backup

Role: Encrypted offsite backup
Purpose: Business continuity for the EBW Assessment Platform
Location: UK/EU
Safeguards: As above

2. Digital Services & Sales Mentor App Sub-Processors

(Used only when Users explicitly choose to use optional digital services)

2.1 Replit, Inc.

Role: Hosting infrastructure for the EBW Sales Mentor App
Purpose: Executes app logic and user-facing functions
Location: United States
Safeguards: SCCs + technical safeguards
Notes:

  • Only receives Sales Report data after explicit User consent

  • No raw assessment items or equal opportunities data

2.2 OpenAI (ChatGPT)

Role: AI model provider
Purpose: Generates private, developmental guidance within the App based on User-provided input
Location: United States
Safeguards: SCCs, encryption, restricted processing
Important:

  • No EBW data is used to train foundation models

  • No assessment scoring or model calibration

  • No storage beyond session-level processing

2.3 Mandrill (Mailchimp Transactional Email)

Role: Email delivery for App notifications (optional feature)
Details: As listed under Section 1.2

3. EBW Global Internal Processing & Support Providers

3.1 Microsoft 365 (UK/EU)

Role: Internal staff communication + secure document storage
Purpose: Support, account administration, service management
Safeguards: ISO27001, UK GDPR-compliant cloud tenancy

3.2 Cloudflare (where enabled)

Role: Web security, CDN, DDoS protection
Purpose: Protects EBW websites and App endpoints
Location: Global network
Safeguards: No access to assessment content; edge logs only

4. Sub-Processor Use by Purpose

Purpose Sub-Processors Involved

Assessment delivery: Rackspace (hosting), Rackspace Backup

Transactional email / Report delivery: Mandrill/Mailchimp

App hosting: Replit

Generative AI for App guidance: OpenAI

Security/CDN: Cloudflare (if enabled)

Internal admin: Microsoft 365

5. International Transfer Safeguards

Where personal data is transferred outside the UK/EEA:

  • SCCs (Standard Contractual Clauses) are in place

  • UK IDTA or Addendum applied where required

  • Encryption in transit & at rest

  • Strict access controls

  • No data used for training AI models

  • No advertising, profiling, or unrelated processing

6. Changes to This Register

EBW Global will:

  • update this register when adding or replacing sub-processors

  • notify EBW Partners where required under the DPA

  • ensure new sub-processors meet equivalent legal and security standards