SkyAcamesis Limited, a company registered in England and Wales with company number 10939992 and its registered office at Chancery Station House, 31-33 High Holborn, London, England, WC1V 6AX (Sky Acamesis, we or us) is committed to protecting and respecting your privacy.
For the purpose of the EU GDPR, the version of the General Data Protection Regulation as implemented by the United Kingdom and the Data Protection Act 2018, we act as a controller in relation to personal data that we collect from you.
Information we may hold about you
We may collect and process the following data about you:
- Information you give to us. You may give us information about you by filling in formsor questionnaires on our service, by corresponding with us by phone, email, social media or otherwise, and by participating in our courses or discussions or groups or Q&As. This includes information you provide when you register to use our service or subscribe to a course, or participate in other parts of our service, or provide testimonial or weekly wins posts or information.
- The information you give us may include your name, address, email address and phone number, financial and credit card information, personal description, data about your health and any other information you provide.
With regard to each of your visits to our service, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile phone to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- location data to determine your current location, some of our location-enabled services require your personal data for the feature to work;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our service (including date and time); pages within our service you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We may receive information about you if you use any of the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our service.
We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers) and may receive information about you from them.
Google Analytics or other software will be used in order to help us understand how our users interact with our service. The information gathered from this service is anonymous, but will ultimately help us shape a better user experience for our customers.
In the course of providing our service to you, we may collect information that is considered “special category data” for example you may provide health data when we ask you to complete questionnaire(s) or when you contribute to courses or discussions.
We will only use your health data with your explicit consent. However, as the nature of some of our services includes comprehensive assistance with your health, training and nutrition, we are unable to provide some of our services to you if you do not consent to us using your health data. Accordingly, where we need to process your health data in order to provide the services you wish to receive, you will be required to provide an explicit consent to our processing of your special category health data. For the avoidance of doubt, we can provide some of our services without processing your health data, and providing your consent will not be required in order for you to receive those services.
How do 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 where it is necessary in order for us to perform our contract with you, or necessary for our legitimate interests (or those of a third party), and your interests, rights and freedoms do not override those interests, or where we need to comply with a legal or regulatory obligation.
We will use your personal data in the following ways, on the legal bases that it is necessary for us to perform our contract with you and for our legitimate interests (or those of a third party), and that your interests, rights and freedoms do not override those interests:
- we will provide you with access to our service (including your participation in live courses, your accessing of online courses and training, and your purchase of other products) and the ability to register as a new service user, including granting you access, allowing you to access all of the services we agree to provide to you;
- we will carry out any other obligations arising from the contract entered into between us and you, including processing payments, fees and any charges, and providing you with customer support;
- we will administer and protect our business and our service including troubleshooting, data analysis and system testing;
- we may send you direct marketing communications in relation to similar products or services that we think may be of interest to you (provided that you have an absolute right to opt-out of any of these communications at any time, including at the time of providing us your personal data or at any time thereafter); and
- we will use your personal data to regularly update and rectify any personal data we hold in relation to you and to notify you of any changes to our service or any other services.
Generally, we do not rely on consent as a legal basis for processing your personal data, provided that we will get your consent before sending any third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes or for educational, training and monitoring or customer service purposes, in which case we may use this information indefinitely without further notice to you.
Disclosure of Your Information
We may share your personal information with any member of our company, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected external third parties, including marketing providers, hosting providers, and other third party providers that we use for the purposes of carrying out our obligations and exercising our rights.
We may disclose your personal data:
- if we sell or buy any business or assets, to the prospective seller or buyer of such business or assets:
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our agreement with our customers, or to protect the rights, property, or safety of Sky Acamesis, our customers, or others.
Third Party Links
Our service may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
Where We Store Your Personal Data
The data that we collect from you is stored in a destination within the UK or the European Economic Area (EEA).
If you are a UK citizen based in the UK or an EU citizen based in the EEA, then whenever we transfer your personal data out of the UK or the EEA, we will only transfer your personal data:
- to countries that have been deemed to provide an adequate level of protection for personal data;
- if we have put in place specific contracts approved for use in the UK and/or EEA which give personal data the same protection it has in the UK/EEA;
- if another appropriate safeguard has been put in place; or
- if one of the exceptions under Article 49 of the GDPR applies.
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 particular:
- we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know; and
- all personal data is stored on secure 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. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our service, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
If we have given you (or where you have chosen) a password which enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How Long We Keep Your Personal Data
We will retain your personal data in line with our data retention policy. 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.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at firstname.lastname@example.org.
You have various statutory rights in relation to your personal data. In particular, you have the right to:
- object to direct marketing communications at any time;
- request and obtain access to your personal data;
- rectification or erasure of your personal data, in certain circumstances;
- object to or restrict the processing of your personal data in certain circumstances;
- have your personal data stored in a manner in which it is portable from the environment in which it is stored by us to another environment; and
- file a complaint with the Information Commissioner’s Office.
We reserve the right to request that you provide evidence of your identification if you ask us to carry out any steps in relation to your personal data.