Privacy Policy

Welcome to CROSSFADER LTD’s (also referred to as “we”, “us” or “our”) PRIVACY POLICY

For details of how to contact us about this policy please see the ‘Contact Us’ section below.

This Privacy Policy describes how your personal information is protected, collected, used, and shared when you visit or make a purchase from https://www.wearecrossfader.co.uk (the “Site”).

It also sets out your rights in relation to your personal data.

It is important that you read this privacy policy together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

PERSONAL INFORMATION WE COLLECT

The following list sets out the type of data we collect from you in the course of processing your order and providing you with our courses or services.

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes payment card details and details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, how you browse the Site, information about how you interact with the Site, what websites or search terms referred you to the Site, the web pages you visit, the courses you view, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

This website is not intended for children and we do not knowingly collect data relating to children.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our courses or services). In this case, we may have to cancel a course you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

Directly:

You give us your Identity, Contact and Financial Data when you:

purchase or subscribe to a course through the Site;
request email and marketing communications to be sent to you; or
give us feedback or contact us.

Automatically:

You give use your Technical, Profile and Usage Data:

When you visit the Site,
Via “Cookies” (which are data files that are placed on your device or computer and often include an anonymous unique identifier. You will be presented with the option to opt out of the cookies we store on your first visit to the Site. You can amend your cookie preferences at the bottom of this page or for more information on cookies visit http://www.allaboutcookies.org.
Via “Log files” (these track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps); or via “Web beacons,” “tags,” and “pixels” (these are electronic files used to record information about how you browse the Site).

Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources such as analytics providers (such as Google, Facebook and Twitter),

HOW DO WE USE YOUR PERSONAL INFORMATION?

Order Information

We use the order information that we collect generally to fulfil any orders placed through the Site (including processing your payment information and providing you with order confirmations).

Additionally, we use order information to:

Communicate with you;
Screen our orders for potential risk or fraud; and
provide you with information or advertising relating to our products or services (when in line with the preferences you have shared with us).

Device Information

We use the device information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

We may also use your personal information in custom audiences on Facebook and other social media platforms to help deliver relevant marketing and advertising campaigns.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer and process your order, including processing your payment	(a) Identity (b) Contact (c) Financial	Performance of a contract with you
To manage our relationship with you which will including notifying you about matters such as changes to your order, our terms or privacy policy	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a)Technical (b) Profile (c) Usage	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To send you marketing & promotional messages and to deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Contact (b) Profile (c) Usage (d) Marketing	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Profile (b) Usage (c) Marketing	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Profile (b) Usage (c) Marketing	Necessary for our legitimate interests (to develop our products/services and grow our business)
To maintain and retain records in connection with legal claims and regulatory investigations; and for governance & compliance purposes.	(a) Identity (b) Contact (c) Financial	Necessary to fulfil our legal obligation
To understand how customers and visitors to our website use the website and interact with it via data analysis	(a)Technical (b) Profile (c) Usage	Necessary for our legitimate interests (to develop our products/services and grow our business)

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Also, we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, for the purposes as described in the table above.

In particular we share your personal information with:

Suppliers

ConvertKit (to administrate our customer relationship management process and send you email communications – you can read more about how they use your personal information here: https://convertkit.com/privacy);
Google Analytics (to help us understand how our customers use the Site–you can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout)
AWS (to host our Site – you can read more about how Amazon uses your personal information here: https://aws.amazon.com/privacy/)
PayPal (to process your payments – you can read more about how PayPal uses your personal information here: https://www.paypal.com/myaccount/privacy/privacyhub)
Braintree (to process your payments – they are part of the PayPal group – you can read more about how PayPal uses your personal information here: https://www.braintreepayments.com/gb/legal/braintree-privacy-policy)

Advisers

We may need to share your personal data with our professional advisers such as our accountants, auditors, bankers, insurers, IT providers or lawyers. We will ensure that they are bound by obligations to protect your personal data.

Governmental/professional bodies

There may be some instances where we are required to share your personal data with governmental or professional bodies (e.g. for legal or compliance reasons) such as HMRC or fraud prevention agencies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Finally, we may also share your Personal Information with relevant authorities in order to comply with applicable laws and regulations, to respond to summons, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

COOKIES (AND BEHAVIOURAL ADVERTISING)

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

FACEBOOK – https://www.facebook.com/settings/?tab=ads

GOOGLE – https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

MARKETING

We will get your express opt-in consent before we send you marketing and promotional materials and we will not share your personal data with any third party for marketing purposes (unless you explicitly agree for us to do so).

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at [email protected] any time.

Please note that we may need to send you messages about your order, courses registration, product/service experience or other transactional information.

YOUR RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, 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.

DATA RETENTION

When you place an order through the Site, we will maintain your Order Information for our records and for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you (unless you submit a Subject Access Request and you ask us to delete this information).

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal, accounting and tax purposes.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. This version was last updated on 22nd July 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail at: Avenue HQ, 10-12 East Parade, Leeds LS1 2BH

If you wish to make a complaint you have the right to contact (at any time) the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

When it comes to actual payment, your financial details are handled by PayPal or Braintree (as set out above) with a secure, encrypted system so we will never actually see you credit card details. All we get are your order and delivery details along with a confirmation from PayPal that you have completed the transaction.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an ‘adequate’ level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK and referred to as ‘Standard Contractual Clauses’.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.