Kademy Privacy Policy

Kademy Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when we are in contact with you about becoming a customer/member and during the course of your membership or when you sign up to receive marketing information or other company updates and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

 

1. Important Information and Who We Are

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

CONTROLLER

Kademy Limited is the controller and responsible for your personal data (collectively referred to as ”Kademy”, “we”, “us” or “our” in this privacy policy).

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

CONTACT DETAILS

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

Full name of legal entity: Kademy Limited

Email address: administrator@kademygroup.com

Postal address: 71-75 Shelton Street, London WC2H 9JQ

We recognise that your privacy is important, and we take our responsibility for safeguarding your personal information very seriously. We are also committed to being transparent about how we collect and use your data and to meeting our data protection obligations.

If you do have any concerns or comments about how we use your personal information we would appreciate the chance to deal with them so please contact us in the first instance. You also 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).

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review and may update it from time to time, so please ensure you regularly check back to review it. This version was last updated on 22 November, 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. It is important to remember that when you follow a link to any of these websites or leave our website to use the services of a third-party website, this Privacy Policy will not apply.

 

2. The Data We Collect About You

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

Website visitors, potential customers, customers:

  • Identity Data includes first name, last name, title, username, email address or similar identifier.
  • Work Data includes job title, company details, email address, username or similar identifier, phone number, country, team size, job history, development goals, development priorities, account management notes.
  • Contact Data includes billing address, delivery address, first names, last names, email address and telephone numbers.
  • 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.
  • Usage Data includes information and reporting about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Customers only:

  • Identity Data additionally includes social media links and photo.
  • Work Data additionally includes social media links.
  • Financial Data includes bank account or payment card details, billing name, billing address, billing email.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses social media links, conversation contributions, account management notes.
  • Transaction Data includes details about payments to and from you and or your company, spend amount, and other details of products and services you have purchased from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with 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 Data, Contact Data, Work Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:

  • you have completed the contact form on our website;
  • you have been recommended to us by a prior or current customer;
  • we contact you because you are a prospective customer;
  • work for an organisation that is an existing, prior or prospective customer;
  • you become a customer;
  • you create a user profile on our website;
  • you approve marketing to be sent to you;
  • you engage in conversation with us about our services;
  • you enter a competition, promotion or survey; or
  • you give us feedback or contact us.


AUTOMATED TECHNOLOGIES OR INTERACTIONS

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

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, Profile Data and Usage Data: analytics providers such as Google (based outside the EU); and
  • Identity Data, Work Data and Contact Data: from publicly available sources such as LinkedIn, 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:

Website visitors, potential customers, customers:

  • 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.

Customers only:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

See 10. Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below 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.

Purpose/ActivityType of DataLawful Basis For Processing Including Basis for Legitimate Interest
To register you as a new customer

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Marketing and Communications Data

Performance of a contract with you

To source legitimate new customers

(a) via the public domain (e.g. LinkedIn);

(b) recommendations from prior or existing customers;

(c) when you fill the contact form on our website

(d) if you are an existing or prior customer

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

To provide you with access to the course materials

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Technical Data

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Financial Data

(e) Transaction Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Improving the services we provide

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

(c) Asking you to provide feedback or take a survey

(d) Provide reporting to the customer on how users are using our products/services

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Technical Data

(e) Profile Data

(f) Usage Data

(g) Marketing and Communications Data

(a)  Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(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

(d) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to have the best experience of our service which will include:

(a) Providing you with the most relevant courses and content

(b) Enhancing your networking opportunities

(c) Providing a supportive community and discussion board

(d) Invite you to relevant, live, introductory or support sessions

(e) Providing coaching

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Transaction Data

(e) Profile Data

(f) Usage Data

(g) Marketing and Communications Data

(a) to (e) Performance of a contract with you

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Transaction Data

(e) Technical Data

(f) Profile Data

(g) Usage Data

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 re-organisation or group restructuring exercise)

To deliver relevant website content and marketing content to you and measure or understand the effectiveness of the marketing we serve to you

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Technical Data

(e) Profile Data

(f)  Usage Data

(g) Marketing and Communications 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) Profile Data

(c) Usage Data

(d) Marketing and Communications 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 Data

(b) Work Data

(c) Contact Data

(d) Transaction Data

(e) Technical Data

(f) Profile Data

(g) Usage Data

(h) Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

Maintaining books and records

(a) Identity Data
(b) Work Data
(c) Contact Data
(d) Transaction Data
(e) Technical Data

Necessary to comply with a legal obligation

Internal communications

(a) Identity Data

(b) Work Data

(c) Contact Data

(d) Transaction Data

(e) Usage 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)

MARKETING

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

PROMOTIONAL OFFERS FROM US

We may use your Identity Data, Work Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). These processes may use automated decision-making, dependent upon your interaction with our marketing offers, to ensure that we send to you relevant marketing offers and mailings only. These processes do not result in a legal or similarly significant effect on you. If, however, you want to request that we cease our automated decision-making processes in this respect, then please see 9. Your Legal Rights below for further information.

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

OPTING OUT

You can ask us to stop sending you marketing messages at any time by using our unsubscribe function which will be presented to you in every communication we send to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a us needing to perform our contract with you or to comply with a legal obligation.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If 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.

 

5. Disclosures of Your Personal Data

We never sell your personal information to any third parties, and you will not receive offers or communications from other companies or organisations as a result of giving your details to us.

THIRD PARTY PROCESSORS

In order to efficiently support you we may share your personal data with third parties to process your personal information for the above purposes on our behalf. These third-party processors include our service providers for website development and support, mailing and marketing facilitators, our customer relationship management platform, training and learning platform providers, document signing facilitators and Kademy coaches.

If/when we do share your personal information for these purposes, the data remains our property at all times – these “data processors” act only under our instructions and are not permitted to use your information for their own purposes. We check carefully that our third-party suppliers are as compliant with data protection law and regulations as we are. We have contracts in place with our third-party data processors under which they are required 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

OTHER THIRD PARTIES

In some circumstances we are legally obliged to share information. For example under a court order. We may also share your personal information with:

  • Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting type services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

6. 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:

  • UK adequacy regulations apply in respect of the country setting out in law that the legal framework in that country, territory, sector or international organisation has been assessed as providing ‘adequate’ protection for individuals’ rights and freedoms for their personal data.
  • Specific contractual clauses approved by the UK are in place which give personal data the same protection it has in the UK.

 

7. 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.

 

8. 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 of up to seven years for applicable legal, regulatory, tax, accounting or other requirements, in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact Data, Work Data, Identity Data, Financial Data and Transaction Data) for seven years after you cease being customers for e.g. tax purposes.

In some circumstances you can ask us to delete your data: see 9. Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

9. Your Legal Rights

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

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.

Object to automated decision making. Whilst our automated decision-making does not result in a legal or significantly similar effect on you, we would be prepared to review these marketing processes to determine whether we can adjust them to avoid the automated decision-making element.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at administrator@kademygroup.com.

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.

 

10. Glossary

LAWFUL BASIS

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

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).

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.