Start With Who: Privacy Policy

Effective Date: Jan 01, 2026


Start With Who (“we,” “us,” or “our”) respects the privacy of individuals and organizations who use our platform. This Privacy Policy explains how we collect, use, store, and protect personal data when providing our services directly or on behalf of our organizational partners.

 

1. Our Role: Controller vs Processor

 When individuals use Start With Who directly, we act as a Data Controller for their personal data.

When Start With Who is provided through an organization or partner, we typically act as a Data Processor, processing personal data only on behalf of and under the instructions of that organization (the Data Controller).

In all cases, we process personal data in accordance with applicable data protection laws, including UK GDPR.

 

2. Information We Collect

We collect only the information necessary to provide our services, which may include:

  • Account information: Name, email address, role, organizational affiliation

  • Assessment data: Responses, results, synthesized themes, insights, outputs

  • Life history & narrative inputs: Experiences, reflections, contextual information

  • Third-party feedback: Information provided by others at the user’s request

  • User-generated content: Notes, DNA markers, descriptions, related inputs

  • Discussion & forum contributions: Posts, comments, replies

  • Support & feedback data: Bug reports, device type, browser information, optional screenshots.

We do not intentionally collect special category data unless users voluntarily choose to provide it.

 

3. Lawful Basis for Processing

 We process personal data based on:

  • Performance of a contract

  • Consent where explicitly given

  • Legitimate interests (security, improvement)

  • Legal obligations

 

4. How We Use Your Information

 We use personal data to:

  • Provide and maintain the platform

  • Generate insights using AI-assisted processing

  • Improve performance and user experience

  • Communicate service updates

  • Provide support

  • Maintain platform security

AI Use:

Personal data is not used to train public or third-party AI models and is not shared for AI training purposes.

Community Features

Forum contributions may be visible to cohort members, facilitators, and administrators. Please be mindful of what you share.

Communications

We may send account notifications, cohort updates, discussion replies, and security alerts. Notification preferences can be managed where available.

 

5. Data Sharing and Third Parties

 We do not sell, rent, or trade personal data. We work with trusted service providers for:

  • Authentication and identity management

  • Cloud hosting and infrastructure

  • Email delivery

  • Integrated assessment platforms

These providers are bound by confidentiality and data protection obligations.

Course administrators may access participant progress, program-related surveys, and metrics necessary to deliver and evaluate the programs. They cannot access any participant-entered personal content used to gather clues in any course or program, such as personal reflections, life stories, or individual assessment results.  

6. International Data Transfers 

Personal data may be processed outside the UK or EEA with appropriate safeguards consistent with UK GDPR.

 

7. Data Retention and Deletion 

We retain data only as long as necessary for service delivery, contractual obligations, or legal requirements.

Users or organizations may request deletion. Data will be deleted or anonymized unless retention is legally required.

 

8. Your Data Protection Rights

You have the right to:

  • Access your data

  • Correct inaccurate data

  • Request deletion

  • Restrict or object to processing

  • Request data portability

  • Withdraw consent


Requests may be routed through your organization or by reaching out to us directly, where applicable.

 

9. Cookies and Similar Technologies

We use essential cookies to maintain authentication, preferences, and security.

We do not use cookies for third-party advertising.

 

10. Changes to This Policy

 
We may update this policy periodically. Changes will be posted with a revised effective date.

 

11. Contact Us

 If you have unresolved questions or concerns about how your personal data is handled, please contact us using the details below. 

privacy@newtoninstitute.com

If you are located in the UK and believe your concerns have not been addressed, you also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).