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july 3rd, 2025

Privacy Policy

1. Who we are

Co:definery is the trading name of Bonn Consulting Ltd (“Co:definery”, “we”, “us” or “our”). Bonn Consulting Ltd is the controller of the personal information described in this privacy policy.

Our contact details are:

  • Bonn Consulting Ltd, 83 Whalley Drive, Bletchley, MK3 6HX, United Kingdom
  • Email: hello@codefinery.com 

We are registered with the UK Information Commissioner’s Office (“ICO”).

This policy explains how we collect and use personal information when you visit our website, contact us, subscribe to our newsletter, download or use our resources and assessments, become a client, take part in a recorded call, provide a testimonial, or otherwise interact with us.

2. Personal information we collect

Depending on how you interact with us, we may collect:

  • Identity and contact information, including your name, job title, organisation, postal address, email address, telephone number and professional profile information.
  • Enquiry and relationship information, including the subject of an enquiry, proposed podcast or discussion topic, correspondence, meeting notes, proposals, contracts and information about our relationship with you or your organisation.
  • Newsletter and marketing information, including your subscription status, communication preferences and information about how you interact with our emails.
  • Assessment and resource information, including information you submit to obtain our Business Case Calculator report or complete a ScoreApp business assessment, together with the resulting score and recommendations.
  • Client and project information, including information contained in project documents, emails, workshop materials, Miro boards, research, recommendations and other materials used to deliver our services.
  • Call information, including audio recordings, transcripts, summaries, speaker information and action points from calls or meetings recorded using services such as Otter, Google Meet or Plaud. We tell participants before recording begins.
  • Testimonial information, including your name, photograph, role, organisation and testimonial.
  • Financial information, including billing contacts, invoices, payment records and accounting information. We do not normally receive complete payment-card details.
  • Website and technical information, including your IP address, browser, device, operating system, pages visited, referring website and information collected through cookies and similar technologies.
  • Information from public and professional sources, including professional information obtained from LinkedIn, company websites, business directories and other publicly available sources.

We do not intentionally ask you to provide special-category information, such as information about your health, ethnicity, political opinions, religion, trade-union membership or sexual orientation. Please avoid including such information in free-text forms, assessment responses, recordings or project materials unless it is relevant and we have agreed that it is appropriate to do so.

3. How we obtain personal information

We obtain personal information:

  • directly from you, including through website forms, emails, calls, meetings, assessments, newsletter subscriptions and client engagements;
  • from your organisation or another person who introduces or refers you;
  • from LinkedIn, networking events, conferences, company websites, professional directories and other public sources;
  • from reputable business-information or contact-data providers; and
  • automatically when you use our website, subject to your cookie choices.

If we obtain your information from another source and use it to contact you, we will provide or direct you to appropriate privacy information as required by law.

4. How and why we use personal information

UK data protection law requires us to have a lawful basis for using personal information. Our principal purposes and lawful bases are set out below.

PurposeInformation typically usedLawful basis
Responding to enquiries and discussing potential workIdentity, contact and enquiry informationOur legitimate interests in responding to enquiries and developing our business; steps requested before entering into a contract
Providing consultancy and other agreed servicesIdentity, contact, client, project, meeting and financial informationPerformance of a contract; our legitimate interests in managing and delivering business-to-business services
Managing client and supplier relationshipsContact, correspondence, contractual, project and financial informationPerformance of a contract; our legitimate interests in operating and administering our business
Sending the Believe in Better newsletterIdentity, contact, subscription and engagement informationConsent where required; otherwise our legitimate interests where applicable and permitted by electronic-marketing law
Sending relevant business-to-business marketingProfessional contact, source, relationship and preference informationOur legitimate interests in promoting our services, subject to your rights and applicable electronic-marketing rules
Providing reports, resources and business assessmentsIdentity, contact, response, score and recommendation informationPerformance of the service you request; our legitimate interests in providing and improving our resources and developing relevant business relationships
Recording and transcribing callsAudio, transcript, meeting and participant informationOur legitimate interests in maintaining accurate records, capturing agreed actions and delivering our services; performance of a contract where relevant. We notify participants before recording
Publishing testimonialsName, photograph, role, organisation and quotationConsent
Operating, securing and improving our website and systemsTechnical, usage and security informationOur legitimate interests in operating, protecting and improving our services; consent where required for cookies or similar technologies
Accounting, taxation and legal complianceContact, contractual, transaction and financial informationCompliance with legal obligations; our legitimate interests in managing claims and protecting our legal rights

Where we rely on legitimate interests, we consider whether our interests are necessary and proportionate and balance them against your interests, rights and reasonable expectations.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that took place before consent was withdrawn.

5. Newsletter and marketing

If you subscribe to Believe in Better, we use the details you provide to send the newsletter and related communications. You can unsubscribe at any time using the link in any marketing email or by contacting us.

We may also contact relevant business professionals about our services where this is permitted by law. We may use professional contact information obtained through an existing relationship, a referral, an event, LinkedIn, a public business source or a reputable data provider. We take account of whether the communication is likely to be relevant and reasonably expected.

We do not send further marketing to anyone who has asked us to stop. We may retain a minimal suppression record so that we can respect that request in the future.

6. Assessments and automated scoring

Our online business assessment, provided through ScoreApp, collects your contact details and answers, calculates a score and generates recommendations.

The score is intended to provide general business insight. It is not used to make a solely automated decision that produces legal or similarly significant effects concerning you. If we use the result to inform a conversation or marketing follow-up, you may object to that use by contacting us.

7. Call recording and transcription

We use specialist call-recording, transcription and AI-summary providers to record, transcribe and summarise telephone or video calls. These currently include Otter, Google Meet and Plaud, but we may use comparable providers from time to time. We tell participants before recording begins. We use recordings and transcripts to create an accurate record of discussions, recommendations, decisions and actions and, where applicable, to deliver client work.

If you do not want a call to be recorded, please tell us before or at the start of the call so that we can consider a suitable alternative.

These services use artificial intelligence to produce transcripts and summaries. They may process information outside the United Kingdom as described in section 11.

8. Testimonials

With your consent, we may publish a testimonial containing your name, photograph, role, organisation and quotation. You may withdraw your consent by contacting us. We will then stop using the testimonial within a reasonable period, although we may not be able to retrieve material already printed or independently republished by others.

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9. Cookies and website analytics

Our website is hosted using Webflow. We use Google Analytics to understand how visitors use the website and to help us improve it. Google Analytics is optional and will not be activated until you provide consent through our cookie settings.

Our website may also use essential technologies needed for security, network management, remembering your cookie choices and providing features you request. These do not require consent where they are strictly necessary.

Podcast content is embedded using Captivate. When you use an embedded player, Captivate may receive technical information such as your IP address, device information and information about playback. Where its technologies are not strictly necessary to provide content you have requested, they will be managed in accordance with your cookie choices.

You can accept or reject optional technologies and change your choice at any time using the Preferences link on our website. Further details, including the technologies used and how long they operate, are available in our cookie notice.

10. Who we share personal information with

We share personal information only where reasonably necessary for the purposes described in this policy. Recipients may include:

  • website, hosting, content-delivery, security and analytics providers, including Webflow and Google;
  • customer-relationship, newsletter and marketing providers, including HubSpot and Mailchimp;
  • form, assessment and resource providers, including Typeform and ScoreApp;
  • productivity, email, document-storage and collaboration providers, including Google Workspace and Miro;
  • call-recording, transcription and AI-summary service providers, currently including Otter, Google Meet and Plaud;
  • podcast hosting and embedded-player providers, including Captivate;
  • accounting and financial-administration providers, including Xero;
  • professional advisers, including accountants, lawyers and insurers;
  • suppliers and contractors who assist us in delivering our services;
  • regulators, courts, law-enforcement agencies and public authorities where disclosure is legally required or necessary to protect legal rights; and
  • a prospective purchaser, investor or adviser in connection with a proposed sale, restructuring or investment in our business.

Our providers may use their own subprocessors. We require processors handling personal information on our behalf to protect it and use it only in accordance with their contractual obligations and our instructions, except where the law permits or requires otherwise.

We do not sell personal information.

11. International transfers

Some of our providers and their subprocessors are based outside the United Kingdom or access information from other countries. These may include countries in the European Economic Area, the United States, Australia and New Zealand.

Where UK law requires safeguards for an international transfer, we use an appropriate legal mechanism. Depending on the destination and recipient, this may include:

  • UK adequacy regulations;
  • the UK Extension to the EU–US Data Privacy Framework, where the recipient is appropriately certified;
  • the UK International Data Transfer Agreement;
  • the UK Addendum to the European Commission’s Standard Contractual Clauses; or
  • another transfer mechanism permitted by applicable data protection law.

You may contact us if you would like further information about the safeguards relevant to your personal information.

12. How long we keep personal information

We retain personal information only for as long as reasonably necessary for the relevant purpose, including legal, regulatory, accounting and reporting requirements. Our usual periods are:

RecordUsual retention period
Unsuccessful or inactive enquiriesTwo years after the last meaningful contact
Prospect and business-development recordsThree years after the last meaningful contact, subject to periodic review
Client project and contractual recordsSix years after the relevant project or client relationship ends
Invoices, accounts and tax recordsSix years after the relevant financial year
Newsletter subscriber informationUntil you unsubscribe, withdraw consent or the newsletter ends
Marketing suppression recordAs long as needed to ensure that we continue to respect your objection, limited to the minimum necessary information
Business Case Calculator and similar resource requestsTwo years after the request or last meaningful contact
Call recordings, transcripts and summariesThree years from the recording, unless earlier deletion is appropriate or a longer period is required in connection with an active matter or legal claim
TestimonialsUntil consent is withdrawn or the testimonial is no longer used
Website technical and security recordsFor a limited period determined by operational and security requirements, normally no longer than 12 months unless an incident requires longer retention

We may retain information for longer where required by law or where reasonably necessary to establish, exercise or defend legal claims. Where appropriate, we delete or anonymise information instead of continuing to retain it in identifiable form.

13. Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration or disclosure. These include access controls, account security, appropriate supplier arrangements and the security features provided by our technology platforms.

No internet or storage system can be guaranteed to be completely secure. If you believe information you have provided to us may have been compromised, please contact us promptly.

14. Your rights

Depending on the circumstances and the law that applies, you may have the right to:

  • ask for confirmation that we process your personal information and obtain a copy;
  • ask us to correct inaccurate or incomplete information;
  • ask us to delete your information;
  • ask us to restrict how we use your information;
  • object to processing based on legitimate interests;
  • object at any time to the use of your information for direct marketing;
  • receive certain information in a structured, commonly used and machine-readable format, or ask us to transfer it to another organisation;
  • withdraw consent where we rely on consent; and
  • challenge a decision based solely on automated processing where it has legal or similarly significant effects.

These rights are not absolute, and exemptions may apply. We may need to request information to verify your identity before responding. We will normally respond within one month, subject to any extension permitted by law.

To exercise your rights, email hello@codefinery.com.

15. Complaints

Please contact us first if you have a concern about our use of your personal information. We will try to resolve it.

You also have the right to complain to the Information Commissioner’s Office:

  • Website: ico.org.uk/make-a-complaint
  • Telephone: 0303 123 1113

If you are located in the European Economic Area or another jurisdiction whose data protection law applies, you may also be entitled to complain to the relevant local data protection authority.

16. Information about other people

If you provide personal information about another person, you should ensure that you are permitted to do so and, where appropriate, make this policy available to them.

17. Children

Our website and services are intended for business professionals and are not directed at children. We do not knowingly collect personal information from children through the website. If you believe a child has provided information to us, please contact us.

18. Links to other websites

Our website may link to websites operated by other organisations. Those organisations are responsible for their own privacy practices, and we encourage you to read their privacy information.

19. Changes to this policy

We may update this policy to reflect changes to our services, suppliers or legal obligations. We will publish the updated version on this page and change the “Last updated” date. Where a change has a material effect on how we use personal information, we will take reasonable steps to bring it to the attention of affected individuals.

20. Contact us

Questions, requests and concerns about this policy or our use of personal information should be sent to:

Bonn Consulting Ltd, trading as Co:definery
83 Whalley Drive
Bletchley
MK3 6HX
United Kingdom

Email: hello@codefinery.com 

Specialists in positioning and business transformation for marketing services companies.
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