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Privacy Policy for Any Guru Platform

Last Updated: April 2026

Any Guru Privacy Notice

This privacy notice explains how Upstream Outcomes Ltd collects, uses, stores and protects personal data in relation to Any Guru, our business coaching, guidance and support platform.

We are committed to handling personal information fairly, lawfully and transparently, in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

Data Controller: Upstream Outcomes Ltd
Platform: Any Guru
Address: Ergo, Bridgehead Business Park, Meadow Road, Hessle, HU13 0GD
Phone: +44 03455481654
Email: contact@any.guru

For the purposes of data protection law, Upstream Outcomes Ltd is the organisation responsible for deciding how your personal data is used in connection with Any Guru.

2. Our Commitment to Protecting Your Information

At Upstream Outcomes Ltd, we respect your privacy and are committed to keeping your personal data safe. We only collect and use personal information where we have a clear reason to do so, and we take appropriate technical and organisational measures to protect it.

This notice applies to personal data collected through:

  • the Any Guru platform;
  • related support services, onboarding and coaching activity;
  • our communications with you; and
  • any business support programmes delivered through the platform.

3. The Information We Collect

We may collect and process the following categories of personal data:

Personal and Business Information

  • name;
  • email address;
  • telephone number;
  • job title or role;
  • organisation or business name;
  • business sector, size and profile.

Account and Profile Information

  • login details;
  • account preferences;
  • questionnaire responses;
  • onboarding information;
  • topics, goals, challenges and interests you choose to share.

Platform Usage Information

  • pages viewed;
  • resources accessed or downloaded;
  • tools used;
  • session activity;
  • click, navigation and interaction data.

Coaching and Support Information

  • information you provide during support sessions;
  • coaching notes;
  • feedback;
  • session summaries;
  • action plans;
  • milestones and progress updates.

AI Interaction and Personalisation Data

  • prompts, inputs and responses submitted to AI-powered tools;
  • quiz and assessment responses;
  • preferences used to personalise content and support;
  • session history relevant to providing continuity of advice.

Technical Information

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • approximate location data derived from technical identifiers;
  • log and diagnostic data.

4. How We Collect Your Information

We collect personal data:

Directly from you

For example, when you:

  • create an account;
  • complete forms, quizzes or assessments;
  • use the platform;
  • engage with AI tools;
  • request support;
  • take part in coaching or advisory sessions;
  • contact us by email, telephone or through the platform.

Automatically

When you use the platform, we may automatically collect technical and usage data through logs, cookies or analytics tools.

From third parties

We may receive limited personal data from:

  • analytics providers;
  • delivery partners involved in a support programme;
  • advisers, coaches or Gurus recording outcomes from sessions;
  • organisations referring users into a programme, where appropriate and lawful.

5. Why We Use Your Information

We use personal data to:

  • create and manage your account;
  • provide access to Any Guru services, tools and content;
  • personalise your experience;
  • generate tailored business guidance, recommendations and action plans;
  • provide one-to-one or group coaching and support;
  • monitor progress against goals, milestones and activities;
  • improve the quality, relevance and effectiveness of the platform;
  • troubleshoot technical issues and maintain platform security;
  • communicate with you about service updates, support activity and relevant opportunities;
  • evaluate and develop our programmes and services;
  • comply with legal, regulatory and contractual obligations.

6. Our Lawful Bases for Processing

Under UK GDPR, we must have a lawful basis for processing your personal data. Depending on the activity, we rely on one or more of the following:

Contract

Where processing is necessary to provide you with access to the platform or deliver services you have requested.

Legitimate Interests

Where processing is necessary for our legitimate interests in operating, improving and securing Any Guru, delivering effective business support, understanding platform usage, and ensuring users receive relevant services, provided those interests are not overridden by your rights and freedoms. The ICO states legitimate interests is one of the UK GDPR lawful bases and is often appropriate where people would reasonably expect the processing and the privacy impact is limited.

Consent

Where you have given us clear consent to process your data for a specific purpose, such as certain optional personalisation features, marketing activity, or where consent is otherwise required. You can withdraw consent at any time, although this will not affect processing already carried out lawfully before withdrawal.

Legal Obligation

Where we need to process your data to comply with the law.

7. How We Use AI Within Any Guru

Any Guru includes AI-powered features that help provide tailored guidance, recommendations, summaries, prompts and support content.

We may use your inputs, interaction history, goals, preferences and related information to:

  • personalise support;
  • generate relevant suggestions and next steps;
  • improve continuity across sessions;
  • help our coaches and advisers understand the support you may need.

AI outputs are intended to support decision-making, not replace professional or specialist advice. While we aim for outputs to be helpful and relevant, AI can produce inaccurate, incomplete or out-of-date responses.

Unless specifically stated otherwise, we do not use your data to make solely automated decisions that produce legal effects or similarly significant effects about you. If that changes for a particular service, we will explain it clearly at the point of collection.

8. Who We Share Your Information With

We do not sell your personal data.

We may share personal data where necessary with:

  • authorised employees, coaches, advisers and Gurus within Upstream Outcomes Ltd;
  • trusted service providers and processors who support hosting, analytics, communications, security, customer support or AI functionality;
  • programme or delivery partners where this is necessary to provide a service and there is a lawful basis for doing so;
  • regulators, law enforcement bodies, courts or other authorities where required by law.

Where third parties process data on our behalf, we require them to do so securely and only in accordance with our instructions and applicable data protection law.

9. International Transfers

We aim to store and process personal data within the UK. However, some of our service providers may process data outside the UK.

Where personal data is transferred internationally, we will ensure appropriate safeguards are in place, such as:

  • adequacy regulations;
  • the UK International Data Transfer Agreement;
  • or other lawful transfer mechanisms.

10. How Long We Keep Your Information

We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, contractual and reporting requirements.

As a general approach, we may retain information for up to six years from the date of collection or the end of your relationship with us, unless:

  • a longer retention period is required by law or contract;
  • the data is still needed for an ongoing legitimate purpose;
  • you successfully request deletion and there is no overriding reason for us to keep it;
  • the data can be securely deleted earlier.

We may also retain anonymised or aggregated information for service improvement, reporting and analysis where it no longer identifies you.

11. How We Keep Your Information Secure

We use appropriate technical and organisational security measures to protect personal data, including measures designed to prevent unauthorised access, loss, misuse, alteration or disclosure.

These measures may include:

  • secure hosting environments;
  • access controls;
  • staff confidentiality obligations;
  • encryption and secure data transmission where appropriate;
  • monitoring and security testing;
  • secure third-party infrastructure.

12. Your Data Protection Rights

Under UK data protection law, you have a number of rights. These include:

  • Right to be informed about how your data is used;
  • Right of access to the personal data we hold about you;
  • Right to rectification of inaccurate or incomplete personal data;
  • Right to erasure in certain circumstances;
  • Right to restrict processing in certain circumstances;
  • Right to object to certain processing, including some processing based on legitimate interests;
  • Right to data portability in certain circumstances.

The ICO explains these rights under the UK GDPR, including that organisations generally have one calendar month to respond to a valid request.

You do not usually have to pay a fee to exercise your rights.

To make a rights request, contact us at: contact@any.guru

13. Cookies and Analytics

We may use cookies and similar technologies to:

  • keep the platform functioning properly;
  • understand how users engage with the platform;
  • improve performance and user experience;
  • support reporting and service development.

Where required, we will ask for your consent before using non-essential cookies.

14. Third-Party Services

Any Guru may use trusted third-party tools and services, including cloud hosting, analytics, communications and AI service providers.

These providers may process personal data on our behalf strictly for the purposes of delivering and improving the service. We ensure appropriate contractual and security arrangements are in place with such providers.

15. Changes to This Privacy Notice

We may update this privacy notice from time to time to reflect changes in our services, legal obligations or the way we process personal data.

When we make material changes, we will update the “Last Updated” date at the top of this notice and, where appropriate, take steps to bring the changes to your attention.

16. How to Contact Us

If you have any questions about this privacy notice or want to exercise any of your rights, please contact:

Upstream Outcomes Ltd
Ergo, Bridgehead Business Park, Meadow Road, Hessle, HU13 0GD
Phone: +44 03455481654
Email: contact@any.guru

17. How to Complain

If you are unhappy with how we have used your personal data, you can complain to the Information Commissioner’s Office (ICO).

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113

You can also find further guidance on the ICO website.