Privacy Policy

Last updated: November 2025

This Privacy Policy explains how we collect, use, and protect your personal information when you use the Firefly Online Learning Library (“the Library”), operated by Firefly Leadership Ltd.

Firefly Leadership Ltd is registered in Scotland (Company Number: 07650668, VAT Registration: 118465801).
If you have any questions, you can contact us at onlinelearning@thefireflygroup.co.uk.

1. Overview

We are committed to protecting your privacy and handling your data responsibly.
This policy explains:

  • What information we collect

  • How and why we use it

  • How we keep it secure

  • Your rights under data protection law

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

We collect and process the following types of personal data, depending on how you interact with us:

Information you provide directly

  • Name

  • Email address

  • Phone number

  • Job title and organisation

  • Payment details (processed securely by third-party payment providers)

  • Postal address (only if we send you physical materials)

Information collected automatically

  • Usage data (such as pages visited, time spent on the site, and referring links)

  • Analytics data collected through Squarespace and Google Analytics

Information provided by others

  • Your employer or client company may share your details with us if they have purchased access on your behalf (for example, to enrol you in the Library or a Firefly coaching or facilitation programme).

3. How We Collect Data

We collect personal data in several ways:

  • When you sign up directly for a course, subscription, or event

  • When you fill in forms, surveys, or download materials

  • When you contact us by email

  • When your organisation provides your details for access to the Library or a related Firefly programme

  • Automatically through website analytics tools

4. How We Use Your Information

We use your data for the following purposes:

  • To create and manage your account and provide access to the Library

  • To deliver learning content and downloadable materials

  • To process payments and manage subscriptions

  • To communicate with you about your access, updates, or related services

  • To improve our services, content, and user experience

  • To send marketing or service emails, where you have opted in or where we have a legitimate business relationship

  • To send physical products or materials, if applicable

We will never sell your data or share it with unrelated third parties for marketing purposes.

5. Legal Basis for Processing

We rely on the following legal bases under UK GDPR:

  • Contractual necessity – where processing is required to deliver your subscription, account, or purchased service

  • Legitimate interests – for improving services, communicating with existing clients, or ensuring system security

  • Consent – for optional marketing communications

  • Legal obligation – where we must retain certain records for tax or accounting purposes

6. Data Sharing

We may share limited personal data with:

  • Service providers who help us deliver our online learning (for example, Kajabi, Squarespace, or Stripe)

  • Your employer or client organisation, when they have arranged your access

  • Professional advisors, such as accountants or legal representatives, if necessary for business operations

  • Regulators or authorities, if legally required

All third-party providers we work with are required to keep your data secure and process it only for agreed purposes.

7. Data Retention

We keep your personal data only as long as necessary to fulfil the purpose for which it was collected, including legal or accounting requirements.
When data is no longer required, it will be securely deleted or anonymised.

8. Your Rights

Under UK data protection law, you have the right to:

  • Access a copy of your personal data

  • Request correction of inaccurate data

  • Request deletion of your data (“right to be forgotten”)

  • Restrict or object to certain types of processing

  • Withdraw consent for marketing at any time

  • Request data portability

To exercise any of these rights, please contact us at onlinelearning@thefireflygroup.co.uk.
We will respond to all valid requests within one month.

9. Cookies and Analytics

Our website uses cookies and analytics tools (including Google Analytics and Squarespace Analytics) to understand how users interact with the Library and improve performance.
Cookies are small files stored on your device. You can adjust your browser settings to disable cookies, though this may affect functionality.

We use the following types of cookies:

Essential cookies
These are necessary for the website to function and cannot be switched off in our systems. They include things like remembering your login details or keeping your session secure.

Performance and analytics cookies
These help us understand how visitors use our website - for example, which pages are most popular, how people navigate the site, and where they come from.
We use Google Analytics and Squarespace Analytics for this purpose.
All data is collected in an anonymised form and used only to improve the user experience.

Functional cookies
These allow the website to remember your preferences (such as language settings) and provide enhanced functionality.

Marketing and tracking cookies
We may use limited tracking cookies within Kajabi to understand how users engage with our course content, sign-up forms, or emails.
These help us measure performance and improve our communication, but we do not use cookies for third-party advertising or sell tracking data.

Third-Party Cookies

Some cookies are placed by third-party services that appear on our pages - such as Kajabi, Google, or Squarespace.
These providers may collect data in accordance with their own privacy policies.
We recommend reviewing the following for more information:

How to Manage Cookies

You can control or delete cookies at any time through your browser settings.
Most browsers allow you to:

  • Block all cookies

  • Delete existing cookies

  • Receive alerts before cookies are placed

Please note that disabling certain cookies may affect how the Library functions or limit some features (for example, keeping you logged in).

For detailed guidance, visit www.allaboutcookies.org.

Updates to This Policy

We may update this Cookie Policy occasionally to reflect changes in how we use cookies or due to legal requirements.
The latest version will always be available on this page.

10. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration.
All payment data is processed securely through trusted third-party providers, and we do not store your full payment information on our servers.

11. International Transfers

Some of our service providers (e.g. Kajabi) may store or process data outside the UK.
Where this occurs, we ensure that appropriate safeguards are in place - such as UK adequacy decisions or standard contractual clauses - to protect your information.

12. Updates to This Policy

We may update this Privacy Policy occasionally to reflect changes in our practices or legal requirements.
The latest version will always be available on this page, with the date of last update clearly shown.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact: onlinelearning@thefireflygroup.co.uk