Privacy Policy

 Aletheia is a trading name of Autobahn Capital Limited ("we", "us", or "our"), a company registered in the Isle of Man. We provide HR Consultancy and Coaching Services to organisations (“Client Organisations”) and individuals.

Autobahn Capital Limited is the Data Controller for the personal data we process. We are committed to protecting the privacy and security of your personal data in accordance with applicable legislation.

 Data protection in the Isle of Man is governed by the Data Protection Act 2018, together with the Data Protection (Application of GDPR) Order 2018 (the “Applied GDPR”). References in this notice to "GDPR" refer to the Applied GDPR as it operates in the Isle of Man.

“Personal data” means any information relating to an identifiable living individual. We collect and process data necessary to deliver our services, including:

• Identity & Contact Details: Name, business/personal email, address, and      telephone numbers.
• Professional Details: Job titles, roles, organisational structures, and career history.
• Engagement & HR Records:Consultancy notes, leadership impact data, strategic goals, performance reviews, and records relevant to specific HR projects      (e.g., disciplinary or grievance info).
• Psychometric Data: Assessment data from tools such as EQ-i 2.0 or EQ 360 to support      leadership development.
• Financial Data: Billing information and payment details.
• Marketing & Technical Data:Communication preferences, IP addresses, cookies,      and website analytics.

 We collect data directly from you (via our website, email, or consultations), through contractual agreements with Client Organisations, and via automated technologies (cookies). 

We use this data to:

• Perform our contract to provide HR and Coaching services.
• Manage client relationships and respond to inquiries.
• Send marketing communications (where you have consented or have not opted out).
• Comply with legal and regulatory obligations.

 During our services, we may encounter sensitive information (e.g., health data in sickness reviews or diversity data). We process this only when strictly necessary, typically based on:

• Employment Law obligations (Schedule 2 of the Data Protection Act 2018); or
• Your explicit consent.

Under the Applied GDPR, we rely on the following bases:

• Contract: Necessary to deliver the services you or your employer have engaged us for.
• Legitimate Interests: To manage our professional practice effectively and securely.
• Legal Obligation: To comply with Isle of Man law (e.g., tax or corporate record keeping).
• Consent: Where you have provided clear, affirmative internal for a specific purpose (e.g., psychometric testing).

We treat all information as confidential. We do not sell or rent your data. Your data may be shared only with:

• Service Providers: Secure platforms supporting our practice (e.g. Microsoft, MHS for psychometrics).
• Professional Supervisors: To ensure coaching quality (data is anonymised).
• Legal Authorities: If required by law or to prevent serious harm to you or others.

If we transfer personal data outside the Isle of Man or the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Transferring data to countries deemed "adequate" by the Isle of Man authorities.
• Using Standard Contractual Clauses (SCCs) approved for use in the Isle of Man.

We implement appropriate technical and organisational measures to prevent unauthorised access, loss, or misuse:

• Platform Security: Utilising industry-standard encryption.
• Device Security: All project documents are stored on password-protected, encrypted devices.
• Minimisation: We use unique reference codes or initials rather than full names in local working files wherever possible.

We retain personal data only for as long as necessary to fulfil the purposes we collected it for.

• Client & Business Records: Generally retained for 6 years following the end of the contract for tax and legal purposes.
• Marketing Data: Retained until you withdraw consent.

Under the Applied GDPR, you have the right to:

• Access your data (Subject Access Request).
• Rectify inaccurate information.
• Erase your data ("Right to be forgotten").
• Restrict or Object to our processing of your data.
• Data Portability (moving your data to another provider).

To exercise your rights or ask questions, please contact: Leila Goelz  DPO@aletheia-global.com

If you remain unsatisfied, you have the right to lodge a complaint with the Isle of Man Information Commissioner:

• Website: www.inforights.im
• Address: P.O. Box 69, Douglas, Isle of Man, IM99 1EQ.