We know that the handling of your personal data is important to you. For this reason, we take the greatest possible care when handling your personal data and thus ensure a high level of data security. We respect the personal rights of our customers and are aware of the importance of protecting the personal data we receive from you.

With this privacy policy, we Keynance Learning Ltd (hereinafter “Keynance” or “we”) would like to inform you about all data protection aspects concerning the collection, storage and use of your personal data when using our website http://www.keynance.com (the “Website”).

We will only collect, process, and use your personal data in accordance with the UK`s Data Protection Act (“DPA”), the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”)/ California Privacy Rights Act (“CPRA”) and of course as described in this privacy policy.

Personal data in this sense are all individual details about personal or factual circumstances of an identified or identifiable natural person, such as your name, your telephone number, your email address, social media login data and other information that you provide to us when you use our offers by you or contact us about you.

Person responsible for data processing

The data controller within the meaning of the DPA and the GDPR is:

Keynance Learning Ltd

Address: Ground Floor 5, The Pavilions, Cranmore Dr, Shirley, Solihull B90 4SB

Web: http://www.keynance.com

E-mail: info@keynance.com 

Facebook: https://www.facebook.com/Keynance-Learning-107749202029981/

YouTube: https://www.youtube.com/channel/UC2dqD5TBuhYlDEsdR77diYg

Instagram: https://www.instagram.com/kleberkeynance/

LinkedIn: https://www.linkedin.com/in/kleber-hernandez-cfa-9ba09310/

Collection and storage of personal data as well as type and purpose of their use

a) processing of data for the use of the website

When you access the website via your browser, we only collect personal data that your browser or mobile device automatically transmits to us in order to enable you to visit our website and to ensure stability and security. These can be in particular:

Your IP address, Your device identification, i.e., the unique number of the end device, the content, date, and time of the request, the time zone of the requesting computer or mobile device, the website from which the request was forwarded, the requested page, the HTTP status code, the amount of data transferred, browser ID, your operating system, language and version of the browser software.

We process this data to ensure a seamless connection to our website, display our services and listings, enhance the usability of our services, evaluate and maintain system security and stability, and for other administrative purposes.

We process the transmitted data strictly for the intended purpose, for a period of 90 days, in the interest of being able to detect, limit and eliminate attacks on our websites. After this period has expired, we delete or anonymise the IP address, unless there are separate legal obligations to store it. The legal basis for this processing of your personal data is Art. 6 (1) f) GDPR.

b) processing of data when you are contacting us

We offer you the possibility to contact us, we process the following data from you for the purpose of processing and handling your enquiry: name, contact details -if provided by you- and your message.

When you use our WhatsApp chat feature, we collect and process certain personal data when you engage in the Chat. This may include your name, phone number, chat history, and any other information you provide during the conversation. The collected data is processed for the purpose of facilitating communication, addressing your inquiries or support requests, and providing a personalized experience. The processing of your personal data is based on our legitimate interest in responding to your inquiries and providing effective support.

The legal basis of the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations in accordance with Art. 6 (1) b) GDPR and/or our legitimate interest in processing your enquiry in accordance with Art. 6 (1) f) GDPR.

c) Thinkific

Our courses are hosted by Thinkific Labs Inc. The Thinkific platform provides the learning environment and offers the corresponding sales interface. In accordance with Thinkific`s Privacy Policy, your data is stored at Thinkific, in their databases and applications on a secure server with up-to-date security standards.

When you make a payment the transaction is processed by Thinkific and its third-party providers, Stripe or Paypal. The payment transactions are encrypted by the “Payment Card Industry Data Security Standard (PCI-DSS)” and your payment data will be stored only as long as it takes to complete your order. In accordance with Thinkific`s Privacy Policy, all direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

d) processing of data for contract fulfilment and data management

We process various data within the framework of the provision of our services, workshops, and coaching sessions as well as for the initiation and processing of the existing contractual relationship between you and us. If you have commissioned us to provide a service, we process your data (if provided: Name, contact details) and all information that is necessary in the context of fulfilling the services, exclusively for the purpose of processing and handling the contractual relationship. Accordingly, the data is processed on the basis of Art. 6 (1) b) GDPR as well as to fulfil our legal obligations pursuant to Art. 6 (1) c) GDPR.

e) processing of data for administration and financial accounting

We may also process your personal data in the context of administrative tasks as well as the organisation of our operations, financial accounting and compliance with legal obligations, such as archiving Art. 6 (1) c) GDPR. In this regard, we process the same data that we process in the course of providing our contractual services Art. 6 (1) b) GDPR.

f) Tryineract

To conduct quizzes design we use Tryineract provided by The Quiz Collective, Inc. We have no knowledge about the type and scope of processing or the duration of storage by Tryinteract. The legal basis for this processing is our legitimate interest according to Art. 6 (1) f) GDPR to establish better profitability of our offers via individually generated marketing measures.

g) YouTube

On our website, we implement videos from the video portal “YouTube” of the company Google Inc.

In doing so, we use the “extended data protection mode” option provided by Google. When you call up a page that has an embedded video, a connection is established to Google’s servers and in the process the content is displayed on the website by notifying your browser. According to Google’s information, in “extended data protection mode” your data – in particular which of our Internet pages you have visited as well as device-specific information including the IP address – is only transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission.

If you are logged in to Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your member account before visiting our website.

h) processing of data for our newsletter

To receive our newsletters, users must register themselves. This involves providing their email address and name and clicking on the “Subscribe” button. In order to ensure the accuracy of the subscription and obtain explicit consent, a confirmation email is sent immediately after registration. To complete the newsletter subscription process, users must confirm their intent to subscribe by clicking on the confirmation link included in the email. This double opt-in method guarantees that only those who have willingly registered and confirmed their subscription receive our newsletters.

The personal data collected in the context of a registration for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The processing of your e-mail address is thus based exclusively on your consent. You can revoke this consent at any time. To revoke your consent simply use the unsubscribe option at the bottom of every newsletter or by contacting us using info@keynance.com.

The newsletter is sent using ConvertKit of ConvertKit LLC. The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on ConvertKit’s servers in the USA. ConvertKit uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, ConvertKit may use this data to optimise or improve its own services, e.g., to technically optimise the dispatch and display of the newsletters or for economic purposes in order to determine from which countries the recipients come. However, ConvertKit does not use the data of our newsletter recipients to write to them or to pass it on to third parties.

i) processing of data for Quiz Completion

Users may provide their email addresses by completing a quiz embedded on our home page. We collect these email addresses to send relevant information, technical content, and offers related to our courses. The quiz responses may also be used to tailor our content and offerings to better suit user interests and preferences.

The Quiz Completion is sent using ConvertKit of ConvertKit LLC. The email addresses of our recipients, as well as their other data described in this notice, are stored on ConvertKit’s servers in the USA. ConvertKit uses this information to send and evaluate the Quiz Completion on our behalf. Furthermore, according to its own information, ConvertKit may use this data to optimise or improve its own services, e.g., to technically optimise the dispatch and display of the Quiz Completion or for economic purposes in order to determine from which countries the recipients come. However, ConvertKit does not use the data of our recipients to write to them or to pass it on to third parties.

The processing of your e-mail address is thus based exclusively on your consent. You can revoke this consent at any time. To revoke your consent simply by contacting us at info@keynance.com. Please note that upon revocation of consent, you will not receive further updates or communications related to our courses or services.

j) processing of data for eBooks Download

Users who download our eBook available on our website may be asked to provide their email addresses. We collect this information to deliver the eBook and to send users updates, technical content, and offers related to our courses. The email addresses collected during eBook downloads may also be used to provide personalized recommendations and course suggestions based on user interests.

The ebooks is sent using ConvertKit of ConvertKit LLC. The email addresses of our recipients, as well as their other data described in this notice, are stored on ConvertKit’s servers in the USA. ConvertKit uses this information to send and evaluate the ebooks on our behalf. Furthermore, according to its own information, ConvertKit may use this data to optimise or improve its own services, e.g., to technically optimise the dispatch and display of the ebooks or for economic purposes in order to determine from which countries the recipients come. However, ConvertKit does not use the data of our recipients to write to them or to pass it on to third parties.

The processing of your e-mail address is thus based exclusively on your consent. You can revoke this consent at any time. To revoke your consent simply by contacting us at info@keynance.com. Please note that upon revocation of consent, you will not receive further updates or communications related to our courses or services.

Use of personal information

Keynance uses personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

1. To provide our services to you: We may use your personal information to provide our Services to you.
2. To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
3. To protect our Services: We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
4. To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
5. To respond to user inquiries/offer support to users: We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
6. To send you marketing and promotional communications: We and/or our third-party partners may use the personal information you send to us for our marketing and promotional purposes. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us.

We collect personal information, including email addresses, first names, and last names, for all the above-mentioned purposes including but not limited to marketing and promotional purposes, quiz completions, and ebook downloads. Users have the option to unsubscribe and withdraw their consent from our marketing or promotional emails at any time by clicking the unsubscribe button provided at the bottom of each email.

We may offer free live events open to all individuals who subscribe to them. By subscribing to our live events, you consent to receive marketing, promotional, and informational emails about our program and courses. These communications are intended to offer further information and opportunities beyond the live event. By subscribing to our live events, you agree and acknowledge that your personal data, including your name and email address, will be used for the purposes stated herein and will be shared with third parties for related marketing purposes.

You have the option to unsubscribe from these marketing at any time by utilising the unsubscribe button provided at the bottom of each email.

Transfer of your data to order processors and third parties

In order to process your data, we use special external service providers such as the credit institution entrusted with payment processing, online marketing providers, providers of marketing solutions, providers of web analysis tools and IT service providers. These are carefully selected and commissioned by us, are bound by our instructions, and are regularly monitored.

Duration of storage

We store your personal data for as long as necessary to achieve the respective storage purpose. Afterwards, your data will be deleted by us, unless we are obliged to store it for a longer period of time according to Art. 6 (1) c) GDPR due to tax, commercial or other legal storage or documentation obligations, or you have agreed to storage beyond this period according to Art. 6 (1) a) GDPR.

Data security

We use technical and organisational security measures to ensure that your personal data is protected against loss, incorrect modification, misuse, or unauthorised access by third parties. The security measures are constantly adapted to the improved technical possibilities. All data exchanged between your computer and us over the Internet is encrypted with 256-bit. The encryption is done with SSL technology. This is a technology that encrypts all of your personal data, including your credit card information and other payment information, in such a way that this data cannot be viewed by any unauthorised third party while the data is being transmitted over the Internet. You can recognise the transmission of encrypted data by the display in your browser. Your browser indicates the security of the website by an icon in the form of a padlock or a key in the status bar at the bottom of the window. In addition, a green bar will be displayed in your browser bar to show you that you are connected to our server and can be sure that your data will not end up on a phishing server. If your browser is configured appropriately, you will receive a warning message the first time you access the website. This simply informs you that your data will be protected by the website.

Disclosure of data

In general, and unless otherwise mentioned in this policy, we will not share your data. However, if we do so we will only pass on your personal data to third parties if:

you have given your express consent to this in accordance with Art. 6 (1) a) GDPR, this is legally permissible and necessary for the fulfilment of a contractual relationship with you according to Art. 6 (1) b) GDPR, if there is a legal obligation for the disclosure according to Art. 6 (1) c) GDPR, the disclosure is necessary in accordance with Art. 6 (1) f) GDPR for the protection of legitimate business interests and for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data.

If we commission third parties with the processing of personal data, this is done on the basis of a contract processing agreement in accordance with Art. 28 of the GDPR.

Third-Party Websites

The Website may contain third-party links or websites like Thinkific, Interact Quiz, Convert Kit, WhatsApp, WordPress, etc. We cannot guarantee the safety and privacy of the data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Website. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

WE HEREBY DISCLAIM LIABILITY FOR, ANY INFORMATION, MATERIALS, PRODUCTS, OR SERVICES POSTED OR OFFERED AT ANY OF THE THIRD-PARTY SITES LINKED TO THIS WEBSITE. BY CREATING A LINK TO A THIRD-PARTY WEBSITE, WE DO NOT ENDORSE OR RECOMMEND ANY PRODUCTS OR SERVICES OFFERED OR INFORMATION CONTAINED ON THAT WEBSITE, NOR ARE WE LIABLE FOR ANY FAILURE OF PRODUCTS OR SERVICES OFFERED OR ADVERTISED AT THOSE SITES. SUCH A THIRD PARTY MAY HAVE A PRIVACY POLICY DIFFERENT FROM THAT OF OURS AND THE THIRD-PARTY WEBSITE MAY PROVIDE LESS SECURITY THAN THIS SITE.

Your data subject rights

a) Information

Upon request, we will provide you at any time and free of charge with information about all personal data that we have stored about you.

b) Correction, deletion, restriction of processing (blocking), objection.

If you no longer agree with the storage of your personal data or if this data has become incorrect, we will arrange for the deletion or blocking of your data or make the necessary corrections (insofar as this is possible according to the applicable law) on the basis of a corresponding instruction. The same applies if we are only to process data in a restrictive manner in the future. You have the right to object in particular in cases where your data is required for the performance of a task that is in the public interest or in our legitimate interest, as well as profiling based on this. You also have such a right of objection in the event of data processing for the purpose of direct advertising.

c) Right to revoke consent with effect for the future.

You may revoke your consent at any time with effect for the future. Your revocation will not affect the lawfulness of the processing up to the time of revocation.

d) Data portability

If data is processed on the basis of a contract, pre-contractual negotiations, consent or with the help of automated procedures, you have the right to data portability. Upon request, we will provide you with your data in a common, structured, and machine-readable format so that you can transfer the data to another data controller if you wish.

e) Exercise of your data subject rights and right of appeal

To assert these rights, please contact us. The same applies if you have questions about data processing in our company. You also have the right to lodge a complaint with a data protection supervisory authority. The Information Commissioner`s Office (ICO) is the for Keynance relevant authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO in the first instance.

Your data protection rights under the California Consumer Privacy Act (CCPA)/ California Privacy Rights Act (CPRA).

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and storage of their personal information.

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:

1. The categories of personal information we have collected about you.
2. The categories of sources for the personal information we have collected about you.
3. The specific pieces of personal information we have collected about you.
4. Our business or commercial purpose is to collect or sell your personal information.

The categories of third parties to whom we have sold or shared your personal information if any, and the categories of personal information that we have shared with each third-party recipient.

Your Right to Opt-Out of Sale or Sharing of Personal Information: California residents have the right to opt-out of the sale of their personal information by submitting a request as directed on the homepage of our website or by contacting us using the information in the “Contact Us” section below. Please note that we do not knowingly sell the personal information of any individuals under the age of 18.

Where we are sharing your personal information with third parties for the purposes of cross-context behavioural advertising or profiling, you may opt out of such sharing at any time by submitting a request as directed on the homepage of our website or by contacting us using the information in the “Contact Us” section below.

Your Right to Limit Use of Sensitive Personal Information: California residents have the right to request that we limit our use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically enumerated business purposes under the CCPA, as amended by the CPRA.

Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our third-party service providers to delete, your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA.

Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfil such a request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.

To exercise these rights, please contact us at the contact information mentioned in the “Your contact for data protection” clause.

Hyperlinks

Our website contains so-called hyperlinks to the websites of other providers. When you activate these hyperlinks, you will be redirected from our website directly to the website of the other provider. You will recognise this by the change of URL, among other things. We cannot accept any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with data protection regulations. Please inform yourself about the handling of your personal data by these companies directly on these websites.

Accuracy

It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

Automated Decision Making

The automated decision-making is not used at Keynance.

Processing of special categories of data

No special categories of data are processed at Keynance.

Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your account or by contacting us using info@keynance.com. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, that we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets, intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal data, notably where such requests would not allow us to provide our service to you anymore.

Social Media Logins

Our Website offers you the ability to register and log in using your third-party social media account details (like your Facebook, LinkedIn and Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platforms.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

Social Media

We are present in various “social media” platforms like LinkedIn, Instagram, Facebook, and YouTube in order to communicate with our users, interested parties and users registered there and to be able to inform them about our offers there. We would like to point out that you use these platforms and their functions on your own responsibility. This applies in particular to the use of interactive functions (e.g., commenting, sharing, rating).

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. Cookies are usually stored on your computer for this purpose. Independently of this, data that is not directly collected from your devices may also be stored in the usage profiles (especially if you are a member of the respective platforms and are logged in to them).

We, as the provider of this information service, do not collect and process any data from your use of our service beyond this.

The processing of users’ personal data is based on our legitimate interests in providing users with effective information and communicating with users pursuant to Art. 6 (1) f) GDPR. If you are asked by the respective providers for consent to data processing, the legal basis for processing is Art. 6 (1) a), Art. 7 GDPR.

If you are a member of a social network and do not want the network to collect data about you via our website and link it to your stored membership data with the respective network, you must log out of the respective network before visiting our website, delete the cookies on your device and close and restart your browser.

After logging in again, however, you will once more be recognisable to the network as a specific user. In the case of requests for information and the assertion of user rights, we would also like to point out that these can most effectively be asserted with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us using info@keynance.com.

Content Management System

We also use the Content Management System (CMS) of WordPress to publish and maintain the created and edited Content and texts on our website and to provide the forms used. This means that all content and texts submitted to us by users for publication are transferred to WordPress. In addition to texts, this also includes, for example, your data in our forms. This represents a legitimate interest within the meaning of Art. 6 (1) f) GDPR.

Personal data and children

Our Services are not for the use of children below the age of 18 (“Child” or “Children”). We do not knowingly collect personally identifiable information from Children under 18 without the consent of the parents or legal guardian. If you become aware that a Child has provided us with Personal Data without the parent’s or legal guardian’s consent, please contact us. If we become aware that we have collected Personal Data from Children, we take steps to remove that information from our servers.

Can the privacy policy be changed without my consent?

The entire offer of Keynance, like all Internet offers, is based on extensive data processing. The processes, software and interfaces used in this process are continuously developed and optimised. As a result, data processing may also be affected. Keynance may change this privacy policy at any time without notice and adapt it to future processing. Please inform yourself regularly about the privacy policy in force at any given time.

Your contact for data protection

If you have any questions regarding the collection, processing, or use of your personal data, or if you wish to request information, correct, block, or delete data, or revoke any consent you have given, please contact us using info@keynance.com.