Privacy Policy - Consultancy

The Thinking Luxury LTD | Trading as Carlo Rappa

1. OVERVIEW

The Thinking Luxury LTD (“we”, “us”, or “our”) provides elite business consultancy, executive training, and strategic mentorship. In the course of these professional engagements, the protection of your personal data and the confidentiality of your business strategies are our highest priorities.

This policy details our commitment to the UK General Data Protection Regulation (UK GDPR) and explains how we handle your information with the discretion expected in the luxury consultancy sector.

2. DATA WE COLLECT

We collect only the information necessary to deliver high-impact consultancy and training:

Identity Data: Full name and professional title.
Contact Data: Professional or personal email address, phone number, and business billing address.
Professional Context: Information regarding your business structure, goals, and challenges shared during mentorship or training sessions.
Financial Data: Bank details or payment information for the settlement of professional fees (processed via secure, encrypted channels).
Engagement Data: Records of your participation in our workshops, training modules, and consultancy sessions.

3. PURPOSE OF PROCESSING

We utilize your data for the following professional purposes:

Service Delivery: To fulfill our obligations under your Statement of Work (SOW) or Consultancy Agreement.
Bespoke Mentorship: To tailor our training and advice specifically to your business needs and history.
Professional Communication: To provide updates on project milestones and respond to strategic inquiries.
Legal Compliance: To meet our statutory obligations for UK tax reporting and accounting.

4. CONFIDENTIALITY & DATA SHARING

As a boutique consultancy, we do not sell or trade your data. Sharing is strictly limited to:

Strategic Subcontractors: On occasion, we may engage specialist partners (e.g., Marketing, Art, Real Estate specialists) to assist in your project. These partners are bound by strict Non-Disclosure Agreements (NDAs) and our Subcontractor Data Processing Agreement.
Professional Requirements: Disclosure only when required by law or to protect our legal rights.

5. THE "AI SILO" PROTECTION

Unique to The Thinking Luxury LTD, we guarantee that your private business data, strategic insights, and project outputs are never utilised to train or "feed" public Generative AI models. All consultancy and mentorship data is processed within a secure, private environment to ensure your competitive advantage is never compromised.

6. DATA SECURITY & RETENTION

We employ robust technical and organisational measures to safeguard your data against unauthorised access. We retain your data only for as long as is necessary to fulfill our professional and legal obligations. As per our Terms of Business, confidentiality regarding your strategic insights survives for three (3) years following the conclusion of our mentorship.