Introduction

Welcome to the General Privacy Notice relating to the NailKnowledge Online Courses. NailKnowledge is a service provided by Professional Animated Learning Limited.

Professional Animated Learning Limited respects your privacy and is committed to protecting your personal data. This Privacy Notice 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.

1. Important information and who we are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Professional Animated Learning Limited (“PAL”) collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase goods or courses or other services from us, or take part in competitions.

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 Notice together with:

• Any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you; and
• Our Cookies Policy.

This will mean that you are fully aware of how and why we are using your data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.

Controller

Professional Animated Learning Limited is the controller and responsible for your personal data (collectively referred to as “PAL”, “we”, “us” or “our” in this Privacy Notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise Your legal rights, please contact the data privacy manager using the details set out below.

Contact details 

If you have any questions about this Privacy Notice or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: PAL Limited

Email address: [email protected].

Correspondence address: Unit 50, Faraday Business Park, Faraday Road, Plymouth, PL4 0ST

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review. This version was last updated on 15/01/2021. Historic versions can be obtained by contacting us.

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

The 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 policies. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

2. 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 and Contact Data We collect personal contact information such as your name, address, contact details including your e-mail address, mobile number and other provided contact details. We also collect personal data from other sources including :-
• any forms you fill in at any time,
• over the telephone;
• competition entries; and
• other companies and businesses which have your permission to share your personal data with us and others from time to time

We retain your emails as part of our records and may use the information for the purposes set out in this Privacy Notice.

• Transaction Data and Telephone Calls includes details about the products and services you have purchased from us. We may record any telephone calls for :
• ensuring that you receive good customer service from us;
• to enable us to train our staff and improve services to you;
• to establish, record and be able to prove the contract made between us over the telephone.
• 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 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 Notice.

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 goods 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.

3. 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 and Contact Data, Telephone Calls records and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. We use cookies to improve the performance of our site and give you the best experience we can. Cookies are small files, placed onto your device’s memory, or hard drive when visiting most websites. They help the site ‘remember’ if you’ve been there previously. In some cases it means it can put on screen things of interest to you. We use cookies for these types of activity:
• Experience – to track visitors on our website (where they’ve come from, how long they stay and what they look at when on our site). Security – to protect your personal data and prevent fraudulent activity;
• Choices – during our signup process these allow you to choose and order our services. Marketing – to see how our campaigns are working. This helps us improve our website design, experience and offers. Information – we may use third parties to collect anonymous user information, sometimes through cookies and web beacons;
• Video – Flash cookies which assist media player functionality without which some video content may not render correctly.

Note: Our cookies don’t store financial information, or personal details, e.g. your name or address.

You can turn cookies off but if you do this you may not be able to use all services on our websites and you might see more pop-ups and other intrusive advertising, as we won’t be able to limit what you see using cookies. You may be able to use some of the site. Some of the cookies are set by business partners (e.g. analytics companies) to track and collect browsing behaviour Others are used to show specific content to you. (We don’t control how these cookies are set). If you register for our website, turning off cookies will mean you cannot use this service.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
• analytics providers;
• advertising networks;
• search information providers;
• Contact Data and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. 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 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.

Please refer to the Glossary 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.

Purposes for which we will use your personal data

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 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	(a) Identity and Contact Data, (b) Profile Data	Performance of a contract with you
To process and deliver your order	(a) Identity and Contact Data, (b) Profile Data, (c) Transaction Data and Telephone Calls, (d) Marketing and Communications Data	(a) Performance of a contract with you, (b) Necessary for our legitimate interests (to track orders and payments)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Notice (b) Asking you to leave a review or take a survey	(a) Identity and Contact Data, (b) Profile Data, (c) Marketing and Communications Data	(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 customers use our products/services)
To enable you to partake in a competition, event or complete a survey	(a) Identity and Contact Data, (b) Profile Data, (c) Usage Data, (d) Marketing and Communications Data	(a) Performance of a contract with you, (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity and Contact Data, (b) Profile Data, (c) Technical Data	(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 and Contact Data, (b) Profile Data, (c) Usage Data, (d) Marketing and Communications Data, (e) Technical Data	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)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical Data, (b) Usage Data	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)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity and Contact Data, (b) Technical Data, (c) Usage Data, (d) Profile Data, (e) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

Where you have given your consent to marketing we will send you our marketing and promotional materials for services, products, surveys, competitions, events and other activities we think useful to you.

We (and third parties service providers under contract with us) use customer contact information to personalise the types of information you receive from us, to determine customer satisfaction with products and/or services we have provided and to improve the operation of our services to you.

We may combine or match data your personal data for internal business purposes including aggregating information, cross matching and pooling data for effective data management, to understand your needs, improve security, devising, deploying and measuring marketing campaigns and other similar and reasonable business purposes.

We use online behavioural advertising (OBA) which allows us to deliver targeted advertising to visitors. As you browse our site, some of the cookies used are advertising cookies, so we can understand what sort of pages you are interested in. It then generates adverts which we believe may interest you based on your use of our site. The OBA techniques we use will not collect personal information such as your name, email address, postal address or phone number.

We may also share anonymised behavioural data with advertising partners. This may mean that when you are on other websites, you will be shown advertising based on your behaviour on our website. We may also show you advertising on our site based on your behaviour on other sites you have visited and where you appear to have given permission. This is known as behavioural retargeting and is another form of OBA that allows us and some of our advertising partners to show you ads based on your browsing patterns and interactions with other sites. You can opt out of this form of marketing, but you will still see adverts when you visit our site, they just will not be personal for you

You can withdraw your consent to any marketing at any time by writing to us at the address in the Contact Us section.

Other internal business purposes

We will also use it for internal business purposes including effective data management, to understand your needs, improving security of data, for statistical analysis, devising, deploying and measuring marketing campaigns and for such and other reasonable business purposes and operational efficiency improvement.

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 above.

• External Third Parties:
• Service providers including UKFast.Net Ltd (based in the UK) as our internet hosting company providing our access and security protection for the data held on its server(s), WordPress (Aut O’Mattic A8C Ireland Ltd.) (based in Ireland and the USA) for our website platform, and HubSpot, Inc. (based in Ireland and the USA) providing us with customer relationship management and marketing services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors 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 Notice and we will endeavour to inform you as soon as possible of any such change.

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.

5. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, 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; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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

6. 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.

7. 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.

In some circumstances you can ask us to delete your data: see the Glossary 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.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

• 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.

More information relating to these rights can be found in the Glossary. If you wish to exercise any of the rights set out above, please contact us.

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. 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. Glossary

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 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.