Privacy Policy
Privacy policy
1. Introduction
1.1 We are
committed to safeguarding the privacy of our website visitors, service users,
individual customers and customer personnel.
1.2 This policy
applies where we are acting as a data controller with respect to the personal
data of such persons; in other words, where we determine the purposes and means
of the processing of that personal data.
1.4 We use
cookies on our website. Insofar as those cookies are not strictly necessary for
the provision of our website and services, we will ask you to consent to our
use of cookies when you first visit our website.
1.5 In this
policy, “we”, “us” and “our” refer to Live Academy
Limited.
2. Credit
2.1 This document
was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this
Section 3 we have set out the general categories of personal data that we
process[ and, in the case of personal data that we did not obtain directly from
you, information about the source and specific categories of that data].
3.2 We may
process data enabling us to get in touch with you (“contact data“).
The contact data may include your name, email address, telephone number, and postal
address. The source of the contact data is you and/or your employer.
3.3 We may
process your website user account data (“account data“). The
account data may include your account identifier, name, email address, business
name, account creation and modification dates, website settings and marketing
preferences. The primary source of the account data is you and/or your
employer, although some elements of the account data may be generated by our
website.
3.4 We may
process information relating to transactions, including purchases of goods
and/or services, that you enter into with us and/or through our website (“transaction
data“). The transaction data may include your name, your contact
details, your payment card details (or other payment details) and the
transaction details. The source of the transaction data is you and/or our
payment services provider.
3.5 We may
process information contained in or relating to any communication that you send
to us or that we send to you (“communication data“). The
communication data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms.
3.6 We may
process data about your use of our website and services (“usage data“).
The usage data may include your IP address, geographical location, browser type
and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency
and pattern of your service use. The source of the usage data is our analytics
tracking system.
4. Purposes of processing and legal bases
4.1 In this
Section 4, we have set out the purposes for which we may process personal data
and the legal bases of the processing.
4.2 Operations
– We may process your personal data for [he purposes of operating our
website, the processing and fulfilment of orders, providing our services,
supplying our goods, generating invoices, bills and other payment-related
documentation, and credit control. The legal basis for this processing is our
legitimate interests, namely the proper administration of our website, services
and business.
4.4 Relationships
and communications – We may process contact data, account data, transaction
data and/or communication data for the purposes of managing our relationships,
communicating with you (excluding communicating for the purposes of direct
marketing) by email, SMS, post, fax and/or telephone, providing support
services and complaint handling. The legal basis for this processing is our
legitimate interests, namely communications with our website visitors, service
users, individual customers and customer personnel, the maintenance of
relationships, and the proper administration of our website, services and
business.
4.5 Direct
marketing – We may process contact data, account data and/or transaction
data for [the purposes of creating, targeting and sending direct marketing communications
by email, SMS, post and/or fax and making contact by telephone for
marketing-related purposes. The legal basis for this processing is our
legitimate interests, namely promoting our business and communicating marketing
messages and offers to our website visitors and service users.
4.6 Research
and analysis – We may process usage data and/or transaction data for the
purposes of researching and analysing the use of our website and services, as
well as researching and analysing other interactions with our business. The
legal basis for this processing is our legitimate interests, namely
[monitoring, supporting, improving and securing our website, services and
business generally.
4.7 Record
keeping – We may process your personal data for the purposes of creating
and maintaining our databases, back-up copies of our databases and our business
records generally. The legal basis for this processing is our legitimate
interests, namely ensuring that we have access to all the information we need
to properly and efficiently run our business in accordance with this policy.
4.8 Security –
We may process your personal data for the purposes of security and the
prevention of fraud and other criminal activity. The legal basis of this
processing is our legitimate interests, namely the protection of our website,
services and business, and the protection of others.
4.9 Insurance
and risk management – We may process your personal data where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks
and/or obtaining professional advice. The legal basis for this processing is
our legitimate interests, namely the proper protection of our business against
risks.
4.10 Legal
claims – We may process your personal data where necessary for the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely [the protection and
assertion of our legal rights, your legal rights and the legal rights of
others].
4.11 Legal
compliance and vital interests – We may also process your personal data
where such processing is necessary for compliance with a legal obligation to
which we are subject or in order to protect your vital interests or the vital
interests of another natural person.
5. Providing your personal data to others
5.1 We may
disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal
data held in our website database will be stored on the servers of our hosting
services providers.
5.3 Financial
transactions relating to our website and services are handled by our payment
services providers. We will share transaction data with our payment services
providers only to the extent necessary for the purposes of processing your
payments, refunding such payments and dealing with complaints and queries
relating to such payments and refunds.
5.5 In addition
to the specific disclosures of personal data set out in this Section 5, we may
disclose your personal data where such disclosure is necessary for compliance
with a legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person. We may also
disclose your personal data where such disclosure is necessary for the
establishment, exercise, or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
7. Retaining and deleting personal data
7.1 This Section
7 sets out our data retention policies and procedures, which are designed to
help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.
7.2 Personal data
that we process for any purpose or purposes shall not be kept for longer than
is necessary for that purpose or those purposes.
7.3 We will
retain your personal data as follows:
(a) contact data
will be retained for a minimum period of 6 months following the date of the
most recent contact between you and us, and for a maximum period of 2 years following
that date;
(b) account data
will be retained for a minimum period of 12 months following the date of
closure of the relevant account, and for a maximum period of 2 years following
that date;
(c) transaction
data will be retained for a minimum period of 12 months following the date of
the transaction, and for a maximum period of 2 years following that date;
(d) communication
data will be retained for a minimum period of 6 months following the date of
the communication in question, and for a maximum period of 2 years following
that date;
(e) usage data
will be retained for 12 months following the date of collection;
7.4 Notwithstanding
the other provisions of this Section 7, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.
8. Your rights
8.1 In this
Section 8, we have listed the rights that you have under data protection law.
8.2 Your
principal rights under data protection law are:
(a) the right
to access – you can ask for copies of your personal data;
(b) the right
to rectification – you can ask us to rectify inaccurate personal data and
to complete incomplete personal data;
(c) the right
to erasure – you can ask us to erase your personal data;
(d) the right
to restrict processing – you can ask us to restrict the processing of your
personal data;
(e) the right
to object to processing – you can object to the processing of your personal
data;
(f) the right
to data portability – you can ask that we transfer your personal data to
another organisation or to you;
(g) the right
to complain to a supervisory authority – you can complain about our
processing of your personal data; and
(h) the right
to withdraw consent – to the extent that the legal basis of our processing
of your personal data is consent, you can withdraw that consent.
8.3 These rights
are subject to certain limitations and exceptions. You can learn more about the
rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may
exercise any of your rights in relation to your personal data [by written
notice to us, using the contact details set out below].
9. About cookies
9.1 A cookie is a
file containing an identifier (a string of letters and numbers) that is sent by
a web server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from the
server.
9.2 Cookies may
be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
9.3 Cookies may
not contain any information that personally identifies a user, but personal
data that we store about you may be linked to the information stored in and
obtained from cookies.
10. Cookies that we use
10.1 We use cookies
for the following purposes:
(a) authentication
and status – we use cookies to identify you when you visit our website and
as you navigate our website, and to help us determine if you are logged into our
website;
(b) shopping
cart – we use cookies to maintain the state of your shopping cart as you
navigate our website;
(c) personalisation
– we use cookies to store information about your preferences and to personalise
our website for you;
(d) security
– we use cookies as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally;
(f) analysis
– we use cookies [to help us to analyse the use and performance of our website
and
(g) cookie
consent – we use cookies [to store your preferences in relation to the use
of cookies more generally.
12. Managing cookies
12.1 Most browsers
allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. You can
however obtain up-to-date information about blocking and deleting cookies via
these links:
(a) https://support.google.com/chrome/answer/95647
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
12.2 Blocking all
cookies will have a negative impact upon the usability of many websites.
12.3 If you block
cookies, you will not be able to use all the features on our website.
13. Amendments
13.1 We may update
this policy from time to time by publishing a new version on our website.
13.2 You should
check this page occasionally to ensure you are happy with any changes to this
policy.
13.3 We may notify
you of significant changes to this policy.
14. Our details
14.1 This website
is owned and operated by Live Academy Limited.
14.2 We are registered
in England and Wales under registration number 1196291.
14.4 You can
contact us:
(a) using our
website contact form;
(d) by email, using the email address published on our website.