Thrive 8 Privacy Notice
Who we are
IntogreatLtd (Intogreat, we, us, our) provides the Thrive 8 Index assessment and related learning and development services. We are registered in England and Wales (company number 13734084) and have our registered office at Suite 6a 10 Duke Street, Liverpool, England, L1 5AS.
This Privacy Notice explains how we use personal information about individuals who complete the Thrive 8 Index assessment, receive an individual report, access our learning platform, or take part in related learning and development activities.
Intogreat Ltd is the owner of the Thrive 8 Index® assessment methodology and related intellectual property.
Depending on how the Thrive 8 Index is delivered, your employer or sponsoring organisation may also be a separate controller of certain personal information relating to your participation in the programme. Your employer or sponsoring organisation will provide its own privacy information explaining how it uses personal information for its employment, organisational development and human resources purposes.
Effective: September 2026
1. Contact details
Address: Suite 6a 10 Duke Street, Liverpool, England, L1 5AS.
Email: hello@intogreat.net
Telephone:+44 (0) 7597 487 220
intogreatLtd is registered with the Information Commissioner’s Office (registration number available on request). You can also contact the InformationCommissioner’s Office at www.ico.org.uk.
2. Our role under data protection law
For the personal information collected through the Thrive 8 Index assessment platform, Intogreat generally acts as a data controller because we determine how assessment responses are collected, analysed, scored and reported. In some customised or white-labelled situations, we may instead process specified information on the sponsoring organisation’s documented instructions. We will explain any materially different arrangement before collecting your information.
The organisation that invites you to participate may also act as a separate controller in relation to information it holds about you, including information relating to your employment, participation in organisational programmes and receipt of aggregated organisational reporting.
In certain programme arrangements, including customised, white-labelled or hybrid programmes, Intogreat and the sponsoring organisation may each have separate responsibilities under data protection law. Where this is relevant, the information provided to you before you take part will identify the relevant organisation, explain their respective role and state who will receive your Individual Report.
Your employer or the organisation that invited you to participate is also likely to be a separate data controller for information it holds about you and for its use of aggregated reports. Your employer should provide its own privacy information about how it uses personal information in an employment or workplace context.
Because participants may complete the Thrive 8 Index, or receive training and debriefs, from a range of countries, other data protection laws (for example, the EUGDPR) may also apply to some of our processing in addition to UK data protection law. Where this is the case, we will comply with the applicable requirements of those laws as well as this Privacy Notice.
3. What the Thrive 8 Index is
The Thrive 8 Index is an assessment tool designed to help you understand how you are doing across 8 science-led factors and 28 sub-factors associated with thriving and wellbeing.
You are asked to respond to statements using a scale, for example from strongly agree to strongly disagree. Your answers are scored and used to create an individual report for you. The report may identify areas of strength, areas for development, and learning content that may support your wellbeing and development.
The Thrive 8 Index is not a medical, psychiatric, diagnostic, therapeutic, clinical, occupational health or crisis service. It does not diagnose mental health conditions.
4. What personal information we collect
We may collect and use the following information.
4.1 Identity and contact information
1. name;
2. email address;
3. employer or organisation;
4. role, team, department, programme or cohort, where relevant;
5. country where you currently work; and
6. other contact or administrative details needed to provide the assessment.
4.2 Demographic information
1. age or age range;
2. gender; and
3. country or region.
4.3 Thrive 8 assessment responses
This includes your responses to the Thrive 8 Index questions, including answers about how you perceive your wellbeing, behaviours, habits, working experience, stress, thriving, nutrition, energy, focus, relationships, mindset, purpose and related factors.
4.4 Well-being and mental health-related information
Some Thrive 8 Index statements relate to personal wellbeing factors, including areas such as sleep, resilience, stress management, nutrition, energy, mindset and personal wellbeing. Responses to these statements may constitute special category personal data under applicable data protection laws where they reveal informtion relating to an individual's physical or mental health.
4.5 Report and scoring information
1. scores across the 8 Thrive 8 factors and 28 sub-factors;
2. overall thriving scale position;
3. individual report outputs;
4. learning recommendations; and
5. programme or cohort segmentation data where relevant.
4.6 Coaching, workshops and learning records
Where coaching sessions, workshops, development activities or programme debriefs are provided, we may collect information relating to attendance, participation, development objectives, action plans, feedback and notes created during those activities. These activities may be delivered by intogreat, by your employer’s internal HR team, or by both, depending on how your organisation uses the Thrive 8 Index. If you access our learning platform, we may collect information such as your account details, course enrolment, progress, completion information, learning activity and platform usage data.
4.7 Technical and communications information
We may collect basic technical and communications information, including email delivery information, IP address, device information, access logs and information needed to keep our systems secure.
5. How we collect your information
We collect personal information:
1. directly from you when you choose to complete the Thrive 8 Index assessment, communicate with us, or use the learning platform;
2. from your employer or sponsoring organisation that invited you, where they provide administrative information needed to facilitate participation such as your name, email address, cohort, programme or department;
3. from Microsoft Forms, Microsoft Excel, Microsoft OneDrive and related Microsoft services used to collect, store and process assessment responses;
4. from the Thrive 8 Index scoring engine or model used to generate your report;
5. from workshop, coaching and learning activities where applicable;
6. from any learning platform provider identified to you before you use that platform;
7. from our business systems, email systems and service providers; and
8. from correspondence or support requests relating to the Thrive 8 Index assessment or associated services.
Where the Thrive 8 Index is delivered as a customised or white-labelled programme, invitations and communications may be issued by your employer or sponsoring organisation on our behalf.
Regardless of how the programme is delivered, including in customised, white-labelled or hybrid arrangements, the underlying assessment data, the Thrive 8 Index scoring engine and the generation of reports always remain within intogreat’s control. Your employer or sponsoring organisation will not have direct access to the underlying individual-level data used to generate reports.
6. Automated scoring, modelling and report generation
The Thrive 8 Index assessment uses automated scoring and modelling. Your assessment responses are processed through Intogreat’s scoring engine/model to generate your individual scores and Individual Report.
The automated scoring process is designed to generate personal development insights and educational wellbeing information. The results are not used by Intogreat to make decisions about an individual's employment, promotion, remuneration, disciplinary status or contractual relationship.
The report is generated automatically based on your answers, the Thrive 8 Index scoring methodology, and statistically validated norms. The norms were developed using a benchmark dataset of individuals employed in a defined set of countries, obtained by intogreat from an independent survey panel provider, and may be updated over time as the Thrive 8 Index develops.
Automated report generation is used to provide consistent, efficient and personalised learning and development insights. The report is not a medical diagnosis and should not be treated as clinical advice.
Intogreat may engage specialist technology providers, including providers of artificial intelligence tools, to assist in developing, validating and refining the Thrive 8 Index scoring methodology and statistical norms. Where this involves personal information, it is limited to historic benchmark data obtained for that purpose, as described in section 9; your own individual assessment responses and Individual Report are generated by intogreat's scoring engine and are not shared with such providers.
We do not permit your employer to use your Individual Report to make decisions about your employment. Depending on how your organisation uses the Thrive 8 Index, we may send your Individual Report directly to you, or, where your organisation has arranged for its internal HR team to distribute reports and conduct debriefs, we may send your Individual Report to a nominated member of that HR team for distribution to you and for the purpose of the debrief. We do not provide your employer with your individual response scores or Individual Report other than in these agreed distribution arrangements, which will be explained to you before you take part, together with the safeguards that apply. In every case, your employer does not have access to the underlying raw assessment data used to generate your report.
7. What your employer receives
Your employer or sponsoring organisation receives aggregated reporting only. This means it may receive a company, programme, country, department, management or cohort-level report showing overall scores, themes and learning and development recommendations.
Your employer does not receive your individual assessment responses, individual scores or Individual Report unless we have told you clearly in advance and there is a lawful basis for doing so.
Intogreat applies measures intended to reduce the likelihood that individuals could be identified from organisational reporting.
Where practical, group reporting will be generated only where a sufficient number of participants have completed the assessment. Intogreat may combine, suppress or withhold certain reporting outputs where there is a material risk that information could be linked to identifiable individuals.
For your organisation’s initial benchmark report, intogreat may generate aggregated reporting regardless of group size, because there is no earlier result to compare it with. We recommend, and will discuss with you, an appropriate minimum group size to reduce the risk that individuals could be identified from that reporting.
For any reporting that compares results over time, for example to measure change following an assessment cycle, we will not produce a comparative result for asegment unless at least 10 participants within that segment have completed the assessment on both occasions, because a smaller number could allow an individual’s change in score to be inferred.
If your organisation asks us to segment reporting, for example by team, department, location or business unit, that segmented reporting will show the number of participants in the segment but will not identify which individuals responded. A small segment size increases the risk that responses could be attributed to a particular individual, and we will discuss appropriate minimum segment sizes with your organisation before enabling segmented reporting.
Organisations receiving aggregated reporting are contractually prohibited from attempting to identify individual participants from those outputs or combining them with other information for that purpose. We only describe an output as anonymised where individuals are not reasonably identifiable from it; aggregated reporting that shows participation numbers by segment, such as by team or department, is disclosed to your organisation as aggregated but may not always meet the higher anonymisation standard, and we apply the safeguards described in this section accordingly.
8. Why we use your personal information
We use your personal information for the following purposes:
1. to invite you to complete the Thrive 8 Index assessment;
2. to administer the assessment;
3. to score your responses;
4. to generate and send your Individual Report;
5. to provide personalised learning and development recommendations;
6. to provide access to any learning platform;
7. to generate aggregated reports for your employer or sponsoring organisation;
8. to maintain, validate, develop and improve the Thrive 8 Index, scoring model, statistical norms and learning content;
9. to administer coaching, workshops, debrief sessions and development programmes;
10. to manage customised and white-labelled Thrive 8 Index programmes;
11. to monitor, validate, develop and improve the scientific robustness, reliability and effectiveness of the Thrive 8 Index methodology;
12. to manage security, quality assurance, troubleshooting and system administration;
13. to respond to queries, complaints and rights requests;
14. to comply with legal and regulatory obligations; and
15. to establish, exercise or defend legal claims.
9. Lawful basis for using your personal information
We rely on the following lawful basis under UK data protection law. Where we rely on consent or explicit consent, that consent is given directly to intogreat before we collect your name or email address, separately from any invitation issued by your employer, so that you retain a genuine and free choice about whether to participate.
1. Purpose: Administering the assessment, generating your Individual Report and providing related Thrive 8 services. Lawful basis: Consent under Article 6(1)(a) UK GDPR.
2. Purpose: Processing wellbeing-related assessment responses and other special category data Lawful basis: Explicit consent under Article 9(2)(a) UK GDPR.
3. Purpose: Improving, validating and developing the Thrive 8 Index using anonymised or aggregated information Lawful basis: Data protection law does not apply to information that has been effectively anonymised so that no individual is reasonably identifiable. Before anonymisation, we process the relevant responses under the explicit consent basis described above.
4. Purpose: Creating aggregated reports for your employer Lawful basis: Legitimate interests in helping organisations understand workforce learning and wellbeing themes. Where the creation of those reports involves health information, we also rely on your explicit consent under Article 9(2)(a) UK GDPR. We apply aggregation and disclosure controls and do not share individual-level results under our standard model.
5. Purpose: Improving and validating the Thrive 8 Index and statistical norms Lawful basis: Legitimate interests in developing, validating and improving our assessment tools and services, with safeguards including aggregation, access controls and anonymisation where appropriate.
6. Purpose: Security, records, complaints and legal compliance Lawful basis: Legal obligation, legitimate interests, and establishment, exercise or defence of legal claims.
7. Purpose: Coaching sessions, workshops, development activities, programme debriefs or learning platform access Lawful basis: Legitimate interests in delivering and administering the relevant activity, performance of a contract, or consent where participation is optional and consent is appropriate. If notes reveal health information, we will also identify and document an applicable Article 9 condition.
Where we rely on consent, you may withdraw that consent at any time. Withdrawal does not affect processing carried out before withdrawal.
Sale of goods and services
These Terms govern the sale of goods and services available on our Site. We are legally required to ensure all goods and Services match the description provided in accordance with applicable law. You agree to purchase goods and services from our Site at your own risk. All our goods and Services will be paid for in full when they are ordered.
We reserve the right to cancel your order before dispatch of goods or commencement of Services, or as otherwise allowed by law. Any cancellation or reversal of your transaction will be conducted in accordance with applicable law.
Shipping and delivery
When you purchase goods from our Site, the goods will be delivered through one of the following methods:
- Royal Mail standard delivery by post.
- DPS standard delivery by post.
- UPS standard delivery by post.
Delivery will take place as soon as reasonably possible. Delivery times may vary due to unforeseen circumstances. Please note that delivery times do not include weekends and bank holidays.
If you purchase goods from us for delivery to a destination outside the United Kingdom your purchase may be subject to import duties and taxes applied by the destination country. You are responsible for paying any such duties or taxes. Please contact your local customs office for more information before making a purchase. We are not responsible for the payment of any such duties or taxes and are not liable for any failure by you to pay them.
You are required to provide us with a complete and accurate delivery address, including the name of the recipient. We are not liable for the delivery of your goods to the wrong address or wrong person as a result of you providing us with inaccurate or incomplete information.
Return and Refund Policy
If you wish to cancel your purchase and the goods have already been sent to you, then you must return the goods to us as soon as possible after informing us of your decision. You will be responsible for the cost of returning the goods. We will not be responsible for any damage or loss to the goods that occurs before they are returned to us, including while the goods are in transit. Returns must be made by mail. To return a good by mail, pack your goods, go to your nearest post office and pay the necessary postage. Return to intogreat Ltd, Suite 6A, 10 Duke Street, Liverpool L1 5AS, UK.
If the goods you returned are deemed by us to be undamaged, we will reimburse to you all payments we received from you in relation to the purchase of the goods. Please note that we are permitted by law to reduce your reimbursement to reflect any reduction in the value of the goods that was caused by handling other than what is necessary to establish the nature, characteristics, and functioning of the goods.
We will provide the reimbursement within 30 days after we receive back from you any goods supplied. We will make the reimbursement using the same form of payment as you used for the initial purchase unless you have expressly agreed otherwise. You will not incur any fees because of the reimbursement. This right to cancel and to reimbursement is not affected by any return or refund policy we may have.
Intellectual Property
All intellectual property rights in the Site, Services, Platform and Content are owned by us or our licensors. Except as expressly permitted, you must not reproduce, distribute, modify, create derivative works from, publicly perform, or otherwise exploit the Content. Subject to payment of applicable fees, we grant you a personal, non-exclusive, non-transferable, revocable licence to access and use the Content for your personal, non-commercial development during the term of your access to the Services.
If a product description expressly permits limited sharing or download, you may do so only in accordance with that description and for personal use. You must not remove proprietary notices or circumvent technical protections.
All content and materials made available via the Services, including without limitation text, audio, video, images, workbooks, templates, tools, software, code, designs, trade marks, and branding are owned by us or our licensors and are protected by copyright and other intellectual property laws.
User Content Licence
You retain ownership of your User Content. To enable provision and improvement of the Services, you grant us a worldwide, non-exclusive, royalty-free licence to host, use, reproduce, adapt, and display your User Content solely for the purpose of operating, providing, improving, securing and promoting the Services, including in anonymised or aggregated form, and to comply with law. You represent that you have the rights necessary to grant this licence and that your User Content does not infringe the rights of any third party.
Accessibility Feedback
We are committed to providing an accessible experience for all users and to continually improving the accessibility and usability of our Services. We aim to conform to recognised accessibility standards, including alignment with the principles of the Web Content Accessibility Guidelines (WCAG), and we implement ongoing measures to identify and address barriers to access.
To support this commitment, we undertake the following measures:
- Periodic accessibility reviews and audits of our website and platform;
- Remediation of identified issues within reasonable timeframes;
- Consideration of accessibility in our design and development processes; and
- Provision of reasonable adjustments or alternative formats on request where feasible.
Some content or functionality may be provided by third parties. While we do not control third-party content, we encourage providers to adopt accessible practices and we will work to facilitate accessible alternatives where reasonably practicable.
We welcome feedback on the accessibility of our services. If you encounter any accessibility barriers or require information in a different format, please contact us at support@intogreat.net or Suite 6a, 10 Duke Street, Liverpool L1 5AS, UK. Please include a description of the issue, the relevant webpage or feature, and any assistive technology you are using. We will acknowledge your feedback within 10 working days.
Data Protection and Privacy
We act as controller in respect of the personal data we collect about you in connection with the Services. We will process your personal data in accordance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018 and our Privacy Policy, which forms part of these Terms.
We collect personal data that you provide to us directly (for example, when creating an account, booking sessions, or purchasing Services), data generated through your use of the Services (including usage data and analytics), and, where applicable, data from third-party integrations that you authorise. The categories of personal data processed include identity and contact details, account credentials, transaction and payment information, communications, and engagement with course materials. We do not require special category data for the Services. If you choose to disclose health or other sensitive information during coaching or group sessions, you do so voluntarily. We will treat such information with appropriate confidentiality and will avoid recording or retaining special category data unless strictly necessary for the purposes you request and with your explicit consent.
We use your personal data to provide and administer the Services, manage your account, process payments, respond to enquiries, personalise content, improve our offerings, comply with legal obligations, and, where permitted, to send you marketing communications. We will only send you electronic marketing with your consent or where otherwise lawful, and you may opt out at any time.
We share personal data with trusted processors who provide services to us, such as hosting, analytics, communications, and payment processing, under written contracts that require appropriate safeguards. We may disclose data where required by law or to protect our rights. We will not sell your personal data.
Personal data is stored securely using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction, or damage. We retain personal data only for as long as necessary for the purposes set out above and in accordance with our data retention policies.
Some processing may involve transfers outside the UK/EEA. Where this occurs, we will ensure appropriate safeguards are in place, such as adequacy regulations or standard contractual clauses.
You have rights under data protection law, including rights of access, rectification, erasure, restriction, objection, and data portability, and the right to withdraw consent where processing is based on consent. You also have the right to lodge a complaint with the InformationCommissioner’s Office. For further details of how we process personal data, please refer to our Privacy Policy.
If you participate in group sessions, you must respect the confidentiality of other participants and must not record or share information about them without their express consent.
Warranties and Standards
We will provide the Services with reasonable skill and care and in conformity with the contract. We do not provide medical, psychological, financial, tax or legal advice. Personal development outcomes vary and are not guaranteed. Nothing in this clause limits your statutory rights.
Liability
Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot lawfully be excluded or limited.
If you are a consumer, we are responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms or our failure to use reasonable skill and care. We are not responsible for loss or damage that is not foreseeable. Loss is foreseeable if it is obvious it will happen or if, at the time the contract was made, both we and you knew it might happen.
We only supply the Services for domestic and private use. If you use the Services for any commercial or business purpose, we will have no liability for any loss of profit, loss of business, business interruption or loss of business opportunity.
Subject to the first paragraph of this clause, and to the extent permitted by law, our total liability to you for all losses arising under or in connection with the contract shall be limited to the higher of: the total fees you have paid to us in the 12-month period preceding the event giving rise to liability; or £2,000. This cap does not apply to the liabilities we cannot limit by law.
Your statutory rights under the Consumer Rights Act 2015 and related legislation remain unaffected.
You are responsible for ensuring that your devices, internet connection, and software are suitable for accessing the Services. We are not responsible for any failure to access the Services caused by your equipment, connectivity, or third-party platforms.
Third Party Services
The Services may inter-operate with third-party platforms or contain links to third-party websites. We are not responsible for third-party services or content and your use of them is at your own risk and subject to their terms.
Indemnity
If you are using the Site and services on behalf of a business or legal entity and not in an individual capacity then, except where prohibited by law, you agree to indemnify and hold harmless intogreat Ltd and our directors, officers, agents, employees, subsidiaries, and affiliates from any actions, claims, losses, damages, liabilities and expenses including legal fees arising out of your use of our Site or your violation of these Terms.
Force Majeure
We shall not be in breach of these Terms nor liable for delay in performing, or failure to perform, any of our obligations where such delay or failure results from events, circumstances, or causes beyond our reasonable control, including acts of God, flood, drought, earthquake, or other natural disaster, epidemic or pandemic, governmental actions, war, threat of or preparation for war, terrorist attack, civil commotion, industrial dispute not involving our workforce, failures of utilities or telecommunications, or the default of suppliers or sub-contractors outside our reasonable control.
If a force majeure event prevents performance of our obligations for a continuous period of more than 30 days, either party may terminate the affected Services on written notice. Where Services are terminated due to a force majeure event, we will provide a fair and proportionate refund or credit for Services not provided, taking into account costs already incurred.
Complaints Policy
We are committed to resolving complaints fairly and promptly. If you have a complaint, please contact us by email at hello@intogreat.net, by post to Suite 6a, 10 Duke Street, Liverpool L1 5AS UK or via the Contact Us form on the website. Please include your full name, contact details, a clear and full description of your complaint, relevant dates and the outcome you seek.
We will acknowledge receipt within 10 working days and aim to provide a substantive response within 14 working days. If we need more time, we will tell you when you can expect a full response. If your complaint is not resolved, you may request that it be escalated to a senior manager. If you are a consumer and remain dissatisfied, you may have the right to refer the matter to an alternative dispute resolution (ADR) body. Details of any ADR provider we are willing to use will be provided on request. Use of ADR is voluntary and these Terms do not affect your right to bring a claim in the UK courts.
We will keep a record of your complaint, our investigation, and the outcome for at least 12 months for quality assurance and compliance. We will handle personal data in accordance with our Privacy Policy and applicable data protection laws.
Dispute Resolution and Governing Law
We encourage you to contact us first to resolve any issues. Nothing in these Terms limits your statutory rights or your ability to bring proceedings in the courts of the United Kingdom.
These Terms, their subject matter and formation, are governed by the laws of England and Wales. If you are a consumer resident in Scotland or Northern Ireland, you may bring proceedings in your local courts. If you are a consumer resident elsewhere in the UK, you may bring proceedings in your local courts or in the courts of England and Wales. If you are a business customer, the courts of England and Wales shall have exclusive jurisdiction.
If you reside in the European Union, you may be entitled to submit your complaint to the European Commission’s Online Dispute Resolution (ODR) Platform. ODR allows EU consumers to resolve disputes related to the online purchases of goods and services without going to court.
Subject to any exceptions specified in these Terms, if we are unable to resolve any dispute through informal discussion, then we agree to submit the issue first before a non-binding mediator and to an arbitrator in the event that mediation fails. The decision of the arbitrator will be final and binding. Any mediator or arbitrator must be a neutral party acceptable to both parties. Notwithstanding any other provision in these Terms, we agree that we both retain the right to bring an action in small claims court.
Communications
We will communicate important information about your account, renewals and changes to the Services by email to your registered address or through your account. Please keep your contact details up to date.
Changes to these Terms
These Terms may be amended and updated from time to time in order to maintain compliance with the law and to reflect any changes to the way we operate our Site, Platform or delivery of our Services. If these changes materially affect your use of the Platform and Services, or your legal rights, we will give you reasonable notice. If you continue to use our Services after the changes have taken effect, it means that you agree to the changes. If you don’t agree, you must stop using our Services.
Assignment
You may not assign or transfer your rights or obligations without our prior written consent. We may assign our rights and obligations to an affiliate or in connection with a merger, acquisition or sale of assets, provided this does not materially reduce your rights.
No Waiver
Failure to enforce a right or provision is not a waiver. A waiver must be in writing and applies only to the specific instance.
Severability
If any provision is found invalid or unenforceable, it will be replaced by a valid provision that most closely reflects the original intent, and the remaining provisions will continue in full force.
Entire Agreement
These Terms, together with any documents expressly referred to in them, constitute the entire agreement between you and us regarding their subject matter and supersede any prior discussions or understandings. Nothing in this clause excludes liability for fraud or fraudulent misrepresentation.
Contact details
Please contact us if you have any questions or concerns. Our contact details are as follows: +44(0)7597 487 220
Email: support@intogreat.net
Post: Suite 6A, 10 Duke Street Liverpool, L1 5AS, UK
You can also contact us through the Contact Us form available on our Site.
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