Privacy Policy

This Privacy Policy describes the data protection practices of CREW ROOM ACADEMY LTD (collectively referred to as “Crew Room Academy,” “us,” “we,” or “our”). This Privacy Policy applies to information that we collect and use about you when you access or use Site, apps, and other products and services (collectively “Services”).

CREW ROOM ACADEMY LTD is the controller and responsible for your Personal Data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, but for features or Services related to the Content Offerings, Personal Data is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, “Personal Data” (also referred to as “personally identifiable information” or “personal information”). Personal Data 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). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things.

We collect information about you through the means discussed below. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.

You are responsible for ensuring the accuracy of the Personal Data you submit to Crew Room Academy. 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. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

We keep our Privacy Policy under regular review. We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your user account.

We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

Our Site 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.

1.
What Information We Collect and How It is Collected
When you come to our Site and access our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
– The Services you access
– Requests or questions you submit to us via online forms, email, or otherwise
– Your participation in surveys
– Any reviews that you submit about the Services
– Account registration and administration of your account
– Uploads or posts to the Services
– Requests for customer support and technical assistance

While parts of the Site may not require you to provide any information that can directly identify you by name (such as if you choose to browse the Site without logging in), the specific types of information we collect will depend upon the Services you access and use, how you use them, and the information you choose to provide. We use different methods to collect data from and about you including through:

Direct interactions. The types of data we collect directly from you includes:
– Email address
– Name, Surname
– Log-in credentials, if you create an account
– Information about your customer service interactions with us
– Demographic information such as your age, race, ethnicity, gender etc.
– User-generated content you provide to us, such as when you comment on content on the Services, respond to a survey request, or participate in the public forums
– Any other information you choose to directly provide to us in connection with your use of the Services
We collect Personal Data that you provide to us when you register for an account, update or change information for your account, access our Services, complete a survey, sign-up for email updates, send us email messages, give us feedback, participate in Content Offerings or other Services on our Site. We may use the Personal Data that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other events, and send you email messages about Site maintenance or updates.
Automated technologies or interactions. When you use our Site, we may track, collect, and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience. We may also use cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to our Cookie Policy.
Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources. If you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook or Twitter), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information disclosed, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services; you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.
For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

We may receive additional information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device. 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. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, promotional partners, and sponsors. 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

2.
No Information from Children Under 13
We strongly believe in protecting the privacy of children. The Site and the Services are not intended for children under the age of 13. Any use or access by anyone under the age of 13 is prohibited. We do not knowingly collect or maintain Personal Data on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner.
If we become aware that we have inadvertently collected Personal Data from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible.

3.
How We Use Your Personal Data
We will only use your Personal Data when the law allows us to. The legal bases for using your Personal Data as set out in this Privacy Policy are as follows:
– Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the Terms of Use which you accept by browsing the Site/registering; and/or our contract to provide our Services to you).
Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Site and applications; operate our business and our Services; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services).
– Where we need to comply with a legal obligation.
– Where we have your consent, in accordance with applicable law. We may process your Personal Data in some cases for marketing purposes on the basis of your consent which you may withdraw at any time. If we rely on your consent for us to use your Personal Data in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.
See the Lawful Basis below to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We, or our service providers, use your Personal Data for various purposes depending on the types of information we have collected from and about you, in order to:

– Access the Site and provide the Services
provide the Services you have requested
provide Content Offerings
– Communicate with you and provide support
Respond to your request for information and provide you with more effective and efficient customer service
Provide you with updates and information about our Services
– Marketing and content customization
Contact you by email, postal mail, or phone regarding Crew Room Academy and third-party products, services, surveys, research, promotions, special events and other subjects that we think may be of interest to you
Customize the advertising and content you see on the Services
– Business operations
Help us better understand your interests and needs, and improve the Site and Services
Provide technical support to you, secure our Site and applications, and resolve app crashes and other issues being reported
– Legal Purposes
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the Lawful Basis 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 Personal 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 user	(a) Identity (b) Contact	Performance of a contract with you to provide the Services
To deliver the Services	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to run, grow and develop our business)
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	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use our site and services)
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 Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how users use our services, to develop them and grow our business)
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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) (b) 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 Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

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.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.
Disclosures of Personal Data
We may share your Personal Data with the parties set out below. Please note that 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.

– We may disclose your Personal Data we collect within our group of companies to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.
– We provide access to or disclose your Personal Data to select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your Personal Data for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, consultancy, banking, legal, insurance and accounting services.
– 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.
– Certain features of our Services make it possible for you to post comments publicly that other users can see. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.

5.
Data Retention
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.

6.
International Transfers
We do not transfer your Personal Data outside the European Economic Area (EEA).

7.
Data Security
We will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. 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. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.

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.

8.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:

You have the right to:

– Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and 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 Personal 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.

If you wish to exercise any of the rights set out above, please contact us.

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.

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.

We try to respond to all legitimate requests within one month. 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 and keep you updated.

9.
Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

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

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Please note that even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you.

10.
Questions, Suggestions, and Complaints
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights please contact us using the details set out below.

Email address: Contact@CrewRoomAcademy.com

Postal address: Crew Room Academy, Coach Road Cottages, Little Saxham, Bury St Edmunds., Suffolk, IP29 5LE, England

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.

Cookie Policy

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

Cookies enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.

We use the following cookies:

– Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
– Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
– Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
– Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

Except for essential cookies, all cookies will expire after 24 hours.