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Privacy Policy

Introduction 

Welcome to the Schudio.tv privacy policy.  

Schudio Ltd (Schudio.tv) respects your privacy and is committed to  protecting your personal data. This privacy policy will inform you as  to how we look after your personal data when you visit our website  (regardless of where you visit it from) and tell you about your  privacy rights and how the law protects you.  

Please also use the Glossary below to understand the meaning of  some of the terms used in this privacy policy. 

Purpose of this privacy policy 

This privacy policy aims to give you information on how Schudio.tv  collects and processes your personal data through your use of this  website, including any data you may provide through this website  when you enrol as a student or subscriber (“learner”), sign up to our  newsletter or purchase a product or service.  

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

It is important that you read this privacy policy together with any  other privacy policy or fair processing 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. This privacy policy supplements other notices and  privacy policies and is not intended to override them.

Controller 

Schudio.tv is a product provided by Schudio Ltd who is the data  controller and responsible for your personal data (“Schudio.tv”,  “we”, “us” or “our” in this privacy policy). 

We have appointed a Data Protection Officer who is responsible for  overseeing questions in relation to this privacy policy. If you have  any questions about this privacy policy, including any requests to 

exercise your legal rights, please contact the Data Protection Officer  using the details set out below.  

Contact details 

If you have any questions about this privacy policy or our privacy  practices, please contact our Data Protection Officer in the following  ways: 

Darren Rose of DHR Consultancy 

Email address: Darren.rose@dhrconsultancy.co.uk 

Postal address: 50b Manchester Rd, Huddersfield, HD7 5JA 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 (www.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.  Changes to the privacy policy and your duty to inform us of  changes 

We keep our privacy policy under regular review. Historic versions  can be obtained by contacting us. Changes and updates to our  privacy policy will take effect immediately upon their posting on the  website. 

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. 

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. In  particular, payment gateways and other payment transaction  processors have their own privacy policies which we recommend  that you read.

The data we collect about you 

Personal data, or personal information, means any information  about an individual from which that person can be identified. It does  not include data where the identity has been removed (anonymous  data). 

We may collect, use, store and transfer different kinds of personal  data about you which we have grouped together as follows: 

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes 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, 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. 

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 products or services). In this case, we may have to cancel a 

product or service you have with us but we will notify you if this is  the case at the time.  

How is your personal data collected? 

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

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal  data you provide when you: 
  • purchase our products or services;
  • create an account on our website;
  • enrol as a student or subscriber;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We  collect this personal data by using cookies, server logs and  other similar technologies. We may also receive Technical  Data about you if you visit other websites employing our  cookies.  
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:  

Technical Data from the following parties: 

  1. analytics providers such as Google based outside the EU;
  2. social media platforms such as Facebook based outside the EU; and
  3. search information providers such as Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU. 
  • Usage Data and Technical Data from Thinkific Labs Inc based outside the EU.
  • Identity Data and Transaction Data from our third-party Content Partners based inside the EU.
  • Identity Data and Contact Data from your employer, where your employer has enrolled you on one or more of our courses or bought our products/services on your behalf. 

How we use your personal data 

We will only use your personal data when the law allows us to. Most  commonly, we will use your personal data in the following  circumstances:

  • Where we use your Consent as a lawful basis, you may withdraw consent at anytime however please note this may affect our ability to deliver the service effectively.  
  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • 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. 
  • Where we need to comply with a legal obligation.

See the Glossary below to find out more about the types of lawful  basis that we will rely on to process your personal data. 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways  we plan to use your personal data, and which of the legal bases we  rely on to do so. We have also identified what our legitimate  interests are where appropriate. 

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. 

Purpose/Activity  Type of  

data

Lawful basis for  

processing including  basis of legitimate  

interest

To register you as a  new customer, student  or subscriber (a)  

Identity  

(b)  

Contact

Art.6(1)(b) Performance of  a contract with you. 

Art.6(1)(a) Where you have  provided consent to the  processing of your  

personal data.

To process and deliver  your order including: 

(a) Manage payments,  fees and charges 

(b) Collect and recover  money owed to us

(a)  

Identity  

(b)  

Contact  

(c)  

Financial  

(d)  

Transactio n  

(e)  

Marketing  and  

Communi cations

Art.6(1)(b) Performance of  a contract with you.  

Art.6(1)(f) Necessary for  our legitimate interests (to  recover debts due to us).

 

To manage our  

relationship with you  which will include: 

(a) Notifying you about  changes to our terms or  privacy policy 

(b) Asking you to leave  a review or take a  

survey 

(c) Updating you about  course content or your  course progress 

(d) Adding you to one  or more communities  within the Community  section of this website

(a)  

Identity  

(b)  

Contact  

(c) Profile  

(d)  

Marketing  and  

Communi cations

Art.6(1)(b) Performance of  a contract with you.  

Art.6(1)(c) Necessary to  comply with a legal  

obligation. 

Art.6(1)(f) Necessary for  our legitimate interests (to  keep our records updated  and to study how  

customers use our  

products/services) 

Art.6(1)(a) Where you have  provided consent to the  processing of your  

personal data.

 

To enable you to  

partake in a prize draw,  competition or complete  a survey

(a)  

Identity  

(b)  

Contact  

(c) Profile  

(d)  

Usage  

(e)  

Marketing  and  

Communi cations

Art.6(1)(b) Performance of  a contract with you  

Art.6(1)(f) Necessary for  our legitimate interests (to  study how customers use  our products/services, to  develop them and grow our  business) 

Art.6(1)(a) Where you have  provided consent to the  processing of your  

personal data.

To administer and  

protect our business  and this website  

(including  

troubleshooting, data  analysis, testing,  

system maintenance,  support, reporting and  hosting of data)

(a)  

Identity 

(b)  

Contact 

(c)  

Technical

Art.6(1)(f) 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) 

Art.6(1)(c) Necessary to  comply with a legal  

obligation

 

To deliver relevant  

website content and  advertisements to you  and measure or  

understand the  

effectiveness of the  advertising we serve to  you

(a)  

Identity  

(b)  

Contact  

(c) Profile  

(d)  

Usage  

(e)  

Marketing  and  

Communi cations  

(f)  

Technical

Art.6(1)(f) 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) 

Art.6(1)(a) Where you have  provided consent to the  processing of your  

personal data.

To use data analytics to  improve our website,  products/services,  

marketing, customer  relationships and  

experiences

(a)  

Technical  (b) Usage

Art.6(1)(f) 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) 

Art.6(1)(a) Where you have  provided consent to the  processing of your  

personal data.

 

To make suggestions  and recommendations  to you about goods or  services that may be of  interest to you (a)  

Identity  

(b)  

Contact  

(c)  

Technical  

(d)  

Usage  

(e) Profile  

(f)  

Marketing  and  

Communi cations

Art.6(1)(f) Necessary for  our legitimate interests (to  develop our products/ 

services and grow our  business) 

Art.6(1)(a) Where you have  provided consent to the  processing of your  

personal data.

 

Marketing  

We strive to provide you with choices regarding certain personal  data uses, particularly around marketing and advertising. We have  established the following personal data control mechanisms: Promotional offers from us  

We may use your Identity, Contact, Technical, Usage and Profile  Data to form a view on what we think you may want or need, or  what may be of interest to you. This is how we decide which  products, services and offers may be relevant for you (we call this  marketing).  

You will receive marketing communications from us if you have  requested information from us or purchased products or services  from us and you have not opted out of receiving that marketing via  the unsubscribe link in the bottom of the email. 

Third-party marketing 

We will get your express opt-in consent before we share your  personal data with any third party for marketing purposes.  

Opting out 

You can ask us or third parties to stop sending you marketing  messages at any time by logging into the website and checking or  unchecking relevant boxes to adjust your marketing preferences, by  following the unsubscribe links on any marketing message sent to  you, or by contacting us at any time.  

Where you opt out of receiving these marketing messages, this will  not apply to personal data provided to us as a result of a product/ service purchase, product/service experience or other transactions. Change of purpose  

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, prior to carrying out any processing activities for the new  purpose. 

Disclosures of your personal data 

We may share your personal data with the parties set out below for  the purposes set out in the table (‘Purposes for which we will use  your personal data’) above. 

  • External third parties including:

Service providers acting as processors based inside and  outside the EU including Xero (accounting software),  Zapier (customer form integration tool) and Instiller (email  marketing tool).

Professional advisers including lawyers, bankers,  auditors, insurers and accountants (including Brooks  Accountants) based in the United Kingdom who provide  consultancy, banking, legal, insurance and accounting  services. 

HM Revenue & Customs, regulators and other authorities  based in the United Kingdom who require reporting of  processing activities in certain circumstances. 

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a  change happens to our business, then the new owners may  use your personal data in the same way as set out in this  privacy policy.  

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. International transfers 

We share your personal data with Thinkific Labs Inc (Thinkific).  Thinkific hosts this website and provides us with the online course  creation platform that allows us to sell our product/services to you  and to provide the Community section of this website. Thinkific are  based in Canada and so this will involve transferring your data  outside the United Kingdom. We may also share your personal data  with other third parties based outside of the United Kingdom.  Whenever we transfer your personal data out of the United  Kingdom, as required under the Data Protection Act 2018, 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 by the United Kingdom. The United Kingdom  recognises Canada as providing adequate protection. 
  • Where we use certain service providers, we may use specific contracts approved by the United Kingdom and European Union which give personal data the same protection it has in  the United Kingdom.  

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

Payment: 

If you make a purchase on our website, we use a third-party  payment processor such as Stripe or Paypal. Payments are  encrypted through the Payment Card Industry Data Security  Standard (PCI-DSS). Your purchase transaction data is stored only  

as long as is necessary to complete your purchase transaction. Data security 

We have put in place appropriate security measures to prevent your  personal data from being accidentally lost, used or accessed in an  unauthorised way, altered or disclosed. In addition, 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.  

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. Data retention 

How long will you use my personal data for? 

We will only retain your personal data 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. 

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 tax purposes. In some circumstances you can ask us to delete your data: see  ‘Your legal rights’ below for further information. 

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.  

Your legal rights 

Under certain circumstances, you have rights under data protection  laws in relation to your personal data. These rights are as follows: 

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.Request transfer of your personal data.
  • Right to withdraw consent.
  • Right to make a complaint.

If you wish to exercise any of the rights set out above, please  contact our Data Protection Officer.  

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 but  without reasonable delay. 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 within the first  month of its complex nature and process it without undue delay. Glossary 

LAWFUL BASIS 

Legitimate Interest means the interest of our business in  conducting and managing our business to enable us to give you the  best service/product and the best and most secure experience. We  make sure we consider and balance any potential impact on you  (both positive and negative) and your rights before we process your  personal data for our legitimate interests. We do not use your  personal data for activities where our interests are overridden by  the impact on you (unless we have your consent or are otherwise  required or permitted to do so by law). You can obtain further  information about how we assess our legitimate interests against  any potential impact on you in respect of specific activities by  contacting us. 

Performance of Contract means processing your data where it is  necessary for the performance of a contract to which you are a  party or to take steps at your request before entering into such a  contract. 

Comply with a legal obligation means processing your personal  data where it is necessary for compliance with a legal obligation  that we are subject to. 

With your Consent to process your personal data. Your consent  will be informed and freely given via an explicit action such as  clicking on a sign-up button, and maybe withdrawn at any time.

YOUR LEGAL RIGHTS 

You have the right to: 

Request access to any personal data relating to you (commonly  known as a “data subject access request”). This enables you to  receive a copy of the personal data we hold which relates to you,  allowing you 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. 

16/09/2021 – Schudio Ltd (SchudioTV) – Privacy Policy v3 final

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