In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site and in order to utilize the services We provide;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 13, below;
“Data Protection Regulation” means all legislation in force in the United Kingdom from time to time relating to data protection and privacy including, but not limited to, the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendment Etc.) (EU Exit) Regulations 2019, and any successor legislation relating to data protection and privacy, and only if you are an EU or EEA resident and if applicable the General Data Protection Regulation (EU Regulation 2016/679);
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or otherwise. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Regulation; and “personal data”
“We/Us/Our” means I-VINE TRAINING LTD .
1. Our Site is owned and operated by I-VINE TRAINING LTD , a limited company registered in England and Wales under company number 14737992 , whose registered address is 128 City Road, London, EC1V 2NX , United Kingdom.
This Privacy Policy applies to your use of Our Site and/or services including but not limited to in your personal capacity or as a representative of a legal entity. Our Site may contain links to other websites, and as part of Our services We offer to provide references to third-party suppliers including but not limited to financial institutions, accountants, accountancy and bookkeeping service providers, auditors, telephone answering and post handling service providers, tax advisers and/or other similar third-party service providers. Please note that We have no control over how your personal data is collected, stored, or used by other websites and third-party suppliers. We advise you to check the privacy policies of any such websites and third-party suppliers before providing any data to them.
1. As a data subject, you have the following rights under the Data Protection Regulation, which this Policy and Our use of personal data have been designed to uphold:
1. The right to be informed about Our collection and use of personal data;
2. The right of access to the personal data We hold about you;
3. The right to rectification if any personal data We hold about you is inaccurate or incomplete;
4. The right to be forgotten – i.e., the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in Part 6);
5. The right to restrict (i.e., prevent) the processing of your personal data;
6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organization);
7. The right to object to Us using your personal data for particular purposes; and
8. Only if you are an EU or EEA resident and if applicable rights with respect to automated decision making and profiling.
9. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in Part 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the United Kingdom’s supervisory authority, the Information Commissioner’s Office.
10. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.1 . Depending upon your use of Our Site and/or services, We may collect some or all of the following personal data as well as non-identifiable web browsing information such as the following (please also see Part 13 on Our use of Cookies and similar technologies):
5.1.1 name;
5.1.2 address;
5.1.3 nationality;
5.1.4 passport/ID number;
5.1.5 email address;
5.1.6 telephone number;
5.1.7 IP address;
5.1.8 location data;
5.1.9 device type;
5.1.10 web browser type and version; and
5.1.11 operating system.
5.2 We are not collecting financial information such as credit / debit card numbers, but our payment provider may collect such information refer to the privacy policy of the payment provider for further information about the collection and processing of such information.
1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Regulation at all times. For more details on security see Part 7, below.
2. Our collection and use of your personal data will always have a lawful basis because it is in Our legitimate interest to collect and use such information. Specifically, We may use your data for the following purposes:
1. Providing and managing your Account;
2. Providing and managing your access to Our Site;
3. Personalizing and tailoring your experience on Our Site;
4. Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
5. Personalizing and tailoring Our products and services for you;
6. Replying to emails from you;
7. Supplying you with emails that you have opted into. You may unsubscribe or opt-out at any time by pressing unsubscribe on any correspondent email, or contact Us using the contact details below in Part 14 and requesting it;
8. Market research; and
9. Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Regulation.
4. Third parties whose content appears on Our Site may use third party Cookies, as detailed below in Part 13. Please refer to Part 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
5. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases): Subject to Part 6.7 We shall as a default keep your data on file for 36 months of your last activity.
7. When supplying Our products and services to you We may need your personal data and other ID information, and We will keep that as well as details of transactions you carry out via Our Site or services provided by Us in order to comply with public anti-money laundering regulations and bookkeeping, audit, reporting and other public requirements, which requires Us to hold and retain records for seven years after ceasing to provide the service to you.
1. We only keep your personal data for as long as We need to in order to use it as described above in Part 6 or for as long as We have your permission to keep it.
2. The security of your personal data is essential to Us, and to protect your data, We take a number of important measures, including the following:
1. limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
2. implementing procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where We are legally required to do so.
3. We may transfer some or all of your personal data to public and authorities including but not limited to Companies House and HMRC.
4. We may transfer some or all of your personal data to third parties including but not limited to accountants, accountancy and bookkeeping service providers, auditors, telephone answering and post handling service providers, tax advisers, financial institutions and/or other similar third-party service providers, provided you have authorized Us to do so by ordering particular products or services.
5. We may store or transfer some or all of your personal data to countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These including the United Kingdom are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that We will endeavour to take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be under the Data Protection Regulation as follows:
5.1. We may share your data within the group of companies of which We are a part, including but not limited to UK limited company I-Vine Training Ltd. Where this involves the transfer of personal data outside the United Kingdom or the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”.
5.2. We may share your data with external third parties that are based outside of the United Kingdom or the EEA. The following safeguards are applied to such transfers if you are an EU or EEA resident:
5.1a. We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission.
5.2b. We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation.
6. Please contact us using the contact details below in Part 14 for further information about the particular data protection mechanisms used by Us when transferring your personal data to a third country.
1. We may share your data with other companies in Our group in order to supply services attached to our core business. This includes Our holding company and its subsidiaries.
2. We may contract with third parties including but not limited to accountants, accountancy and bookkeeping service providers, auditors, telephone answering and post handling service providers, tax advisers, financial institutions and/or other similar third-party service providers to supply products and services to you on Our behalf or to make an introduction for you. These may also include third-party service providers to help check your identity or assist with payment processing, search engine facilitation, advertising, marketing and the provision of other goods and services. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the Data Protection Regulation.
3. As company formation agents we must comply with UK Anti Money Laundering regulations (“AML legislation”) including the The Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020. This entails that we must carry out ‘client due diligence’ measures with the purpose of checking that our clients are who they say they are. We refer Our clients to third-party providers to help prove their’ identity for Us in order to comply with the AML legislation. The third-party providers collect personal data from Our clients directly, and personal data are not transferred by Us to the third-party provider. The personal data collected may include special category data for which explicit consent from you is required. Such collection, processing and handling of personal data is done further to the privacy policies of the third-party providers.
4. Clients that order a dormant account service or referral to an accountant must agree to have their details including personal data passed to a third-party service provider, which will handle this service.
5. Clients that order VAT registration service must agree to have their details including personal data passed to a third-party service provider, which will handle this service.
6. We may compile statistics about the use of Our Site and services including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as public authorities, prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the Data Protection Regulation.
7. Any transfers of your personal data to third-party data processors used by Us that are not located within the United Kingdom or the EEA will follow the principles laid out in Part 7.
8. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or public or governmental authorities.
1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
1. In addition to your rights under the Data Protection Regulation, set out in Part 4, when you submit personal data to Us via Our Site or otherwise, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
2. You may restrict Our use of Cookies. For more information, see Part 13.
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Regulation, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in Part 14.
1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
2. By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for, e.g., Advertising purposes. For more details, please refer to Part 6, above, and to Part 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
3. All Cookies used by and on Our Site are used in accordance with the Data Protection Regulation.
4. Before Cookies are placed on your computer or device, you will be shown a popup or push notification requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
5. Certain features of Our Site depend on Cookies to function. The Data Protection Regulation deems these Cookies to be “strictly necessary”. These Cookies are shown below in Part 13.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in Part 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
6. The following first party Cookies may be placed on your computer or device:
