Effective date: 01 July 2026
Trewly Ltd ("Trewly", "we", "us" or "our") provides a leadership development platform designed to help organisations strengthen leadership capability, improve team experience and support learning and development.
This Privacy Policy explains how we collect, use, share and protect personal information when you:
- visit the Trewly website;
- contact us or enquire about our services;
- register for or use the Trewly platform;
- take part in a trial, pilot, demonstration or learning programme; or
- use Trewly through your employer or another organisation.
It also explains your rights under applicable data protection law, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.
1. Who we are
Trewly Ltd is a company registered in England and Wales.
Company name: Trewly Ltd
Company number: 17177377
Email: support@trewly.co.uk
When Trewly is the data controller
Trewly is normally the data controller for personal information that we collect and use for our own purposes, including information collected through our public website, enquiries and sales communications, management of our customer relationships, billing and subscription administration, operation, security and improvement of our business and services, and direct accounts purchased or managed by an individual user.
When Trewly is a data processor
Where an employer, business or other organisation provides access to Trewly for its employees, workers or team members, that organisation will normally be the data controller for the information processed through its account. Trewly will generally act as a data processor on the organisation's instructions.
If you use Trewly through your employer or another organisation, you should also read that organisation's employee or workforce privacy notice.
2. Personal information we collect
The information we collect depends on how you interact with Trewly and which parts of the platform your organisation has chosen to use.
2.1 Information you provide directly
We may collect identity and contact information (name, work email address, telephone number, job title, employer or organisation, team or department, profile information), account information (username, password, account role and permissions, login activity), learning and development information (course enrolment and completion, knowledge-check responses, learning-path progress, leadership reflections, development goals, coaching feedback), team experience and feedback information (team pulse responses, workplace experience ratings, feedback relating to leadership and team experience, manager responses and action plans), coaching and support communications, and commercial and billing information.
2.2 Information provided by your organisation
Where you use Trewly through an employer or other organisation, it may provide us with information needed to establish and administer your account, such as your name and work email address, job title and role, team or department, manager or reporting relationship, platform access permissions, assigned learning content, and account status.
2.3 Information collected automatically
When you use our website or platform, we may automatically collect IP address, browser and device type, operating system, date and time of access, pages or platform areas viewed, login and session information, features used, error reports, security logs, referring website, and cookie or similar technology identifiers.
2.4 Information from integrations
Where an organisation enables an integration, or where you choose to connect another service, we may receive information from identity and single sign-on providers, learning or human-resources systems, calendar services, and other workplace software.
3. Sensitive information
Trewly is not designed to collect medical information or other special category personal data as part of its standard operation. However, free-text fields, coaching messages or user reflections may contain information that reveals matters such as physical or mental health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, sexual orientation, or other sensitive personal circumstances.
Please avoid including sensitive personal information unless it is relevant and appropriate for the particular activity.
4. How we use personal information
We may use personal information to provide and administer Trewly (create and manage accounts, authenticate users, provide learning and coaching features, record course progress, generate reports, deliver customer support, manage subscriptions), provide leadership and team insights (calculate scores or progress indicators, identify themes for development, recommend relevant learning content), operate and improve our service (monitor technical performance, identify and resolve errors, understand how platform features are used, improve usability, develop new features, protect accounts), communicate with you (account and service messages, security notifications, support responses, marketing communications where permitted by law), and meet our legal and business obligations.
5. AI-assisted insights and automated processing
Trewly may use automated rules, analytics or artificial intelligence to help produce summaries, learning recommendations, knowledge insights, leadership-development suggestions, team-level themes, suggested actions, and notifications or reminders. These outputs are intended to support learning, reflection and informed human decision-making.
Trewly does not use the platform to make solely automated decisions about an individual that produce legal effects or similarly significant effects. Customers must not use Trewly-generated information as the sole basis for significant employment decisions.
6. Our lawful bases for processing
Under UK data protection law, we must have a lawful basis for using personal information. Depending on the circumstances, we rely on: Contract (where necessary to provide services purchased or requested), Legitimate interests (operating and improving Trewly, supporting customer relationships, securing the platform, preventing fraud, understanding service performance, developing our products), Legal obligation (to comply with legal or regulatory requirements), and Consent (for non-essential cookies, certain electronic marketing, or optional integrations).
7. Who can see information within Trewly
The information accessible to another user depends on their platform role, the feature being used, the organisation's account structure, its permissions and configuration, and the purpose for which the information was collected. Authorised recipients may include the individual user, their manager, an assigned coach, designated company administrators, authorised Trewly personnel, and other people expressly authorised by the customer organisation.
8. How we share personal information
We do not sell personal information. We may share information with customer organisations (where you use Trewly through an employer), service providers and subprocessors (cloud hosting, authentication, email and communications, payment processing, analytics, security monitoring, AI functionality), professional advisers (accountants, auditors, insurers, lawyers), legal and regulatory recipients (where required by law), and in connection with business transactions (investment, merger, acquisition or sale).
9. International data transfers
Some of our service providers may store or access personal information outside the United Kingdom. Where personal information is transferred to a country not covered by UK adequacy regulations, we use an appropriate lawful safeguard, which may include the UK International Data Transfer Agreement, the UK Addendum to the European Commission's Standard Contractual Clauses, another approved transfer mechanism, or an applicable legal exception.
10. Cookies and similar technologies
Our website and platform may use cookies and similar technologies, including strictly necessary technologies (required for account login, authentication, security, session management and core operation), preference technologies (remembering account or display preferences), analytics technologies (understanding how people use our website or platform), and marketing technologies (where used, to measure marketing activity or provide more relevant advertising).
We will request consent before placing non-essential cookies where required by law. You can manage your choices through our cookie banner or cookie settings tool.
11. Marketing
We may use business contact information to communicate with existing and prospective customers about Trewly's services. We will only send electronic marketing where permitted under applicable data protection and electronic communications law. You can opt out at any time by using the unsubscribe link in a marketing email or by contacting us at support@trewly.co.uk.
12. Data retention
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including to meet legal, accounting, security and contractual requirements. The relevant period depends on the type and sensitivity of the information, the purpose for which it is used, the terms of the customer agreement, the duration of the account or subscription, and applicable legal requirements.
13. Data security
We use appropriate technical and organisational measures designed to protect personal information from unauthorised access, accidental loss, destruction, alteration, inappropriate disclosure, and other unlawful processing. These measures may include encryption in transit, authentication and access controls, role-based permissions, secure hosting, logging and monitoring, data minimisation, supplier due diligence, backup and recovery arrangements, and regular review of security measures.
No online service can guarantee complete security. Users are responsible for keeping their login details confidential.
14. Your data protection rights
Depending on the circumstances and applicable law, you may have the right to request confirmation that your personal information is being processed, obtain a copy of your personal information, ask us to correct inaccurate or incomplete information, ask us to delete your information, ask us to restrict the use of your information, object to processing based on legitimate interests, object to direct marketing, receive certain information in a portable format, withdraw consent where processing is based on consent, and ask for human intervention in relation to certain automated decisions.
These rights are not absolute and may be subject to legal exemptions. To exercise your rights, contact: support@trewly.co.uk
15. Complaints
Please contact us first at support@trewly.co.uk. You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator for data protection: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.
16. Children's privacy
Trewly is intended for workplace and professional development use and is not intended for children. Individuals under the age of 16 should not create an account or submit personal information to Trewly unless their use has been expressly agreed and lawfully arranged by an authorised organisation.
17. Third-party websites and services
Our website or platform may contain links to third-party websites, resources or services. Those third parties operate under their own privacy policies and terms. Trewly is not responsible for the privacy or security practices of third-party services that we do not control.
18. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our services, changes to our data-processing activities, legal or regulatory developments, or improvements to the information we provide. We will publish the updated Policy with a revised effective date.
19. Contact us
Questions, requests or concerns about this Privacy Policy or Trewly's use of personal information may be sent to:
Trewly Ltd 17177377
Email: support@trewly.co.uk
