At Strongoak Education Limited (a company registered in England and Wales under company number is 11496603 whose registered office is at The Oakley, Kidderminster Road, Droitwich, Worcestershire WR9 9AY) ("we", "us" or "our"), we are committed to protecting the privacy of visitors to our website (the "Website"). In this Privacy Policy, including our Cookie Policy, you’ll find information about the types of personal data that we collect from visitors to our Website, the purposes for which we use the data and the ways in which the data is handled.

For the purpose of this Privacy Policy, we are the controller of the personal data we process, and our contact details are set out in the Contact section at the end of this Privacy Policy.

By using the Website, you agree to the collection and use of your personal data by us in accordance with this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use the Website.

We may collect and process the following information about you:

• Information that you provide to us, for example when registering on our Website or placing an order with us. This may include your name, email address, mailing address, phone number, credit card information or other details;

• Information which you provide to us for the purpose of subscribing to direct marketing;

• Information provided in, or relating to, communications you may have with us; and

• Statistical data about your browsing actions and patterns, which does not identify you. This means information about your computer and your use of our Website, including (where available) your IP address, unique mobile device identifier, International Mobile Equipment ID, Android ID, device MAC address, browser information, operating system, timestamps, the pages that you request, applications downloaded, traffic data, location data, weblogs and other communication data, and the resources that you access.

We may use the information we collect from you in the following ways:

• To provide the Website and our services to you;

• To ensure that the Website is presented in the most effective manner for you and for your computer, including to personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested;

• To improve the Website;

• To maintain our business relationship;

• To fulfil contractual obligations with you and any other users;

• To deal with enquiries or complaints made by or about you relating to our services or Website;

• Where relevant, to meet legal, regulatory and compliance requirements;

• To notify you about changes to our services or Website; and

• With your consent, for direct marketing purposes (including to provide you with updates and news regarding our services). Where we do so, you will be able to unsubscribe from such communications.

We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:

• Where it is necessary for entering into or performing a contract – in order to perform obligations which arise under a contract we have entered into with you, it will be necessary for us to process your personal data;

• Where we need to comply with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you, optimising our Website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner; and

• Where you have provided consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.

We may share your personal information with third parties in the following circumstances:

• For marketing purposes where you consent to this;

• Where third parties perform functions on our behalf and provide services to us such as Website hosting and assisting in operating the Website, subject always to confidentiality obligations;

• Where we are obliged, or permitted, to do so by applicable law, law enforcement agency, regulation, regulatory body or legal process;

• Where it is necessary to enforce our Website policies, or to protect ours or others' rights, property or safety; or

• If we (or substantially all of our assets) are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets.

To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses or the EU/US Privacy Shield.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.

We conduct regular data-cleansing and updating exercises to ensure that the data that we hold is accurate, and that we are not holding data for too long.

We take appropriate organisational and technical measures to protect your personal information that we hold and to ensure that your personal data is treated in accordance with this Privacy Policy.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

All transactions are processed through a gateway provider (with whom we have put in place a data processing agreement) and are not stored or processed on our servers.

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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential and you are responsible for any misuse of such information. You must change your password on a regular basis and must not share your password with anyone. You are solely responsible for the security and confidentiality of your account. Please ensure that you do not allow anyone else to access the Service in your name and log off after you have finished accessing your account. You are responsible for all orders, and for the accuracy of all information, sent via the internet using your user ID, password or any other personal identification used to identify you on the Website. You will be liable to us for all orders or transactions placed by use of your user ID and password, even if such use might be wrongful. We will not be liable to you for any loss that you may incur as a result of misuse of your user ID and password, and we accept no liability resulting from its unauthorised use, whether fraudulent or otherwise.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Website and any transmission is at your own risk.

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below:

• Right of access – you have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so;

• Right of correction or completion – if personal information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed;

• Right of erasure – in certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information;

• 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, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes. 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;

• Right of data portability – in certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation. This right exists only in respect of personal information that you have provided to us previously and is processed by us using automated means; and

• Right to withdraw consent – to the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.

You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Like most websites, when you visit our Website, we place cookies on your computer or other device. For the most part, these cookies are used to enable the Websites' functionality, improve the user experience or help us to optimise the Website, measure traffic and other internal management purposes. A list of all the cookies used on the Website is set out below.

• Strictly necessary cookies – these cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website or remembering information you have entered on forms when you move to other pages within a browser session. Without strictly necessary cookies, certain services which you may have asked for will not be possible and our Website will not perform as smoothly as we think you would expect;

• Performance cookies – these cookies collect anonymous information about your use of our Website, for instance which pages you visit most often, and if you receive any error messages. These cookies don't collect information that identifies you personally and all information collected by these cookies is aggregated and therefore anonymous;

• Functionality cookies – these cookies remember choices you make on our Website (such as your username, language or the region you are in) and allow us to improve your experience by providing enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites;

• Targeting or advertising cookies – we use targeting cookies or advertising cookies to deliver adverts which we believe are more relevant to you and your interests. We may also use targeting or advertising cookies to limit the number of times you see the same advert on our Website and to help measure the effectiveness of our advertising campaigns. These cookies remember what you have looked at on our Website and may share this information with third parties such as advertisers like Facebook.

• Third party cookies – these cookies allow third parties to track the success of their applications (such as advertisements) or customise the applications for you. For example, if you choose to ‘share’ content through Twitter or other social networks you might be sent cookies from these websites. We don't control the setting of these cookies, so please check those websites for more information about their cookies and how to manage them.

By using the Website, you agree that we can place these types of cookies on your device. You may refuse to accept our cookies on your computer or device at any time by activating the setting on your browser which allows you to refuse cookies.

Please note that by deleting or disabling cookies you may be unable to access certain areas or features of our Website and it will mean that settings such as your stored username and password may have to be reset.

We do not include or offer links to third-party products or services on our Website.

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website. You can set preferences by using the Google Analytics Opt-Out Browser add on.

We keep our Privacy Policy under regular review, and have the right to amend it at any time. Any changes we make will be posted on this page.

This Privacy Policy was last updated on 16th December 2022.

 

Contacting Us

If at any time you have any questions regarding this Privacy Policy, or if you would like to contact us about our processing of your personal data (including to exercise your rights as outlined above) please contact us:

By email: support@commercialpropertyacademy.co.uk 

By post: The Oakley, Kidderminster Road, Droitwich, Worcestershire WR9 9AY

We encourage you to contact us directly in the first instance with any concerns that you may have regarding our use of your personal data. However, you also have the right to make a complaint to a data protection regulator. In the UK, this is the Information Commissioner's Office – for more information, please visit their website at www.ico.org.uk.

If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA and the European Free Trade Area can be accessed here suzi@commercialpropertyacademy.co.uk