Last updated: Jan 25, 2019 in compliance with GDPR.
What is site tracking?
Our site tracking feature tracks visits made to our website and associates those page visits with contact records.
It also collects the IP address of new contacts who sign up to receive emails.
Site tracking allows us to see which web pages a contact visits so we can create segments and send targeted campaigns, display site messages to specific contacts, and is used with attribution features.
These page visits and the IP address are considered personal data.
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a purchase, you are consenting to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to decline.
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, and for the continued collection, use or disclosure of your information, at any time, by contacting us at firstname.lastname@example.org.
Our Services are intended for users who are at least the age of majority in their location of residence. Furthermore, Always Mastering does not knowingly collect personally identifiable information (PII) from persons under the age of 13. If you are under the age of 13, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the age of 13, please contact us immediately at email@example.com. If we become aware that we have inadvertently received Personal Information from a person under the age of 13, we will delete such information from our records.
Information Provided By You
We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, complete a Always Mastering form or application, contact customer support, make a purchase or otherwise communicate with us. This information may include, without limitation: name, date of birth, e-mail address, physical address, business address, phone number or other personal information you choose to provide.
Information Collected Through Your Use of Our Services
The following are situations in which you may provide Your Information to us:
- When you fill out forms or fields through our Services;
- When you register for an account with our Service;
- When you order services, courses, subscription plan or products from, or through our Service;
- When you sign up for any newsletters or other materials through our Services;
- When you provide information to us through a third-party application, service or Website;
- When you communicate with us or request information about us or our courses, products or Services, whether via email or other means;
- When you participate in online surveys;
- When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
- When you participate in forums, reviews or provide user generated content or other submissions.
- We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to cookies and pixel tags (explained below).
We may collect your IP address, browsing behaviour and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customise the Services to improve your overall experience.
Information Collected From Other Sources
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Always Mastering account with a social media service, e.g. LinkedIn, Facebook or Twitter, or a payment provider, e.g. Apple Pay or Google Wallet, or if you engage with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network.
Information Third Parties Provide
We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, other users and our business partners.
Log Files, Cookies and Anonymous Identifiers
Technologies such as cookies (a small file placed on your device), pixel tags, web beacons, touch heat-maps, user recordings, crash videos, scripts and similar technologies that create and maintain unique identifiers are used by us and our partners, affiliates, advertisers, analytics teams, or service providers. These technologies are used in analysing trends, administering the Site, tracking user’s movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
When you use the Services we may collect your precise location data. We may also derive your approximate location from your IP address.
Call and SMS Data
In connection with providing Service, we may receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message. You consent to the receipt, collection and storage of this information.
Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorisation controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure.
We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
The Legal Basis For Collection and Processing Your Personal Information
The legal basis upon which we rely for the collection and processing your Personal Information under the GDPR are the following:
It is necessary for entering into, or performing, the obligations of a contract between you and Always Mastering, including, without limitation, the Terms of Service agreement which may be accessed by you HERE;
It is necessary for our legitimate interests in the proper administration of our website and business; analysing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you.
It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you;
It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.
How We Use Information We Collect
Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customised experience. We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared.
We will use this information in order to:
- Provide users with our Services and customer support including, but not limited to, confirming emails related to our services, reminders, confirmations, requests for information and transactions.
- Contact you and provide you with information.
- Analyse, improve and manage our Services and operations.
- Resolve problems and disputes, and engage in other legal and security matters.
- Enforce our Terms of Service.
Additionally, we may use the information we collect about you to:
- Send you communications we think will be of interest to you, including information about courses, products, services, promotions, news, and events of AlwaysMastering and other companies, where permissible and according to local applicable laws.
- Display advertising, including advertising that is targeted to you or other users based on your location, interests, as well as your Always Mastering activities.
- Verify your identity and prevent impersonation, spam or other unauthorised or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
How We Share Information We Collect
- With third party Service Providers to enable them to provide the Services you request;
- With the general public if you submit content in a public forum, such as your reviews, comments or other features of our Services that are viewable by the general public;
- With third parties with whom you choose to let us share information, for example other Websites or Apps that integrate with our API or Services, or those with an API or Service with which we integrate.
- With Always Mastering subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralisation and/or logistics purposes;
- With affiliated entities that provide payment processing services on our behalf;
- With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
- With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Always Mastering or others;
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- If we otherwise notify you and you consent to the sharing; and
- In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.
We may disclose Your Information:
- To any person who, in our reasonable judgment, is authorised to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
- To our third-party vendors and service providers so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services maintenance and security. These companies are authorised to use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential;
- As required by law or ordered by a court, regulatory, or administrative agency;
- As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
- If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;
- To enforce or protect our rights.
Sharing Information With Law Enforcement
Always Mastering is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If Always Mastering receives a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency.
Furthermore, Always Mastering may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. Always Mastering will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.
Social Media Sharing
Our Services may now or in the future integrate with social sharing features and other related tools which let you share actions you take on our Services with other Apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
Any information or content that you voluntarily disclose for posting publicly to our Service or the social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with the social sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you posted to our Service or the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using our Service or the social sharing service, have re-shared, copied or saved that User Content.
Analytic Services Provided By Others
Links to Third-Party Websites
Do Not Track Settings
International Privacy Practices
In order to provide our products and services to you, we may send and store your personal information outside of the country where you reside or are located, including the U.S, U.K, or Cyprus. Accordingly, if you reside or are located outside of the U.S, U.K, or Cyprus, your personal information may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our products and services, users who reside or are located in countries outside of the Cyprus agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different and may be less protective than those required under the laws of their residence or location.
You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please email us at firstname.lastname@example.org Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debit on your account, or if we believe you have committed fraud or violated our Terms of Service, we may seek to resolve the issue before deleting your information.
Promotional Information Opt Out
You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.
Your Access and Rights to Your Personal Information
You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below.
Right of Correction or Completion. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed.
Right of Deletion. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why.
Right to Object To or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time.
Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 3 years and may retain the information for as long as needed for our business and legal purposes.
If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Address: Always Mastering LTD
Kemp House 160 City Road
Company Number: 11662937