Privacy notice
Version 1.1
1 · Who we are
HONED Performance & Wellbeing is operated by Finch Theory Limited.
Finch Theory Limited is the Data Controller for personal information collected
through honedperformance.uk.
| Legal name | FINCH THEORY LIMITED |
| Company number | 17234046 |
| ICO registration | C2012462 |
| Registered office | 43 Church Manor, Bishop’s Stortford, England, CM23 5AF |
This notice covers the website at honedperformance.uk and the enquiry, booking
and event-registration routes offered from it. It does not cover any other
website, and it does not cover what an independent specialist or partner does
with an enquiry after we have passed it to them — section 6 explains that
distinction.
2 · What this website does, and does not, do
This website has no forms on it. Nothing on honedperformance.uk collects
your details directly. When you make an enquiry, register interest in an event or
request a booking, you follow a link to a form or calendar hosted by our customer
relationship provider, and you enter your details there. Section 3 sets out what
happens in each case.
This website sets no analytics, advertising or tracking cookies, loads no third-party fonts, scripts or trackers, and stores nothing in your browser. Section 5 covers cookies in full.
3 · What we collect, and why
General enquiries by email
The website publishes an email address so that you can ask a question. If you write to us, we hold your email address, your name if you give it, and whatever you choose to put in your message, so that we can reply.
That address is [email protected], which is a shared mailbox
operated within the wider Aetas group rather than a Finch Theory mailbox. We say
so plainly because it affects who can read your message. Which mailbox HONED
publishes is under review; if it changes, this notice changes with it.
Specialist and partner enquiries, and event registrations
When you ask to be put in touch with a specialist, a partner organisation or a service, or register your interest in an event or partner meeting, you are taken to an enquiry form hosted by HighLevel (GoHighLevel), our customer relationship provider. You enter your details on their form, not on this website.
Alongside what you type, the link carries context about where the enquiry came from, so that it can be answered by the right person. That context is: the type of enquiry, the specialist, partner organisation, service or category it relates to, the page you started from and that page’s address. Where a partner organisation has given us a routing address for enquiries, the link also carries that address so the enquiry reaches them.
That context describes the enquiry, not you. It is added by the website from the page you were reading, and it contains nothing you have not chosen to do.
Booking requests
/book-a-review offers a booking calendar hosted by HighLevel
(GoHighLevel). The calendar does not load until you open it. When it does, you
enter your details on their calendar to request a meeting.
Specialists listed in our directory
We publish a directory of independent specialists. If you are listed in it, we hold and publish a limited amount of professional information about you: your name, your job title, the organisation you work through, and the specialist categories you are listed under.
We did not obtain this information from you. It was already published about
you in the public specialist directory that this website replaced, at
wellbeinghub.aetas-wealth.com, and we migrated it from there. We publish no
more personal information than was already publicly available from that source,
and we record the source location for each listing.
We do not publish your direct contact details. These are withheld for every listing unless separate publication permission has been explicitly recorded for the individual concerned.
Technical and security information
This website is delivered through Cloudflare, which hosts it and protects it from automated abuse. As part of delivering and securing any website, Cloudflare processes technical request information, which includes your IP address.
4 · Our lawful bases
| What we do | Lawful basis |
|---|---|
| Reply to an enquiry you send us | Legitimate interests — responding to a request you have deliberately made |
| Pass your enquiry to the specialist or partner you asked for | Legitimate interests — acting on a request you have deliberately made |
| Arrange a booking you have requested | Legitimate interests — arranging the meeting you asked for |
| Publish a specialist’s professional listing | Legitimate interests — preserving the continuity of an existing public directory |
| Deliver and secure the website | Legitimate interests — keeping the site available and protected from abuse |
Where we rely on legitimate interests, you have the right to object, and section 9 explains how.
5 · Cookies and analytics
We do not use analytics, advertising or tracking cookies on this website. There is no Google Analytics, no tag manager, no advertising pixel and no third-party tracker in the pages we publish. The typefaces are served from this website rather than from a font provider, so no third party is contacted to render a page.
Cloudflare’s security layer may set a strictly necessary cookie as part of the automated check that distinguishes human visitors from automated traffic. This is a security measure, runs without any interaction from you, and is not used for advertising, analytics or tracking.
The enquiry form and booking calendar are hosted by HighLevel and are not part of this website. When one opens, your browser connects to HighLevel, and they may receive your IP address before you submit anything. Their own cookies and their own privacy notice apply to their pages.
6 · Who we share information with
We do not sell, rent or trade your personal information.
Our processors
These suppliers process personal information on our instructions.
| Processor | What they do for us | Where |
|---|---|---|
| HighLevel (GoHighLevel) | Hosts the enquiry forms and the booking calendar, and stores and manages the contact and enquiry records created through them | USA |
| Cloudflare | Hosts and delivers this website and protects it from automated abuse | Global |
We require processors to handle personal information in accordance with UK GDPR and to apply appropriate technical and organisational security measures.
Specialists and partners are not our processors
HONED lists independent specialists who work for their own organisations. When you submit an enquiry for a specialist, provider or service, or register your interest in an event, you are asking us to put you in touch with that organisation, and we pass your enquiry to them so that they can respond to you.
The organisation receives your name, your email address, your company name if you gave one, the content of your message, and the context of your enquiry — which specialist, service or event it relates to and which page you sent it from.
That organisation is an independent controller, not our processor. It receives your enquiry so that it can respond to you, and it decides for itself how it handles your information from that point onwards. Its own privacy notice applies to what it does with it, not this one.
We may also disclose information where we are required to do so by law, by court order, or by a regulatory authority.
7 · Transfers outside the UK
HighLevel processes data in the United States. Those transfers are made under the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, and HighLevel states that it participates in the Data Privacy Framework, including the UK Extension.
Cloudflare operates a global network, so technical request information may be processed outside the UK as part of delivering the website to you.
8 · How long we keep information
We keep personal information only for as long as is necessary for the purpose it was collected for, or as required by law.
- Email enquiries — up to 24 months, unless the enquiry leads to an ongoing relationship, in which case the record retention below applies.
- Contact and enquiry records — for the duration of our relationship with your organisation, and for up to six years afterwards to meet legal and record-keeping requirements.
- Specialist directory listings — we retain this professional directory information for as long as the specialist remains listed in the directory. We may remove or update it sooner where appropriate, including following the exercise of applicable data protection rights.
When information is no longer needed, it is securely deleted.
9 · Your rights
Under UK GDPR you have the right to:
- access a copy of the personal information we hold about you;
- rectification of information that is inaccurate or incomplete;
- erasure of your personal information, subject to any legal obligation that requires us to keep it;
- restrict our use of your information in certain circumstances;
- data portability, where processing is based on consent or a contract;
- object to processing based on our legitimate interests — and where you object, we will stop unless we can demonstrate compelling grounds to continue;
- withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before you withdrew it.
If you are listed in our specialist directory, you can object to that publication at any time, and you can ask us to correct or remove what we publish about you.
To exercise any of these rights, contact [email protected]. We will respond within one calendar month, and we may ask you to verify your identity first.
10 · Complaints
If you are unhappy with how we have handled your personal information, please tell us first so that we can put it right.
You also have the right to complain to the Information Commissioner’s Office, the UK’s data protection regulator, at ico.org.uk or by calling 0303 123 1113.
11 · Contact us
Finch Theory Limited Company number 17234046 ICO registration number: C2012462 43 Church Manor, Bishop’s Stortford, England, CM23 5AF Email: [email protected]
12 · Changes to this notice
We will update this notice when what we do with personal information changes. The version and date at the top of this page tell you which version you are reading.