Privacy Policy

Privacy Notice: 

TLN Training Limited

Last updated: 01 May 2021

Commitment to User Privacy

TLN Training Limited is committed to protecting your privacy. This policy sets out how we will use any personal data that we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you have any questions or concerns, please e-mail

For the purpose of the UK GDPR (as defined in the Data Protection Act 2018) and the General Data Protection Regulation ((EU) 2016/679), the data controller is TLN Training Limited of Metropolitan Wharf, Building Unit 403, 70 Wapping Wall, London, E1W 3SS.

Data controller

The data controller is TLN Training Limited of Metropolitan Wharf, Building Unit 403, 70 Wapping Wall, London, E1W 3SS. We are registered as a data controller with the UK Information Commissioner’s Office (ICO) under registration number ZA217867. TLN Training Limited is a private limited company incorporated in England under company number 08776016, doing business as Gemba®.

The information we collect from you

We will collect and process the following data about you:

Information you give us. 

This is information about you that you give us by filling in forms on our site (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register as a Member on our site, participate in discussion boards, instant messaging or other social media functions on our site, complete a survey promotion or survey and when you report a problem with our site. The information you give us may include your full name, business address, home address, business e-mail address, business phone number, personal phone number, job title, employer details, personal description and photograph.

Information we collect about you. 

We will automatically collect the following information when you visit our site: your IP address; browser type; operating system; referring website addresses and information about your visit, including access times, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We may obtain your personal data from publicly accessible sources such as Companies House, your employer’s website, and LinkedIn.

We offer a virtual reality enabled training programme for employees of our corporate clients, ‘the Gemba Programme’. Participants in the Gemba Programme will be required to register as Members in order to use the Gemba Programme software. We will collect usage data from your use of the Gemba Programme Software in order to improve our product and user experience.

We will gather the following data on Gemba Programme participants:

  • Full name
  • Employer company name
  • Position
  • Work challenges, work description/background, expectation of products and feedback
  • Team/colleagues
  • Login Data – time, date
  • Any failed login attempts
  • Time spent in VR (per session)
  • User usage data
    • Where the user has moved within the virtual environment
    • What the user has looked at within the virtual environment
    • What the user has interacted with within the virtual environment
    • Progress through the learning programme (% complete)
    • Test scores


Use of Cookies

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. Our site uses cookies to distinguish you from other visitors. This helps us to provide you with a good experience when you browse our site. When you visit our site, a cookie (a small text file) is placed on your machine (if it is accepted) to provide you with a personalised experience and to allow us to collect information about your visit. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of our site. Please see our Cookie Policy for more information.

More details about cookies can be found at:

How we use the information and our lawful basis for doing so

Information you give to us.

We will use this information to carry out our obligations arising from any contracts entered into between you and us (including the membership agreement) and to provide you with the information and services that you request from us; to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about; to notify you about changes to our service; and to ensure that content from our site is presented in the most effective manner for you and for your computer.

Your full name, job title, employer name, personal description and photograph will be included in a participant list that will be shared with other participants, our Leaders and guest speakers prior to, or at, your Masterclass or Programme (as applicable). We may also share this information and any feedback you provide to us with our host sites and use it to promote our products (including quoting your feedback on our website or in our training materials). If you do not wish your details to be made available or used in this way, or you would like to change any details, please contact us at

Information we collect about you. 

We will use this information: to administer our site; to improve our site and our user experience; to allow you to participate in interactive features of our services; to keep our site safe and secure; to measure the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We process your personal data where the processing is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract with you (including the membership agreement); where the processing is necessary for the compliance of a legal obligation that is applicable to TLN; and where the processing is necessary for the purposes of our legitimate interests. In some cases we may process your personal data based on your consent. We will not be able to perform our contract with you for membership or training services if you do not agree to our processing of your personal data.

Where we carry out personal data processing based on our legitimate interests we have ensured that our interests are not overridden by the interests or fundamental rights of individuals. We have identified our legitimate interests as fraud prevention; IT security and network administration; providing useful content to our members; keeping our website optimised; facilitating user communications and enquiries; carrying out marketing activities to promote our executive network.

In respect of any online chat group for our members made available via third party instant messaging sites, apps or platforms (“Group Chat”), we will only add you to such Group Chats at your request and with your prior consent.  You have the right to withdraw your consent at any time by contacting us.  Alternatively, you may remove yourself from such Group Chats without notice to us.


We use profiling in order to enhance your user experience and to present you with advertising that is relevant to you and in line with your browsing history and past purchases. We do not carry out any automated decision making.

If you exercise your right to object to profiling, then we will unsubscribe you from your membership and stop processing your personal data in accordance with our data retention policy.

Information sharing and where we store the information

We may share your personal data with third party service providers in order to fulfil your order or perform processing or other specialised services; if we need to enforce our terms and conditions or comply with applicable laws; in connection with the contemplated or actual financing or disposal of all or part of our business or assets; where you have requested to participate in Group Chats and as specified in the section ‘How we use the information and our lawful basis for doing so’.

If the Services were purchased by another party for you to use (e.g., TLN Masterclass or Gemba Programme purchased by your employer), the party paying for such Service will receive reports on your use of such paid for Service. The reports will include:

In the case of TLN Masterclasses: confirmation of your attendance at the Masterclass, attendee profile (work challenges, work description/background, expectation of Masterclass), and feedback.

In the case of the Gemba Programme: 

  • Login Data – time, date
  • Any failed login attempts
  • Time spent in VR (per session)
  • Work challenges, work description/background, expectation of products and feedback
  • User usage data
    • Where the user has moved within the virtual environment
    • What the user has looked at within the virtual environment
    • What the user has interacted with within the virtual environment
    • Progress through the learning programme (% complete)
    • Test scores

The data that we collect from you may be transferred to, and stored at, a destination outside the UK. We will only transfer your personal data outside of the UK to jurisdictions that have been recognised by the UK Government or by UK law as having an adequate level of protection or where the transfers are made with appropriate safeguards in accordance with applicable privacy laws.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. 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 data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


How long we keep your personal data

We keep your personal data for as long as required for the purpose for which it was collected, and to comply with any legal requirements, including minimum retention periods. When your personal data is no longer required, it will be deleted. We keep our data retention policy under regular review to ensure that we are not processing your personal data for longer than necessary.

Data security

We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify the ICO and/or you of a personal data breach where we are legally required to do so. See Gemba Security Policy.

Links to other websites

Our site may contain some links to other websites. Please be aware that TLN Training Limited is not responsible for the privacy practices of such other sites. This privacy notice applies solely to the information collected by TLN Training Limited.

Your legal rights and how to exercise them

You have the following data protection rights in relation to your personal data that apply in certain circumstances:

Right to erasure: 

You can ask us to erase or delete all or some of your personal data.

Change or correct data:

You can also ask us to update the data we hold about you.

Object to, or limit, our use of your data:

You can ask us to stop using all or some of your personal data or to limit our use of it.

Subject access requests and portability right: 

You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Withdraw consent at any time where we are relying on consent to process your personal data: 

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.

Object to direct marketing at any time: 

You can object to receiving direct marketing from us at any time.

Lodge a complaint with a regulator, in this case the Information Commissioner’s Office (ICO): 

You have the right to complain to the ICO and their website is at, but we would prefer if you raised any issues with us first.

Notification of changes

We will keep this notice updated in line with new legislation and best practice. When we do, we will also revise the “last updated” date at the top of the notice, and make it clear on our website that the notice has been revised.


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