Legal
Privacy Policy
Working draft · Last updated 10 August 2026
This is an interim working version and will be updated when Qolsta’s final legal, supplier and data-retention details are confirmed.
Qolsta Ltd respects your privacy and is committed to using personal information responsibly and transparently.
This Privacy Policy explains what information we may collect, why we use it, who we may share it with and the choices and rights available to you.
For data protection purposes, the data controller is Qolsta Ltd. Final registered-office and privacy contact details will be added when confirmed.
1. Information we may collect
When you use Qolsta or RTP, we may collect information including your name, email address, membership status and account information.
If your access is provided through an employer or organisation, we may receive information from them such as your name, work email address, organisation and licence allocation.
Where paid access is purchased, we may process information relating to the transaction, subscription or payment status. Full payment-card details may be handled directly by a third-party payment provider rather than Qolsta.
We may also receive information when you contact us, request support, respond to a survey or otherwise communicate with Qolsta.
The website may collect technical information including IP address, device and browser information, login activity and information about how the website is used.
2. Personal reflections and RTP journals
RTP encourages you to think about personal areas of your life, including your ambitions, relationships, wellbeing, work and future plans.
Where an RTP Journal or other resource is downloaded and completed on your own device, that information is not automatically provided to Qolsta.
Unless a feature clearly tells you otherwise before you use it, Qolsta does not use your private RTP journal entries or reflective answers to report back to your employer.
If Qolsta introduces features in the future that store personal reflections on its systems, this Privacy Policy will be updated and appropriate information will be provided before those features are used.
3. Why we use personal information
We may use personal information to create and manage your account, provide access to RTP, administer memberships and licences, provide customer support, maintain the security of the platform, communicate important service information and fulfil our contractual and legal responsibilities.
We may also use appropriate information to understand how Qolsta is being used and improve the programme and website.
Where permitted, we may send communications about Qolsta, new content, events or related services. You can unsubscribe from marketing communications at any time.
4. Our lawful bases
Depending on the circumstances, we may process personal information because it is necessary to perform a contract with you or take steps at your request before entering into a contract.
Where access is provided through your employer, we may rely on our legitimate interests in administering the organisation’s RTP programme and providing your access, provided those interests do not override your rights and interests.
We may also process information where necessary to meet a legal obligation.
Where consent is the appropriate lawful basis, for example for certain marketing or non-essential tracking technologies, you may withdraw that consent.
5. Employer-sponsored RTP
Where your employer or another organisation sponsors your access, they may provide Qolsta with information needed to allocate and administer your place.
We may provide that organisation with reasonable administrative information about its licences, for example the number of places allocated or activated.
We will not provide an employer with your private reflections or journal content simply because they paid for your access.
If a corporate programme involves different reporting arrangements, these will be explained clearly to participants.
6. Who we share information with
We may use trusted service providers to operate Qolsta. These may include:
- Ghost or another website and membership platform;
- a payment processor;
- email and communication providers;
- hosting, security, analytics and technical-support providers;
- professional advisers where reasonably necessary;
- regulators, courts or public authorities where disclosure is legally required.
We require service providers handling personal information on our behalf to use it only for appropriate purposes and to protect it.
7. International processing
Some technology providers may process personal information outside the United Kingdom.
Where international transfers occur, Qolsta will take appropriate steps required by data protection law to ensure that personal information receives suitable protection.
This section will be updated once Qolsta’s final supplier list and hosting arrangements have been confirmed.
8. How long we keep information
We do not keep personal information indefinitely.
We retain information for as long as reasonably necessary for the purpose for which it was collected, including providing RTP, meeting legal or accounting obligations, resolving disputes and protecting Qolsta’s legitimate interests.
Specific retention periods for member records, financial records, enquiries, security logs and marketing records will be added once Qolsta’s final retention schedule has been agreed.
9. Marketing
We may send you marketing communications where we have an appropriate legal basis to do so.
Every marketing email will provide a straightforward way to unsubscribe.
10. Cookies and similar technologies
Qolsta may use cookies and similar technologies to operate the website, remember preferences, maintain security, understand site performance and, where appropriate, analyse use of the service.
Some technologies are necessary for the website to work. Where consent is required for non-essential cookies or similar technologies, we will ask for it before using them.
A separate Cookie Notice or Cookie Settings page may be added once the final analytics and tracking tools used by Qolsta have been confirmed.
11. Your data protection rights
Depending on the circumstances, you may have rights to request access to your personal information, ask for inaccurate information to be corrected, request deletion, restrict certain processing, object to processing and receive certain information in a portable format.
Where processing is based on consent, you may withdraw that consent.
We may need to confirm your identity before dealing with a request.
12. Complaints
If you have concerns about how Qolsta uses your personal information, please contact us first so we can try to resolve the matter.
You also have the right to complain to the UK Information Commissioner’s Office.
13. Security
We take reasonable organisational and technical measures to protect personal information against unauthorised access, loss, misuse or disclosure.
No online system can be guaranteed to be completely secure, so users should also protect access to their email accounts and devices.
14. Changes to this Privacy Policy
We may update this Privacy Policy as Qolsta develops, suppliers change or our use of personal information changes.
The current version will be published on the Qolsta website with the date of the latest update.
15. Contact
Questions about privacy or the use of personal information can be sent to Qolsta Ltd using the contact details published on this website. Formal registered-office and privacy contact details will be added when confirmed.