By using HIDDEN FALLS MEDIA, LLC (the “Company”) website (https://www.hiddenfallsmedia.com), including its
family of Websites including without limitation www.clickfunnels.hiddenfallsmedia.com(collectively, the “Site”), you
each Site visitor or user, “we”, “us” and “our” refer to the Site and the Company, and “Services” refers to all services
provided by us.
BY USING THE SITE AND/OR OFFERINGS AVAILABLE ON THIS SITE, YOU GIVE YOUR CONSENT THAT ALL
PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE
PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT
USE THE SITE.
1. Ownership. This Site is owned and operated by the Company. All right, title and interest in and to the
materials provided on this Site, including but not limited to information, documents, logos, graphics,
sounds and images (the “Materials”) are owned or licensed either by the Company or by our respective
third party authors, developers or vendors. Except as may be expressly stated on the Site or in these
posted, displayed, transmitted or distributed in any way and nothing on this Site shall be construed to
confer any license under any of the Company’s intellectual property rights, whether by estoppel,
implication or otherwise. See the “Contact Information” below if you have any questions about obtaining
such licenses. The Company does not sell, license, lease or otherwise provide any of the Materials
other than those specifically identified as being provided by the Site. Any rights not expressly granted
herein are reserved by the Company.
2. Use of Materials. Any unauthorized use of any Materials contained on this Site may violate copyright
laws, trademark laws, laws of privacy and publicity, communications regulations and statutes as well as
other rights, laws, rules, regulations and statutes.
3. Links to Third Party Sites. This Site may contain links to Web sites controlled by parties other than the
Site (each a “Third Party Site”). The Company may work with a number of partners and affiliates whose
sites are linked with the Site. Both the Company and the Site are not responsible for and do not endorse
or accept any responsibility for the availability, contents, products, services or use of any Third Party
Site, any Site accessed from a Third Party Site, or any changes or updates to such sites. The Company
makes no guarantees about the content or quality of the products or services provided by such sites.
The Company is not responsible for webcasting or any other form of transmission received from any
Third Party Site. The Company is providing these links to you only as a convenience, and the inclusion
of any link does not imply endorsement by the Company of the Third Party Site. You acknowledge that
you bear all risks associated with access to and use of content provided on a Third Party Site and agree
that neither the Company nor the Site are responsible for any loss or damage of any sort you may incur
from dealing with a third party. You should contact the site administrator for the applicable Third Party
Site if you have any concerns regarding such links or the content located on any such Third Party Site.
4. Reviews, Comments, Communications, And Other Content. At various locations on the Site, the
Company may permit visitors to post reviews, comments, and other content (the “User Content”).
Contributions to, access to and use of the User Content is at your own risk and subject to the below
1. Rights and Responsibilities of the Company. The Company respects the intellectual
property of others, and we ask our users to do the same. The Company may, in
appropriate circumstances and at its discretion, disable and/or terminate your use of the
Site for violation of others’ intellectual property rights. If you believe that your work has
been copied in a way that constitutes copyright infringement, or your intellectual property
rights have been otherwise violated, please provide us notice at
The Company has the right, in our sole and absolute discretion, to (i) edit, redact or otherwise change any User
Content, (ii) re-categorize any User Content to place it in a more appropriate location or (iii) pre-screen or delete any
limited to User Content containing offensive language and advertisements.
The Company reserves the right to refuse service to anyone and to cancel user access at any time.
1. Rights and Responsibilities of the Company’s Users or Other Posters of User Content.
You are legally and ethically responsible for any User Content - writings, files, pictures or any other work that you
post or transmit using any service of the Site that allows interaction or dissemination of information. In posting User
Content, you are responsible for honoring the rights of others, including intellectual-property rights (copyright, patent
and trademark), the right to privacy and the right not to be libeled or slandered. For example, if you wish to post a
copyrighted work as User Content, you are responsible for first obtaining the copyright holder’s permission.
Under United States federal law, you retain copyright on all works you create and post as User Content, unless you
choose specifically to renounce it. By posting such user content, you grant a license to the Company to use, reprint,
distribute, modify, and create derivative works, which will be owned by the Company. In posting a work as User
Content, you authorize other members who have access to that service to make personal and customary use of the
work, including creating links or reposting, but not otherwise to reproduce or disseminate it unless you give
permission for such dissemination. You also give permission to the Company to copy your works as part of the
normal backup process. You have the right to remove any of your works from User Content at any time.
The posting of User Content for any illegal activity under the laws of the State of California and the United States is a
consider the possible effect of laws outside the Company’s locality or your own residence. The Company is open to
members worldwide (and works published on the World Wide Web, Usenet or other such services are accessible to
anyone on the Internet), and the Company cannot guarantee that you will not run into legal trouble in other
jurisdictions over your posting. You agree not use the Site in any way that could damage, disable, or impair any
Services provided by the Company (or the network(s) connected to the Site), violate the privacy and security of other
users, or interfere with any user’s use and enjoyment of any of the Site. You agree not to attempt to gain
unauthorized access to any services offered on the Site, other accounts, computer systems or networks connected to
the Site, through hacking, password mining or any other means. You agree not to obtain or attempt to obtain any
materials or information through any means not intentionally made available through the Site.
1. No Warranty. THE SITE AND ALL MATERIALS, DOCUMENTS OR FORMS PROVIDED ON OR
THROUGH YOUR USE OF THE SITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.
TO THE FULLEST EXTENT PERMITTED BY LAW, THE COMPANY EXPRESSLY DISCLAIMS ALL
WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED
TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE,
TITLE AND NON-INFRINGEMENT.
THE COMPANY MAKES NO WARRANTY THAT: (A) THE SITE OR THE MATERIALS WILL MEET YOUR
REQUIREMENTS; (B) THE SITE OR THE MATERIALS WILL BE AVAILABLE ON AN UNINTERRUPTED, TIMELY,
SECURE OR ERROR-FREE BASIS; (C) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE
SITE, OR ANY MATERIALS OFFERED THROUGH THE SITE, WILL BE ACCURATE OR RELIABLE; OR (D) THE
QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION OR OTHER MATERIAL PURCHASED OR OBTAINED
BY YOU THROUGH THE SITE OR IN RELIANCE ON THE MATERIALS WILL MEET YOUR EXPECTATIONS OR
ARE SUITABLE FOR YOUR USE OR CIRCUMSTANCES.
OBTAINING ANY MATERIALS THROUGH THE USE OF THE SITE IS DONE AT YOUR OWN DISCRETION AND
AT YOUR OWN RISK. THE COMPANY SHALL HAVE NO RESPONSIBILITY FOR ANY DAMAGE TO YOUR
COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF ANY CONTENT,
MATERIALS, INFORMATION OR SOFTWARE.
1. Limitation of Liability. IN NO EVENT SHALL THE COMPANY, OUR OFFICERS, DIRECTORS,
EMPLOYEES, AGENTS, CONTRACTORS, SUPPLIERS, OR LICENSEES BE LIABLE FOR ANY
INDIRECT, PUNITIVE, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGE (INCLUDING BUT
NOT LIMITED TO LOSS OF BUSINESS, REVENUE, PROFITS, USE, DATA OR OTHER ECONOMIC
ADVANTAGE), HOWEVER IT ARISES, WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE
OR OTHER TORTIOUS ACTION, OR ARISING OUT OF OR IN CONNECTION WITH THE USE OR
INABILITY TO USE THIS SITE OR MATERIALS AVAILABLE FROM THIS SITE, EVEN IF THE
COMPANY HAS BEEN PREVIOUSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. IF
YOUR USE OF MATERIALS FROM THIS SITE RESULTS IN THE NEED FOR SERVICING, REPAIR
OR CORRECTION OF EQUIPMENT OR DATA, YOU ASSUME ANY COSTS THEREOF. SOME
STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR
CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO
YOU, IN WHICH INSTANCE THE MAXIMUM LIABILITY OF THE COMPANY TO YOU IS THE
LOWEST AMOUNT ALLOWABLE UNDER THE APPLICABLE LAWS.
2. Indemnification. You agree to defend, indemnify and hold harmless the Company, our officers,
directors, shareholders, employees and agents from and against any and all claims, liabilities,
damages, losses or expenses, including reasonable attorneys’ fees and costs, arising out of or in any
way connected with your access to or use of the Site and the Materials.
3. Unsolicited Submissions. Except as may be required in connection with your use of the Company’s
Services, the Company does not want you to submit confidential or proprietary information to us through
this Site. All comments, feedback, information or material submitted to the Site through or in association
with this Site shall be considered non-confidential. By providing such submissions to the Site you
hereby grant the Company a license to use, reprint, distribute, modify and create derivative works which
will be owned by the Company. You acknowledge that you are responsible for the submissions that you
provide, including their legality, reliability, appropriateness, originality and content.
4. Compliance with Intellectual Property Laws. When accessing the Site or using the Company’s Services,
you agree to obey the law and you agree to respect the intellectual property rights of others. Your use of
the Service and the Site is at all times governed by and subject to laws regarding copyright, trademark
and other intellectual property ownership. You agree not to upload, download, display, perform, transmit
or otherwise distribute any information or content in violation of any third party’s copyrights, trademarks
or other intellectual property or proprietary rights. You agree to abide by laws regarding copyright
ownership and use of intellectual property, and you shall be solely responsible for any violations of any
relevant laws and for any infringements of third party rights caused by any content you provide or
transmit or that is provided or transmitted using the Site. If you believe that any Content on the Site is
infringing on your copyright, you may seek the removal of such Content by providing notice to us in
accordance with the Notice and Take Down provisions of the Digital Millennium Copyright Act at as
described above in Section 4(a).
5. Monitoring and Enforcement; Termination or Suspension.
We have the right to:
a. Remove or refuse to post any User Content for any or no reason in our sole discretion.
b. Take any action with respect to any User Content that we deem necessary or appropriate in our sole discretion,
other right of any person or entity, threatens the personal safety of users of the Site or the public, or could create
liability for the Company.
c. Disclose your identity or other information about you to any third party who claims that material posted by you
violates their rights, including their intellectual property rights or their right to privacy.
d. Take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or
unauthorized use of the Site.
e. Terminate or suspend your access to all or part of the Site for any reason or no reason, including without limitation,
1. Inappropriate Content. When accessing the Site or using the Company’s Services, you agree not to
upload, download, display, perform, transmit or otherwise distribute any content that: (a) is libelous,
defamatory, obscene, pornographic, abusive or threatening; (b) advocates or encourages conduct that
could constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local,
state, national or foreign law or regulation; or (c) advertises or otherwise solicits funds or is a solicitation
for goods or services. The Company reserves the right to terminate or delete such material from its
servers. The Company will cooperate fully with any law enforcement officials or agencies in the
2. Compliance with Export Restrictions. You may not access, download, use or export the Site or the
Materials in violation of United States export laws or regulations or in violation of any other applicable
laws or regulations. You agree to comply with all export laws and restrictions and regulations of any
United States or foreign agency or authority and to assume sole responsibility for obtaining licenses to
export or re-export as may be required. You acknowledge and agree that the Materials are subject to
the United States Export Administration Laws and Regulations and agree that none of the Materials or
any direct product therefrom is being or will be acquired for, shipped, transferred or re-exported, directly
or indirectly, to proscribed or embargoed countries or their nationals or used for any prohibited purpose.
3. Children. We do not knowingly collect any personal information from visitors or users of our site who are
under the age of 13. If you are under 13, please do not give us any personal information. We encourage
parents and legal guardians to monitor their children’s Internet usage and to help enforce our privacy
policy by instructing their children to never provide personal information through the Internet without
their permission. If you have reason to believe that a child under the age of 13 has provided personal
information to us, please contact us, and we will endeavor to delete that information from our
4. Governing Law; Venue. By using this Site, you expressly agree that your rights and obligations shall be
governed by and interpreted in accordance with the laws of the State of California, excluding its choice
of law rules. Any legal action or proceeding relating to your access to or use of the Site or Materials
shall be instituted in a state or federal court in the State of California. You and the Company agree
exclusively and irrevocably to submit to the jurisdiction of, and agree that venue is proper in, these
terms of the U.N. Convention on Contracts for the International Sale of Goods, which shall not apply to
any transaction conducted through or otherwise involving this Site.
5. Copyright. All Site design, text, graphics, the selection and arrangement thereof, Copyright © 2020, Hidden Falls Media, LLC. ALL RIGHTS RESERVED.
6. Trademarks. The Company’s name, the Site, all images and text, and all page headers, custom
graphics and button icons are service marks, trademarks and/or trade dress of the Company. All other
trademarks, product names and company names or logos cited herein are the property of their
7. No Guarantee of Success. Any projections or predictions that may have been made available to Subscriber through the offerings are based on estimates, assumptions and forecasts which may prove to be incorrect; and no assurance is given that actual results will correspond with the results contemplated by the various projections; It is impossible to provide any promise or guarantee about the outcome of Client's matter. Nothing in this Agreement or any statements by Alex Vonderhaar, Hidden Falls Media, or his employees in dealing with the Client's matters constitute a promise or guarantee. Any comments about the outcome of the Client's matters are expressions of opinion only.
8. Acknowledgement. BY USING THE COMPANY’S SERVICES OR ACCESSING THE COMPANY’S
BOUND BY THEM.
with the Site, you can contact us at
Important information and who we are
The data we collect about you
How is your personal data collected?
How we use your personal data
Disclosures of your personal data
Your legal rights
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
your use of this website, including any data you may provide through this website when you purchase one of our
products or services or take part in any of our online marketing seminars or other course offerings.
This website is not intended for children and we do not knowingly collect data relating to children.
provide on specific occasions when we are collecting or processing personal data about you so that you are fully
is not intended to override them.
HIDDEN FALLS MEDIA, LCC. is the controller and responsible for your personal data (collectively referred to as
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this
rights, please contact the DPO using the details set out below.
Full name of legal entity: HIDDEN FALLS MEDIA LLC
Postal address: 9078 Union Centre BLVD Suite 350, West Chester OH 45069
Telephone number: (513) 446-9098
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.
and current. Please keep us informed if your personal data changes during your relationship with us.
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
1. 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
● Identity Data includes first name, maiden name, last name, username or similar identifier, marital
status, title, date of birth and gender.
● Contact Data includes billing address, delivery address, email address and telephone numbers.
● Financial Data includes bank account and payment card details.
● Transaction Data includes details about payments to and from you and other details of products and
services you have purchased from us.
● 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
our third parties 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
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.
1. 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, Contact and Financial Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide
● 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. 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. A "cookie" is a small data file that the Site
transfers to your computer for storage to allow our server to "remember" certain information that
identifies you as an individual. The Company may use Technical Data for general marketing purposes,
to retain changes that you made, and to help enhance customer experience on the Site and you hereby
consent to such use by the Company.
● 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:
(a) analytics providers such as Google and Facebook based inside or outside the EU;
(b) advertising networks such as Facebook based inside or outside the EU;
(c) search information providers such as Google and Facebook based inside or outside the EU;
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
(e) Identity and Contact Data from data brokers or aggregators based inside or outside the EU; and
(f) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register
based inside the EU.
1. 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
● 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.
See “Lawful Basis” in the Glossary to find out more about the types of lawful basis that we will rely on to process your
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
Performance of a contract with you
To process and deliver your order
(a) Manage payments, fees and
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to
recover debts due to us)
(b) Collect and recover money owed
(e) Marketing and
To manage our relationship with you
which will include:
(a) Notifying you about changes to
(b) Asking you to leave a review or
take a survey
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary to comply with a legal
(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 prize
draw, competition or complete a
(e) Marketing and
(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
To administer and protect our
business and this website (including
troubleshooting, data analysis,
testing, system maintenance,
support, reporting and hosting of
(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 reorganization or group
(b) Necessary to comply with a legal
To deliver relevant website content
and advertisements to you and
measure or understand the
effectiveness of the advertising we
serve to you
(e) Marketing and
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
To use data analytics to improve our
marketing, customer relationships
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
Necessary for our legitimate interests (to
develop our products/services and grow our
(f) Marketing and
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage 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).
You will receive marketing communications from us if you have requested information from us or purchased goods or
services 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
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on
any marketing message sent 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 product/service purchase, product/service experience, or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
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 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.
1. 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.
● Internal Third Parties as set out in the Glossary.
● External Third Parties as set out in the Glossary.
● 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
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.
1. INTERNATIONAL TRANSFERS
We share your personal data within our group of companies which may involve transferring your data outside the
European Economic Area (EEA).
Some of our external third parties are based outside the EEA so their processing of your personal data may involve a
transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, 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 by the European Commission;
● Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe; or
● Where we use providers based in the US, we may transfer data to them if they are part of the Privacy
Shield which requires them to provide similar protection to personal data shared between Europe and
Please contact us if you want further information on the specific mechanism used by us when transferring your
personal data out of the EEA.
1. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used
or accessed in an unauthorized 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.
1. 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 unauthorized 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.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers.
In some circumstances we will anonymize 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.
1. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal
data. Please review the Glossary to learn more about these rights.
● 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.
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
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.
Internal Third Parties
Other companies in Company’s Group acting as joint controllers or processors, for marketing purposes.
External Third Parties
● Service providers based inside and outside of the United States who provide IT and system
● Professional advisers including lawyers, bankers, auditors and insurers based in the Unites States who
provide consultancy, banking, legal, insurance and accounting services.
● Digital marketing agencies acting as processors based in the United States who provide digital
YOUR LEGAL 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
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 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.