How the CLCD app uses your information
Notice version 2026-09-27
Who is responsible
Invictus Leadership Ltd (company number 11086841), 13 Kingsway, Blakeney, Holt, England, NR25 7PL is the controller responsible for this diagnostic. Privacy questions and data requests can be sent to learning@invictusleadership.co.uk.
Information and purposes
- Email and name identify and support your diagnostic session. Role and organisation add context only if you choose to provide them.
- Your four screener answers produce your Accidental Leadership Screener result using a fixed decision mapping. After purchase or authorised client access, your 64 diagnostic answers and calculated scores create your complete leadership report.
- After access is authorised and you complete the diagnostic, your email address is used to send one operational report-ready message with the PDF and secure view/download links. This is separate from optional marketing.
- Stripe collects and processes payment details on its hosted Checkout page. We receive and retain limited transaction identifiers, your Checkout email, the amount and currency, status, and relevant timestamps; the app does not receive your full card number or security code.
- Calculated scores and derived leadership patterns are sent to OpenAI through its API to create the AI-assisted interpretation. Your name, email, telephone, role, organisation, and individual item answers are not included in that request.
- If an older session has not accepted the current AI disclosure, no AI request is made until you confirm it. We record the disclosure version and confirmation time for that session.
- Commercial-request events let Invictus Leadership respond when you ask for coaching or programme information.
- The screener has separate opt-out controls for processing and marketing. If you opt out of processing, your details and answers are not submitted and we cannot prepare or save your result. Marketing messages are included unless you tick the marketing opt-out; opting out of marketing does not affect your result or diagnostic.
Doctoral research
- Anonymised diagnostic data forms part of a doctoral research project between Invictus Leadership and St Mary's University.
- All names are redacted for anonymity. The research export contains no names, email addresses, phone numbers or organisations.
- Your anonymised results are included by default. You can opt out at the end of the diagnostic with a single checkbox, and opting out never affects your results, your report, or your access to them.
- You can also opt out later by contacting us, or by deleting your diagnostic from the results page.
- The four screener questions record your leadership transition and perceived competence at that time. Those answers are separate from your research participation choice.
- Your marketing choice remains separate and optional, and has no connection to research participation.
- The research data is processed by Invictus Leadership.
Lawful bases
- We rely on your permission to process the details and answers needed to provide this optional diagnostic, including sending derived scores and patterns to OpenAI for the AI-assisted interpretation. The screener explains this use before you request your result and lets you opt out of processing. You can later withdraw your permission by deleting the diagnostic or contacting us.
- We rely on legitimate interests to include your anonymised results in the doctoral research described above. That research data identifies nobody, its purpose is limited to understanding how leaders develop competence, and you can object at any time through the opt-out at the end of the diagnostic or by contacting us. We stop including your results when you do.
- When you choose to buy the diagnostic and complete report, processing the Checkout and delivering that purchase is necessary to perform that contract with you.
- We retain essential financial transaction records where necessary to meet accounting, tax, fraud-prevention, and other legal obligations.
- We rely on legitimate interests to keep the service secure, prevent abuse, maintain essential operational records, and respond to a report, coaching, or programme request you initiate. Those interests are limited to operating and supporting the service in ways you would reasonably expect.
- Marketing email is controlled by your separate marketing preference. You can opt out on the screener or contact us at any time to stop marketing email without affecting the diagnostic.
Service providers, transfers, and AI
Neon hosts the diagnostic database, Stripe processes the one-off payment on its hosted Checkout page, Resend delivers operational emails, and the OpenAI API creates the AI-assisted leadership interpretation. They process information under their applicable service and privacy terms and may use listed subprocessors.
The OpenAI request contains calculated domain and sub-competence scores and derived leadership patterns. It does not contain your name, contact details, role, organisation, or individual item answers.
OpenAI does not use API inputs or outputs to train its models by default. OpenAI may retain prompts and responses in abuse-monitoring logs for up to 30 days, unless it is legally required to retain them for longer.
These providers may process information in the United States and other jurisdictions. Where information is transferred outside the UK, provider contractual safeguards and recognised transfer mechanisms are used. Contact us if you would like more information about those safeguards.
The AI-assisted interpretation is reflective guidance based on a self-reported diagnostic. It does not make decisions about you and is not used for solely automated decisions with legal or similarly significant effects.
Browser storage and analytics
Your four screener answers are saved with your name and email when you request your result without opting out of processing. If you tick the processing opt-out, the form does not submit your details or answers. The app uses strictly necessary signed cookies to keep that result, your access and your diagnostic isolated. After purchase or authorised client access, a session-scoped diagnostic draft is stored in this browser so you can pause and resume. Clearing browser storage removes that draft. Secure report email links establish a separate read-only report cookie.
Vercel Web Analytics provides cookie-free statistics about visits, pages, referring sites and device categories. It uses a temporary identifier that changes daily rather than a persistent advertising identifier.
Our own cookie-free screener analytics records arrivals, which of the four questions is reached, whether an option is selected, whether you continue, and whether saving your result succeeds. Visits using our tagged Mailmeteor link are counted as Mailmeteor; other visits are unattributed. We do not save other link parameters or recipient identifiers. A random identifier exists only for the current form visit; it is not stored in browser storage or linked to your name, email, answers, result or diagnostic session. We retain these progress records for up to 30 days, with expired records removed by a daily job. Anonymous totals are publicly viewable on our analytics page.
If you accept analytics cookies, Google Analytics measures visits and diagnostic progress using cookies such as _ga, including before you provide an email address. Progress events record how many statements have been answered, which question group is displayed, whether the details step is reached and whether submission succeeds. Google's tag does not load before you accept. Advertising features and automatic form, search and download tracking are disabled. We send only these progress counts, reviewed page addresses with query parameters and fragments removed, and referring-site origins; we do not send your name, email, answers, scores or secure report tokens.
Your Google Analytics choice is stored in this browser for up to 180 days. You can change it using Analytics preferences in the footer. Declining or withdrawing this optional consent does not affect the diagnostic, your report or your research and marketing choices. Withdrawal stops further Google Analytics collection in this browser and removes accessible Google Analytics cookies.
Google and Vercel process analytics data under their applicable service and privacy terms and may process it outside the UK. See Google's privacy policy and Vercel's analytics privacy information.
Storage and retention
The screener result, diagnostic server record, generated report, secure report links, and browser draft have a default 365-day retention period. The protected retention job removes expired sessions, answers, reports, fulfilment receipts, and report-email jobs together.
Deleting a diagnostic removes its report content and invalidates its secure links. Minimal payment and reconciliation records are kept separately for applicable accounting, tax, fraud-prevention, dispute, and legal retention requirements.
OpenAI may retain the limited report request and response in abuse-monitoring logs for up to 30 days, unless longer retention is legally required. Operational email systems may retain delivery records under their own configured policies. We review retention rather than extending it automatically.
Your choices and rights
The results page lets you delete the current diagnostic and withdraw its contact consent. Withdrawal does not affect processing that was lawful before withdrawal or shorten a service provider's necessary security or legal retention.
Contact Invictus Leadership to request access, correction, deletion across other sessions, restriction, objection, portability, or marketing withdrawal. We may need to verify your identity before acting on a request.
You may also raise a concern with the UK Information Commissioner's Office.