Privacy Policy

The Headlines:


Data Controller

Helen Sharp


Collected Personal Data 

(Via online contact form)

company name


email address

postal address (upon agreement with the user)


Purpose of collecting data

returning contact from website enquiry form

distribution of training materials

3 yearly refresher training reminder


Use of Cookies

Our Website host (Ionos) does not collect cookies



Privacy policy

March 2024

Twelve15 Projects Ltd ("twelve15", "We", "Us") is a controller of your personal data. We respect your data and your privacy is important to us.

This Privacy Policy explains what personal data we collect and how it is used. This policy also explains what rights you have over your personal data and how you can use those rights.

You have a number of rights under data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal information we process about you. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

1. Summary of how we use your data and your rights

We may use your data to provide and improve our products and services, including for marketing, research, feedback and enquiries, and for safety and security purposes. 

We will use your data to comply with laws and regulations. We use your data to prevent and detect crime, such as fraud.

Where we rely on consent as the legal basis on which we process your personal information, you may also withdraw that consent at any time. To exercise any other data rights, such as obtaining a copy of your data, correcting, deleting or restricting how we use your data Please see “Your rights” for more information.

You can unsubscribe from marketing communications at any time. To opt out of direct marketing, including profiling for direct marketing purposes please email us using the subject title “unsubscribe” to and we will remove your details from the marketing list, normally within 14 working days. 

Our websites do not collect cookies. You can reject and block cookies in your browser settings. 

2. Information we collect from you

We may collect information when you contact us via the website, email, whatsapp, text, or social media messaging.

In particular:

We keep information you give us directly such as contact details (including name, email, address and telephone number), comments, date of birth, gender, region, frequency of visits, feedback, marketing preferences.

If you post information online about us or provide feedback, we keep a record.

If you contact us directly and complain or give feedback, we will record details and all related information (including that you provide to us) such as emails, letters, phone calls, date of birth.

3. Information we receive from third parties

We do not receive your information from other people in normal circumstances. 

4. How we use information and the legal basis

We are allowed to use your data only if we have a proper reason to do so such as:

To fulfil a contract we have with you, such as agreed training, reminders for refreshers etc.

When you consent to it; for our legitimate interests; or to comply with the law.

We have set out below how and why we use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.

When you buy something from us, we use your information to fulfil our contract with you.

We take information to communicate with you, check your identity, take payment, and provide products and services.

To run our business and pursue our legitimate interests, we use your information.

Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our site and services, developing new products and services, and telling you about them and conducting market research.

Further details of our legitimate interests:

To run and promote our business, we use your information:

To provide and improve our products and services, and to respond to you if you contact us.

When we monitor our website, social media platforms such as Instagram, Facebook, Twitter, LinkedIn. If you post comments online or in other media, we capture this information, use it to contact you, and use it to improve our products and services.

Show targeted advertisements within your social networks and to other people like you.

To contact you where you provide us with market research feedback.

We also process the insight data for our legitimate interests to understand how you interact with our Facebook page and its contents and to help us improve our services and contents.

To prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, including where we are required to do so by law, we:

record calls where appropriate and emails.

To comply with law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:

We monitor, and record communications, including incoming and outgoing calls and emails.

We verify your identity in certain circumstances, but we would tell you if this was the case.

We keep records to comply with health and safety legislation, including accounting for the number of individuals on our premises and logging of any accidents.

If you give us consent, we:

Send you electronic marketing, of which you can subscribe or unsubscribe from our marketing communications at any time.

Use data for other purposes where we explain that purpose when we ask for your consent.

When you give consent, you are able to withdraw that consent at any time by contacting us using the details in the “Contact Us” at the end of this policy. If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.

Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time on the website or by using the details in the “Contact Us” section at the end of this notice.

When the law requires us to process your data we will do so. This can include:

Legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement.

When you exercise your rights under data protection legislation, including when you ask to unsubscribe from our marketing communications.

5.  Data Sharing

We use third party providers for the following services:

Recording training progress and certificates

Sending promotional offers

Customer feedback surveys

Data analysis to enable us to optimise our services (including locations and products) 


IT development, support, maintenance and hosting

Personal data may be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.

6. Cookies and similar technologies

Our website does not collect cookies 

7. Data retention

We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active user of our website or where required by law or to protect legal rights.

We always look to keep your data for the minimum time in line with data protection principles and our processes. For example, we keep:.

Personal information related to products and services purchased historically for as long as the personal data is required in order for us to fulfil our contract with you, as long as required to service any related warranty and for 6 years from performance of our contract with you.

Records of payment information in line with tax law and audit requirements.

Customer feedback and correspondence with our customer services teams for up to 2 years afterwards, depending on the nature of the interaction and any applicable law, such as health and safety. This enables us to respond to any questions or complaints.

Information to maintain records according to rules that apply to us.

If you unsubscribe from marketing communications, we keep a record of this request indefinitely to ensure we do not send you direct marketing again.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.

8.  Your rights

You have rights over your personal data, and you can:

ask for a copy of your information;

ask for information to be corrected;

ask for information to be erased or deleted;

ask for us to limit or restrict processing;

object to us processing your data, in particular, where we do not have to process the data to meet a contractual or other legal requirement and in relation to processing for direct marketing purposes, including profiling for direct marketing purposes;

ask us to send you a copy in a structured digital format or ask for us to send it to another party.

Some rights, however, may be limited. We may be obliged by law or regulation to keep information. We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data. On occasion there may be a compelling legitimate interest to keep processing data.

If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below. To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data, this helps us to protect the personal information belonging to our customers against fraudulent requests.

You have a right to complain to an EU data protection authority. This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”).

9. Contact details

To discuss or change your details, including preference settings, you can do this  by emailing us with 

For any queries relating to data protection, please contact is with the subject line “DATA” to 

We may change or update this policy from time to time. We will communicate these as appropriate by updating our website or, where legally required, by actively telling you about the changes.