Version: 3.1 Last Updated: October 2026
1. Introduction
This Privacy Policy explains how MyAcumen (“we”, “us”, “our”) collects, uses, shares, and protects your personal data when you use our services, including via our website, assessments, Debrief calls, coaching calls, and Membership Programmes.
We are committed to safeguarding your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Data Controller: MyAcumen (Garry Mansfield trading as MyAcumen) Halstead, Henley in Arden, B95 5JL, UK
Data Protection Officer: Garry Mansfield Email: garry@myacumen.online
2. What Data We Collect
We may collect and process the following categories of personal data:
Identity data: full name, title, role
Contact data: email address, phone number, billing address
Account data: username, subscription status, and account preferences
Transactional data: details of payments, purchases, and service bookings
Assessment data: your responses to MyAcumen assessments (Core Skills, Role Skills, TrustBuilder Personality, Motivator, and AI Readiness); your AI Readiness profile is derived from your other assessment results rather than a separate assessment. Also includes your results and diagnostic reports generated from your responses, and details of assessments completed including dates and completion status.
360 Feedback data: names and contact details of individuals you nominate to provide feedback; the anonymous responses they submit; and the aggregated themes and patterns included in your report
Membership data: resource library access and downloads, community forum activity and posts, session attendance, membership history, and subscription dates
Coaching and Debrief data: notes and summaries from your Debrief call and any optional coaching calls; any documents or materials shared during those sessions
Usage data: how you interact with our platform and website, pages visited, time spent, features used, downloads, and resource access
Technical data: IP address, browser type, operating system, device information, and cookie identifiers
Marketing preferences: your preferences for receiving communications, and email engagement data such as opens and clicks
Support messages: any messages you send via our support chat
3. How We Use Your Data
We process your personal data for the following lawful purposes:
| Purpose | Legal Basis |
|---|---|
| Delivering and administering your assessment(s) | Performance of a contract |
| Generating your diagnostic report | Performance of a contract |
| Delivering AI-powered report narratives and the Ask Mya assistant | Performance of a contract |
| Delivering Debrief calls and coaching support | Performance of a contract |
| Providing and administering membership services | Performance of a contract |
| Processing payments securely | Performance of a contract / Legal obligation |
| Sending administrative and transactional emails | Legitimate interests |
| Personalising your assessment experience | Performance of a contract / Legitimate interests |
| Providing customer support and responding to enquiries | Legitimate interests |
| Marketing communications about our services | Consent, or legitimate interests for business contacts (see “Contacting business leaders” in section 10) |
| Complying with legal and regulatory obligations | Legal obligation |
| Improving our platform, services, and user experience | Legitimate interests |
| Preventing fraud and maintaining security | Legitimate interests / Legal obligation |
4. AI-Powered Features
MyAcumen uses artificial intelligence to generate personalised written content within the platform. This section explains how that works and what it means for your data.
What AI is used for
Assessment report narratives: after you complete an assessment, your scores and competency data are sent to an AI model to generate the written commentary in your report. This is what makes your report specific to you rather than generic.
Ask Mya: Mya is an AI assistant built into the platform. She can answer questions about your results, drawing on your assessment data to give specific, relevant responses. When you use Ask Mya, your question and the relevant parts of your assessment data are sent to the AI model to generate her reply. Mya does not retain memory between sessions, each conversation starts fresh.
360 Feedback summary: the overall summary paragraph in your 360 Feedback report is generated by AI using your aggregated competency scores. Individual rater responses are never included in what is sent to the AI.
Which AI provider we use
We use the Anthropic Claude API to power all AI features on the platform. Anthropic acts as a data processor on our behalf under a Data Processing Agreement incorporated into their Commercial Terms of Service.
What data is sent to Anthropic
Only the data needed to generate your specific output is sent, your competency scores, sub-competency scores, and relevant question-level responses. We do not send your name, email address, or any information that directly identifies you. The data is sent solely to generate your report or Mya’s response and for no other purpose.
How Anthropic uses your data
Anthropic does not use data submitted via their API to train their AI models. This is confirmed in their API Data Processing Agreement. Your assessment data is processed by Anthropic’s systems only to generate the requested output and is not retained by Anthropic for any other use.
AI content is a starting point, not a verdict
The written commentary and Mya’s responses are generated to help you understand your results. They are not a professional assessment, a clinical evaluation, a performance appraisal, or a hiring decision tool. You should use the content as one input alongside your own judgement and, where appropriate, the guidance of a coach or manager.
How long AI-generated content is stored
Generated report narratives are cached in our database so you can view them repeatedly without regenerating them. This cached content is deleted when your account data is deleted. Mya’s conversation history is held in your browser session only and is not stored in our database.
5. How We Share Your Data
We may share your personal data with:
Essential service providers: all providers are contractually bound by confidentiality agreements and data protection obligations, and process data only as instructed by us. See Section 6 for the full list.
Professional advisors: legal or accounting firms, where necessary for compliance or legal matters
Regulatory bodies: where required by law, we may disclose data to law enforcement, regulatory authorities, or government bodies
360 Feedback providers: rater personal data (name, email) is used only to invite them to provide feedback. Raters will not see your assessment results unless you explicitly choose to share them. You control the feedback process and may withdraw nominations before the feedback window closes.
At your direction: you may choose to share your assessment report with a manager, coach, mentor, or other third party for development purposes. We only disclose results when you provide explicit consent.
We do not sell, rent, or trade your personal data to third parties for marketing or commercial purposes.
6. Our Data Processors
We use a small number of trusted third-party services to run the platform. Each processes data only on our instructions and under contract.
Siteground: hosts our marketing website, community hub, and online store at myacumen.online and hub.myacumen.online. siteground.com/privacy
Supabase: stores your account information and assessment data in a managed PostgreSQL database. Data is encrypted at rest and in transit. SOC 2 Type II certified. supabase.com/privacy
Vercel: hosts the MyAcumen assessment application. Requests are processed via Vercel’s global edge network under a Data Processing Agreement. vercel.com/legal/privacy-policy
Anthropic: powers AI-generated report content and the Ask Mya assistant, as described in Section 4. anthropic.com/privacy
SMTP2Go: delivers transactional emails including your welcome message, access link, and 360 Feedback invitations. Sent from hello@myacumen.online. smtp2go.com/privacy
OttoKit: handles purchase automation, passing your name, email, and role to our platform when you buy. ottokit.com/privacy
SureCart: manages our online store and order processing at hub.myacumen.online. surecart.com/privacy
Stripe: processes payment card transactions on our behalf. We do not store your card details. stripe.com/gb/privacy
SureContact: CRM system used to manage customer records on our community hub. surecontact.com/privacy-policy/
TidyCal: used to schedule Debrief and coaching calls. tidycal.com/privacy
Bunny.net: delivers embedded video content within the platform. May set cookies to support playback. bunny.net/privacy
Charla: provides the support chat on the platform. Messages and basic session data are processed by Charla when you use the chat. charla.io/privacy
7. International Data Transfers
Some processors operate infrastructure outside the UK or EEA. Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including standard contractual clauses (SCCs) where required under UK GDPR. Each processor linked above publishes their transfer mechanisms in their privacy documentation.
8. Data Retention
We retain your data only as long as necessary for the purposes we collected it, including to satisfy legal, accounting, tax, or reporting requirements.
| Data Type | Retention Period |
|---|---|
| Account and transaction data | 6 years from last interaction (for tax and accounting purposes) |
| Assessment responses and results | Duration of active licence; or 36 months after cancellation |
| AI-generated report narratives | Retained while account is active; deleted on account deletion |
| 360 Feedback rater responses | Anonymised immediately after report generation; raw data deleted |
| Membership activity data | While subscription is active; 12 months after cancellation |
| Debrief and coaching notes | Duration of active subscription; 12 months after cancellation |
| Marketing consent records | Until you withdraw consent |
| Website usage and technical data | Up to 12 months |
| Purchase records | 7 years (legal obligation) |
If you request deletion of your data, we will act within 30 days unless we are legally required to retain it.
9. 360 Feedback Confidentiality
When you nominate individuals to provide 360 Feedback as part of your assessment:
For you (the participant): feedback providers remain anonymous. You see themes, patterns, and aggregated insights, never individual responses.
For feedback providers: their responses are anonymous and they will not be identified in your report or to anyone else. They will not see your assessment results unless you choose to share them. Their personal data (name, email) is used only to invite them to participate.
Your control: you decide who provides feedback, you can withdraw nominations before the feedback window closes, and you decide whether to share your report with others.
10. Marketing and Communication Preferences
You can manage your marketing preferences at any time by:
- Clicking the “unsubscribe” link in any marketing email we send
- Contacting us at hello@myacumen.online with the subject line “Communication Preferences”
We will honour your preferences within 5 working days. You will continue to receive transactional and administrative emails (such as booking confirmations, payment receipts, and important service updates) regardless of your marketing preference, as these are necessary to fulfil your contract with us.
Contacting business leaders we think may be interested
We sometimes email senior people at UK companies about our services, where their role suggests the Team Diagnostic is relevant to their work. We do this on the basis of our legitimate interests in promoting our business to relevant organisations.
We get the details we use (name, job title, company and work email address) from B2B contact data providers and from public sources such as company news and job adverts. We only contact people in their professional role, at limited companies or LLPs, and we send no more than three emails.
Every email tells you how to stop. If you ask us to, we’ll stop straight away and keep only your email address on a “do not contact” list, so we never contact you again. If you don’t reply, we delete your details within six months of our last email. You can ask us at any time where we got your details, or ask us to delete them, by replying to the email or writing to garry@myacumen.online.
11. Cookies and Tracking Technologies
MyAcumen uses only the cookies necessary to keep you signed in and the platform working correctly. We do not use advertising or tracking cookies.
Third-party services (Bunny.net for video, Charla for support chat) may set their own cookies in connection with their features. These are covered by their respective privacy policies.
You can manage cookie preferences through your browser settings. Disabling certain cookies may affect your ability to use some features of the platform.
A full Cookie Policy is available on request.
12. Data Security
We implement appropriate technical and organisational security measures to protect your personal data, including:
- SSL/TLS encryption for data in transit
- Encryption of sensitive data at rest
- Secure password hashing and authentication protocols
- Row-level security controls, access to data is restricted by role
- Regular security reviews and vulnerability assessments
- Incident response procedures to address any data breaches
No method of transmission over the internet or storage is 100% secure. Whilst we implement strong protections, we cannot guarantee absolute security.
13. Your Data Protection Rights
Under UK GDPR, you have the following rights:
Right of access: you can request a copy of all personal data we hold about you.
Right to rectification: you can ask us to correct inaccurate or incomplete data.
Right to erasure: you can request deletion of your data, subject to certain exceptions where we are required to retain it by law.
Right to restrict processing: you can limit how we use your data under certain circumstances.
Right to object: you can object to processing where we rely on legitimate interests.
Right to data portability: you can receive a copy of your data in a structured, machine-readable format and request we transfer it to another organisation.
Right to withdraw consent: where we process data based on your consent (such as marketing emails), you can withdraw that consent at any time.
Automated decisions: our AI features generate content but do not make automated decisions that have legal or similarly significant effects on you.
To exercise any of these rights, please contact:
Email: garry@myacumen.online Address: Garry Mansfield (DPO), MyAcumen, Halstead, Henley in Arden, B95 5JL, UK
Please include “Data Subject Request” in the subject line, specify which right(s) you are exercising, and provide sufficient information for us to locate your data. We will respond within 30 days (or up to 90 days for complex requests, with notice to you).
14. Complaints
If you are not satisfied with how we handle your personal data, please contact us first at garry@myacumen.online. We will investigate and respond within 30 days.
If you remain unsatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
Website: ico.org.uk Email: casework@ico.org.uk Phone: 0303 123 1113
15. Children and Minors
MyAcumen services are not directed at individuals under 18 years old and we do not intentionally collect data from minors. If we become aware that we have collected data from a minor, we will delete it promptly.
If you believe a minor’s data has been collected, please contact us immediately at hello@myacumen.online.
16. Third-Party Links
Our website and communications may contain links to third-party websites and services. This Privacy Policy applies only to MyAcumen services. Third-party services have their own privacy policies and we are not responsible for their practices. We encourage you to review their policies before providing personal data.
17. Data Protection Impact Assessments
Where we introduce new services or processing activities that may pose higher risks to your privacy, we conduct a Data Protection Impact Assessment (DPIA) to identify and mitigate risks before proceeding.
18. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or other factors. When we make material changes, we will update the version number and date at the top of this policy and notify you by email.
19. Contact Us
Data Protection Officer: Garry Mansfield garry@myacumen.online MyAcumen, Halstead, Henley in Arden, B95 5JL, UK
General enquiries: hello@myacumen.online
MyAcumen is a diagnostic tool for self-awareness and capability development. It is not a substitute for medical, therapeutic, or psychiatric evaluation.