CODE FOR CREATIVES - PRIVACY AND COOKIES POLICY
Last updated March 2024.
This is the privacy policy of Code For Creatives Ltd, a company registered in England and Wales under company number 14915737 whose registered office is at 63/66 Hatton Garden, Fifth Floor Suite 23, London, EC1N 8LE (“we” or “us”).
Your privacy is important to us. This policy sets out information on the personal data we collect about you, and your rights in respect of this data and applies whether you visit our website, available at codeforcreatives.co.uk (“website”) or purchase our coaching services and access to our course (“services”). Any links to third party websites from our website aren’t covered by this policy so you should review the privacy statements of other websites to understand their information practices.
This policy contains the following information:
Information about us
Information on what we may collect
How we store your personal data
How we disclose your information
When you interact with our website - Information on cookies
Your rights regarding your personal data
What happens when we link to other websites?
The changes we may make to this policy.
Information about us
We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws. We comply with the EU law retained version of the General Data Protection Regulation (2016/679), together with the UK Data Protection Act 2018 (the “Data Protection Legislation”). If any of these laws are replaced or superseded, we will also comply with that.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
What we may collect
Personal data, or personal information, is any information about an individual from which that person can be identified. It doesn’t include anonymous data, where the identity has been removed. We collect, use, store and transfer different kinds of personal data about you when you engage with us and we must have a legal ground (lawful basis) to do so.
Type of data
Purpose and Lawful Basis
Identity and contact information when you contact us, or you purchase our services (Personal Data)
Includes:
Name
Email address
Telephone number
Homework information, which may from time to time include sensitive information
Does not include:
Any details you choose to share with us relating to your pensions, investments, employment or financial situations which doesn’t identify you directly.
The purpose of collecting this information is so that we can respond to your correspondence and provide you with the services. If you contact us with a customer service issue, we may use your name and email address to send you information about your matter or issue raised and we may also provide you with updates on changes to this policy or security information.
When you work with us, we will ask you at times to complete homework tasks. It is completely your decision as to what information you share with us.
The lawful basis for collection of this information is to perform our contract with you (i.e., provide you with the services), it is in our legitimate interest and that you have consented (i.e., by contacting us or purchasing the services).
Identity information when you attend a live session over video conferencing
(Personal Data)
Includes:
Name
Your face and physical appearance as it appears on the screen.
Does not include:
Any details you choose to share with us relating to your pensions, investments, employment or financial situations which doesn’t identify you directly.
We conduct our group video sessions on Google Meet and we will record every live session. The purpose is to make the recordings available to all participants of our course (whether they were able to attend live or not), which participants can rewatch. Google Meet is compliant with Data Protection Legislation, however it is important to make you aware that the sessions will be recorded.
The lawful basis is to perform our contract with you (i.e., provide you with the services), it is in our legitimate interest to make the sessions available to everyone.
When you attend the session and you choose to display your real name and/or to leave your camera on and/or to disclose personal data during the session, you consent to do so. If you’re concerned, you can turn off your camera, avoid speaking or use a pseudonym.
Please note it is a requirement of our sessions, as stated within our terms and conditions, that all participants of the sessions should respect the privacy of each other and do not take photos and/or record the sessions at any time.
Information provided when you make a payment (Payment Details)
Includes:
Name
Email address
Telephone number
The last four digits of your debit/credit card number
Payments are processed via Stripe Inc. Their terms and conditions and privacy policy will apply to that payment so you should read these. We don’t have sight of your payment card details, besides the last four digits of the payment card and the type of card used (i.e. Mastercard Visa).
Identity and contact information when you sign up to receive our marketing or promotional materials (Marketing and Communications Data)
Includes:
Name
Email address
The purpose is to provide you with marketing and promotional material. The lawful basis for this is that you have provided your consent and it is in our legitimate interest to present relevant content, products, and services to you. You can withdraw your consent at any time by contacting us at gayatri@codeforcreatives.co.uk.
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 website
Other technology on the devices you use to access our website.
The purpose is to enable your access to our website. The lawful basis is this is necessary for us to perform our contract with you (i.e., to give you access to the service our website provides).
Cookies Data
Like many websites, we use "cookies" to enhance your experience and gather information about visitors and visits to our website. Please refer to the "Information on cookies" section below for information about cookies and how we use them and what kind.
Cookies are small text files placed on your device when you visit our website and are used to make the users’ experience more efficient.
The lawful basis is this is necessary for us to perform our contract with you (i.e., to give you access to the service our website provides).
We also need this information to study how you use our website, in order to improve and develop the services we provide, and better inform our marketing strategies.
Marketing and Communications Data
Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
The purpose is to enable direct marketing.
The lawful basis is that it is necessary for our legitimate interest to present relevant content, products, and services to you (only where you have provided your consent that we do so).
Analytics
Includes third-party analytics services (such as Google Analytics) to evaluate your use of our website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this policy.
The purpose is to enable direct marketing.
The lawful basis is that it is necessary for our legitimate interest to present relevant content, products, and services to you.
When you interact with our website - Information on cookies
We use cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the Data Protection Legislation.
Cookies are small text files placed on your device when you visit our website and are used to make the users’ experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of our website, however for non-essential cookies we need your permission. We use cookies to distinguish users and to improve our website. We analyse how you use our website, and we look at aggregate statistics about your usage, and how others use our website. We collect certain information from these cookies, and this includes information about your IP address, your location when you access our website, the date and time you access our website, the language you use and the type of browser you use.
We don’t track individual users or use cookies to identify individuals and we use cookies to recognise you and your preferences, improve our website's performance and collect analytical information for ourselves and our business partners. Without the knowledge gained from cookies, we wouldn’t be able to provide the service we do.
These are the types of cookies we use:
'Session cookies' allow us to track your actions during a single browsing session, but they don’t remain on your device afterwards; and
'Persistent cookies' remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our website.
Session and Persistent cookies can be either first or third party cookies. A first-party cookie is set by the website being visited; a third-party cookie is set by a different website. Both types of cookies may be used by us or our business partners.
The third-party cookies we use are:
Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information;
Facebook Ads (the Facebook pixel) – these cookies collect information about how visitors use our website. This data is collected anonymously and is used to help improve our website’s functionality;
Google Ads – these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality; and
Instagram Ads - these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality;
Other forms of social media advertising (including but not limited to ads run on YouTube and TikTok) - these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality.
All of our cookies are categorised by the role they fulfil on our website:
Strictly Necessary: these are essential to enable you to move around our website and use features such as secure services. Without these cookies such services could not be provided;
Functionality: allow our website to remember your choices and to personalise certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
Performance: collect information as to how users use our website. These cookies do not collect information that identifies a visitor. The information collected is aggregated and used to improve our website.
None of the cookies employed are classified as ‘Behavioural Targeting’.
We will always ask for your consent to use non-essential cookies. You’re free to withhold consent to this, but we might not be able to provide the full website experience to you, including some elements of video advertising. You can disable cookies at any time through the settings on your browser, or whenever the pop-up appears on our website (each time you access our website).
We may process your data for compliance with a regulatory requirement or legal obligation to which we’re subject to. Your data will only be processed if processing the data to comply with such obligation is a reasonable and appropriate way of achieving compliance.
We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does 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 policy.
How we store your personal data
We store all of your personal data on our servers within the United Kingdom. We may transfer your collected data to storage outside the European Economic Area (EEA) or the United Kingdom. It may be processed outside the EEA or the United Kingdom so that you may receive the services our website provides. If we do store or transfer data outside the EEA or the United Kingdom, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA or the United Kingdom. This means that sometimes we may need to use legally binding contract terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements.
Data security is very important to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through our website. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA or the United Kingdom. We regularly review our data retention obligations to ensure we’re not retaining data for longer than we’re legally obliged to.
How we disclose your information
We may disclose your information in the following cases:
If we want to sell our business, or our company, we can disclose it to the potential buyer;
We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006;
We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights; or
We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties/subcontractors to supply our services to you on our behalf. These include cloud services used to send emails and technology providers that assist in providing our services to you, such as the third party hosting platform we provide our services from.
Your rights
When you provide us with personal data, you have certain legal rights, and these include:
To request access to, deletion of or correction of your personal data held by us at no cost to you;
To request that your personal data be transferred to another person (data portability);
To be informed of what data processing is taking place;
To restrict processing;
To object to processing of your personal data; and
To complain to a supervisory authority.
If you wish to access, rectify, erase, or transfer your personal data, please contact us gayatri@codeforcreatives.co.uk.
What happens when we link to other websites?
As stated above, this policy only relates to our website and our services. We might have links on/within our website to other websites, which will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.
Please note that our terms and conditions and our policies won’t apply to other websites that you get to via a link from our website. We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Notice for California residents of privacy practises and rights
If you are a California resident, California law may provide you with additional rights regarding your personal data.
Your rights
The California Consumer Privacy Act of 2020 (“CCPA”) gives you the following rights:
Right to know about the personal information we collect and share:
The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you;
Please see above for information on the data we collect on you, and how we process it; and
We do not sell your personal information. However, we do disclose your personal data to limited third parties, as described above
Right of deletion:
You have the right to request that we delete your personal information, subject to certain exceptions
If you wish to delete your personal data, please contact us at gayatri@codeforcreatives.co.uk. Please note that we may require certain information from you in order to verify your identity before proceeding with your request.
Disclosures about your personal information
We collect the categories of personal information from you in connection with your use of our website as described above.
Non-discrimination
We will not discriminate against you for exercising any of your CCPA rights.
The changes we may make to this policy
We can update this policy from time to time as laws change or as our website changes. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.