Website and Cookies Policy

Wharton Global Limited is committed to protecting the privacy of everyone who visits or interacts with our website.

This policy explains what personal data we collect through our website, how and why we use it, who we may share it with and your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Our wider approach to protecting personal data across our occupational psychology, assessment, coaching and consultancy services is set out in our Data Protection and Privacy Policy.

Wharton Global Limited is the data controller for personal data collected through this website.

Wharton Global Limited
115 The Maling, Hoults Yard
Newcastle upon Tyne, NE6 2HL
United Kingdom

Company Number: 03760875
ICO Registration Number: Z8258711
Email: hello@wharton.global
Telephone: +44 (0)191 691 1663

If you have any questions about this policy or how we handle your personal data, please contact us using the details above.

When you use our website, we may collect:

• Contact and enquiry information – when you submit an enquiry through our website, we may collect your name, email address, organisation, telephone number and the content of your message, together with any other information you choose to provide.
• Email correspondence – if you contact us by email, we retain your email address and the contents of that correspondence as appropriate.
• Website usage and analytics information – our website and analytics tools may collect technical and usage information such as your IP address, approximate location, device and browser type, pages viewed, referring URL and time spent on the website.
• Business visitor information – we use LeadInfo to help us understand which organisations visit our website. LeadInfo may use IP address information to identify the organisation associated with a visit; it is intended to identify organisations rather than individual visitors.

We do not seek to collect special category personal data through our website.

If you subsequently take part in an assessment, coaching or development programme or another Wharton Global professional service, additional personal data may be processed under the terms and privacy information provided in connection with that engagement.

We may use personal data collected through our website to:

• Respond to enquiries and provide information you have requested.
• Communicate with prospective and existing clients and other business contacts.
• Maintain appropriate records of our correspondence and professional relationships.
• Understand how our website is used and improve its content, performance and user experience.
• Support appropriate business development and marketing activities.
• Maintain the security and integrity of our website and systems.
• Meet applicable legal and regulatory obligations.

Our lawful basis for processing will depend on the purpose and circumstances and may include:

• Consent – including for non-essential cookies and certain marketing activities where consent is required.
• Contract – where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you.
• Legitimate interests – including responding to business enquiries, maintaining business relationships, understanding how our website is used and protecting our systems, provided those interests are not overridden by your rights and freedoms.
• Legal obligation – where we are required to process or retain information to comply with the law.

Where we rely on consent, you can withdraw your consent at any time.

Cookies are small text files and similar technologies used by websites to store or access information on your device.

Our website uses strictly necessary technologies required for the website to operate and may also use analytics and business visitor-identification technologies.

We use Google Analytics to help us understand how visitors use our website and LeadInfo to help us understand which organisations visit the website.

Where consent is required, non-essential cookies and similar technologies will not be used until you have made your choice through our cookie controls.

You can accept or refuse non-essential cookies when you first visit the website and can change or withdraw your preferences at any time through our Cookie Settings.

Our Cookie Settings provide further information about the individual cookies and technologies currently in use, including their purposes and duration.

We may share website-related personal data with trusted service providers where necessary to operate, maintain and understand the use of our website.

These may include:

• Google Analytics (Google Ireland Limited) – for website analytics.
• LeadInfo (Leadinfo B.V.) – for business visitor identification.
• Website hosting, database and technical service providers.
• Email and communications providers.
• IT and business systems providers.
• Professional advisers and regulators where necessary or required by law.

Where an organisation processes personal data on our behalf, we seek to ensure appropriate contractual and security arrangements are in place.

We do not sell your personal data.

Some service providers may process or store personal data outside the United Kingdom. Where this occurs, we will ensure that an appropriate safeguard or legally recognised transfer mechanism is in place where required, such as UK adequacy regulations, the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected.

As a general guide:

• Website enquiries and correspondence – up to 24 months from our last meaningful contact, unless the enquiry develops into an ongoing client or business relationship.
• Marketing and business contact information – while there is a relevant business relationship or legitimate reason to retain the information, subject to periodic review and any opt-out request.
• Cookie and analytics information – in accordance with the retention periods shown in our Cookie Settings and those applied by the relevant service providers.

Where an enquiry develops into a client engagement, relevant information may subsequently be retained in accordance with our Data Protection and Privacy Policy and the requirements applying to that engagement.

When personal data is no longer required, we will securely delete or anonymise it as appropriate.

We apply appropriate technical and organisational measures to protect personal data against accidental or unlawful loss, alteration, destruction, unauthorised disclosure or access.

These measures include, where appropriate, access controls, secure and individually authenticated accounts, encryption, appropriate contractual safeguards with service providers and data protection and information security training for our team.

We keep our security arrangements under review and will respond to and report personal data breaches where required by law.

Under UK data protection legislation, you may have the right to:

• Access – obtain a copy of the personal data we hold about you.
• Rectification – have inaccurate or incomplete personal data corrected.
• Erasure – ask us to delete your personal data in certain circumstances.
• Restriction – ask us to restrict how your personal data is used in certain circumstances.
• Objection – object to certain processing, including direct marketing.
• Portability – receive certain personal data in a structured, commonly used and machine-readable format where applicable.
• Withdraw consent – where we rely on consent, withdraw it at any time without affecting processing carried out before withdrawal.

To exercise any of these rights, contact hello@wharton.global.

We will normally respond within one month. There is normally no charge, although we may ask you to provide information necessary to verify your identity before acting on a request.

If you are unhappy with how we have handled your personal data, please contact us first at hello@wharton.global so that we have an opportunity to address your concern.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection.

Website: ico.org.uk
Telephone: 0303 123 1113

We will review this policy periodically and update it where our website, technologies, business practices or legal requirements change.

The latest version will be published on our website with a revised date.

Document Ownership
Natasha Addis
Commercial Director

Approved by
Neville Wharton
Managing Partner

Date: August 2026