Privacy Policy
Last updated 12 March 2026.
1. Introduction
We are Adrian Lago trading as The Pack Language Experience of 15/17 Rossie Place, Edinburgh, EH7 5SE (we, us or our). We are the controller responsible for your personal data and we are responsible for this website.
We comply with our obligations under the Data Protection Act 2018 and the EU law retained version of the General Data Protection Regulation ((EU) (2016/679) (UK GDPR) (data protection laws). If any of these laws are replaced or superseded, we will also comply with those.
We are registered with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, and our registration reference is ZC101956. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. You also have the right to make a complaint at any time to the ICO. For data protection matters, please email us at info@thepacklanguageexperience.com.
We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data, such as when you:
- visit our website at https://thepacklanguageexperience.com/,
- contact us with any enquiry by post, email, social media, or phone,
- engage us for our training, coaching, events or related services,
- sign up for newsletters, mailing lists or updates, or
- when you otherwise engage with us.
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2. The data we may collect about you
Personal data/information means any information about an individual from which that person can be identified. It does not include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes your full name, marital status, title, date of birth, gender, and details contained in your passport (such as passport number, country of issue and expiry date), where required in connection with booking accommodation, travel or activities.
- Contact Data includes home address, billing address, email address and telephone number.
- Financial Data includes bank account and payment card details, applicable when issuing refunds.
- Transaction Data includes details about payments to and from you and other details of the services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, time of access, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Aggregated Data such as statistical or demographic data for any purpose, is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
- Special Category Data means special categories of personal data and includes information about your health, race or ethnicity, criminal convictions, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data.
We do not intentionally collect or process Special Category Data as part of our standard business activities. However, where you book onto one of our trips or retreats, we may request limited information relating to your health, disabilities, mobility requirements and allergies. This information is necessary to assess suitability, make reasonable adjustments, and help ensure your safety and wellbeing during the trip. Any such information is handled with appropriate care and in accordance with applicable data protection laws.
3. How is your personal data collected?
We may use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, and Contact Data by filling in forms, by corresponding or engaging with us by post, phone, email, social media or otherwise, including when you register for events, retreats, training sessions, coaching programmes or mailing lists.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies including third-party website tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Public sources. We may collect personal data about you from public sources, such as Google, Companies House, or the electoral register.
4. How we use your personal data
We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:
- Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Legal Obligation: Where we need to comply with a legal obligation.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or you provide us with information about your health, disabilities, mobility requirements and allergies before booking a trip.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To enable you to submit an enquiry to us, whether via email, through our website or via social media, including but not limited to LinkedIn, Facebook and Instagram | Identity
Contact |
Contract – to deliver the services you have signed up to and respond to your enquiries.
Legal Obligation – we must provide certain updates under consumer-protection and data protection laws. Legitimate Interests – to keep our records accurate, improve customer service and demonstrate compliance if challenged. |
| To enable our provision of services to you | Identity
Contact Transaction Financial Special Category |
Contract – to provide the services to you.
|
| To document our trips, retreats, training sessions and events, including by taking photographs and short video clips, and (where you have provided consent) to use such images or footage for promotional and marketing purposes on our website, social media platforms and other marketing materials | Identity Marketing and Communications |
Legitimate Interests – to document our activities and promote our services.
Consent – where we use identifiable images or footage of you for promotional or marketing purposes. |
| To manage our relationship with you which will include (a) notifying you about changes to our terms and conditions or this privacy and cookie policy (b) dealing with your requests, complaints, and queries | Identity
Contact Profile Marketing and Communications |
Contract – necessary to provide the services you have signed up to and respond to your enquiries.
Legal Obligation – we must issue certain updates under consumer protection and data protection laws. Legitimate Interests – to keep our records accurate, improve customer service and demonstrate compliance if challenged. |
| To enable you to register for our mailing list/email marketing | Identity
Contact Marketing and Communications |
Consent – you actively opt in via the sign-up form or cookie banner.
Contract – if you request the newsletter. Legitimate Interests – to promote relevant products and measure the success of our campaigns where the soft-opt-in applies (existing customers who have not opted out). Legal Obligation – to maintain a suppression list of people who have opted out. |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity
Contact Technical |
Legitimate Interests – to run our business efficiently, ensure IT security, prevent fraud and support any corporate reorganisation.
Legal Obligation – to comply with statutory data-security duties and cooperate with lawful requests from regulators or law-enforcement. |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity
Contact Profile Usage Marketing and Communications Technical |
Legitimate Interests – to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy. |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | Technical
Usage |
Legitimate Interests – to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy. |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity
Contact Technical Usage Profile Marketing and Communications |
Legitimate Interests (to develop our products/services and grow our business) |
6. Direct marketing
You will receive marketing communications from us if you have opted in (or, where legally permitted, if you have previously purchased from us and have not opted out). Where we rely on your consent to use photographs or video footage of you for promotional purposes, you may withdraw that consent at any time by contacting us at info@thepacklanguageexperience.com.
We may also analyse your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
7. Third party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
8. Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at info@thepacklanguageexperience.com.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our terms and conditions and checking that your contact details are correct.
9. Cookies
Our website uses third-party website tracking technologies to gather cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and to display advertisements according to your interests, and also allows us to improve our website services.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Some emails and pages contain a tiny graphic file that lets us see when you open a message or visit a page. Web beacons work together with cookies; if you disable cookies, they may stop working.
We display a cookie banner the first time you visit, allowing you to accept or reject non-essential cookies.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
When you first visit, a cookie banner lets you accept, reject or customise non-essential cookies. You can change your choices at any time by clicking “Cookie Settings” in the website footer. Most browsers also let you block or delete cookies through their settings; see allaboutcookies.org for instructions.
10. Disclosures of your personal data
We may disclose your information in the following cases:
- We can disclose your personal data to our employees, workers, and subcontractors in order to facilitate the provision of services to you.
- Where you book onto one of our trips, retreats or events, we may share relevant personal data with third-party accommodation providers (such as hotels) and activity providers in order to arrange your booking and ensure your participation. This may include your full name and, where required by the accommodation provider or local regulations, passport details prior to check-in. We may also share participant names with activity providers where required for booking or safety purposes.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights.
- We can exchange information with others to protect against fraud or credit risks.
We use a variety of third party services (sub-processors) as part of our business activities and you/we will therefore share your personal data with these sub-processors. The types of sub-processors we might use fall into different categories, as follows:
- Payment processing services;
- Order fulfilment service providers;
- Analytics service providers;
- Event/campaign management service providers;
- Website management service providers;
- Information technology and related infrastructure provision;
- Email delivery services;
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
11. Data security
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In particular, we use the following measures:
-storing data on secure platforms
-password protected accounts.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.
12. International transfers
We may transfer your personal data outside of the UK or the EEA where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
13. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
14. Your legal rights
You have several rights under data protection laws in relation to your personal data. Your rights include the following:
- Request access to your personal data (commonly known as a „subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in section 9 for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 5 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us at info@thepacklanguageexperience.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
15. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
16. Changes to this privacy and cookie policy and your duty to inform us of changes.
We keep our privacy and cookie policy under regular review. This version was last updated on the date at the header of this policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.