Privacy Policy

Last updated: January 2024

Introduction

sharp-pathways Ltd ("we", "our", "us") is committed to protecting your privacy. This policy explains how we collect, use, and safeguard information when you interact with our website and services.

We are registered with the Information Commissioner's Office (ICO) under registration number ZA472918. Our registered address is Floor 3, Westgate House, 47-51 Great Eastern Street, London EC2A 3HP.

Information We Collect

We collect information in the following ways:

Information You Provide

When you contact us, book a programme, or subscribe to communications, you may provide:

  • Name and contact details including email address
  • Organisation name and role
  • Information about your financial education needs and goals
  • Payment information for programme bookings
  • Feedback and evaluation responses

Information Collected Automatically

When you visit our website, we may automatically collect:

  • Device information including browser type and operating system
  • IP address and approximate geographic location
  • Pages visited and time spent on site
  • Referring website address

How We Use Your Information

We use collected information to:

  • Respond to your enquiries and provide requested services
  • Process bookings and payments
  • Deliver and improve our educational programmes
  • Send relevant communications about our services (with your consent)
  • Analyse website usage to improve user experience
  • Comply with legal and regulatory obligations

Legal Basis for Processing

Under UK data protection law, we process your personal data based on:

  • Contract: Processing necessary to fulfil our obligations when you book programmes or services
  • Legitimate interests: Processing for business purposes that do not override your rights, such as improving our services and responding to enquiries
  • Consent: Marketing communications are sent only with your explicit permission
  • Legal obligation: Processing required to comply with tax, accounting, or other legal requirements

Data Sharing

We do not sell your personal information. We may share data with:

  • Payment processors to handle transactions securely
  • Email service providers to deliver communications
  • Analytics services to understand website usage
  • Professional advisers such as accountants and legal counsel
  • Regulatory bodies when legally required

All third parties are required to handle your data in accordance with applicable data protection legislation.

Data Retention

We retain personal information only as long as necessary:

  • Client records: Seven years after the last interaction for tax and legal purposes
  • Marketing preferences: Until you withdraw consent or request deletion
  • Website analytics: Aggregated data retained indefinitely; identifiable data deleted after 26 months
  • Enquiry correspondence: Three years unless converted to client relationship

Your Rights

You have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate data
  • Request deletion of your data in certain circumstances
  • Object to processing based on legitimate interests
  • Withdraw consent for marketing communications
  • Request data portability
  • Lodge a complaint with the ICO

To exercise these rights, contact us at [email protected]. We will respond within one month.

Data Security

We implement appropriate technical and organisational measures to protect personal data, including:

  • Encryption of data in transit and at rest
  • Regular security assessments
  • Staff training on data protection
  • Access controls limiting who can view personal data
  • Secure disposal of data when no longer needed

International Transfers

Some service providers may process data outside the UK. Where this occurs, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the ICO.

Changes to This Policy

We may update this policy periodically. Significant changes will be communicated via our website. The date at the top indicates when the policy was last revised.

Contact Us

For questions about this policy or our data practices:

Data Protection Enquiries
sharp-pathways Ltd
Floor 3, Westgate House
47-51 Great Eastern Street
London EC2A 3HP
Email: [email protected]

You may also contact the Information Commissioner's Office at ico.org.uk if you have concerns about how we handle your data.