What is this Privacy Policy for?
This privacy policy is for this website www.harpacademy.co.uk, which is served by Harp Academy, and governs the privacy of anybody who chooses to use it.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.
The Website
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with all UK national laws and requirements for user privacy.
Use of Cookies
This website uses cookies to better the user’s experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer/device.
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the user with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer hard drive, they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.
This website uses tracking software to monitor its visitors, to better understand how they use the site. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to the user’s computer hard drive in order to track and monitor the user’s engagement and usage of the website but will not store, save or collect personal information. You can read Google’s privacy policy here for further information [ http://www.google.com/privacy.html ].
Other cookies may be stored to the user’s computer hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form process to email submissions, but we advise users using such forms that they do so at their own risk.
Use of Data
This website and its owners use any information submitted to provide users with further information about the products and services we offer, or to assist in answering any questions or queries submitted. This includes using user details to subscribe them to any email newsletter programmes the website operates; but only if this is made clear to the user and their express permission was granted when submitting any email forms. Or whereby the user has previously purchased from, or enquired about purchasing from, the company a product or service that the email newsletter or website relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.
We use collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Data Control
Harp Academy processes personal data both as a processor and controller, as defined in the GDPR directive. As of 25th May 2018, Harp Academy adheres to the GDPR. Consequently, Harp Academy processes all data provided by it’s users with accounts in its European Data Region, in the European Economic Area (EEA) only. All data collected by Harp Academy will be stored securely. All transfers of data internally within the EEA is done in accordance with the GPDR.
Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your country but always within the European Economic Area (EEA). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Disclosure of Data
- Business Transaction. If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. Should this occur, we will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
- Disclosure for Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Legal Basis for Processing Personal Data under the GDPR
Harp Academy’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Harp Academy may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and is not overridden by your rights
- For payment processing purposes
- To comply with the law
Your Data Protection Rights under the GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Harp Academy aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the Contact page on this website. In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right to have your information rectified if that information is inaccurate or incomplete
- The right to object to our processing of your Personal Data
- The right to request that we restrict the processing of your personal information
- The right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format
- The right to withdraw your consent at any time for Harp Academy to process your personal information
Please note that we may ask you to verify your identity before responding to such requests. You also have the right to complain to the Information Commissioner’s Office (ICO) about our collection and use of your Personal Data.
Service Providers
We may employ third party companies and individuals to facilitate our Service (Service Providers), to provide a Service, or Services, on our behalf, to perform Service-related services or to assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.
- Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the advertisements of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Payments
We may provide paid products and/or services within our Service. In this case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. This information is provided directly to our third-party payment processors, whose use of your personal information is governed by their own Privacy Policy. These payment processors 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. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
- NatWest Bank. Their Privacy Policy can be viewed at https://personal.natwest.com/global/privacy.html
- PayPal. Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Children Policy
Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Newsletters
Where this website operates an email newsletter program, this will be used to inform subscribers about products and services supplied by this website. Where this is the case, users can subscribe through an online automated process should they wish to do so, but do so at their own discretion. Any associated subscriptions may be manually processed through prior written agreement with the user.
Any associated subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties, or shared with companies and people outside the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website’s email newsletter program. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this policy.
Where an email marketing campaign is published by this website or its owners, this may contain tracking facilities within the actual email. Subscriber activity will be tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no means a comprehensive list]. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
External Links
Although this website only looks to include quality, safe and relevant external links, users should always adopt a policy of caution before clicking any external web links mentioned throughout this website. The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Adverts and Sponsored Links
This website may contain sponsored links and adverts. These may be served through advertising partners, who may have detailed privacy policies relating directly to the adverts they serve. Clicking on adverts may send you to an the advertiser’s website through a referral program which may use cookies that will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computer hard drive. Users should therefore note they click on sponsored external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions, as well as the privacy policies, held with each social media platform respectively.
Users are advised to use social media platforms wisely, and communicate and engage upon them with due care and caution with regard to their own privacy and personal details. Neither this website, nor its owners, will ever ask for personal or sensitive information through social media platforms, or encourage users wishing to discuss sensitive details to contact them through primary communication channels such as telephone or email.
This website may use social sharing buttons, which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, they do so at their own discretion and should note that the social media platform may track and save the request to share a web page through the user’s social media platform account.
Shortened Links in Social Media
This website and its owners, through their social media platform accounts, may share web links to relevant web pages. By default some social media platforms shorten lengthy URLs [web addresses]. Typically these will start without a www prefix, and read http://etc.
Users are advised to take caution and good judgement before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure that only genuine URLs are published on this site, many social media platforms are prone to spam and hacking and therefore this website, and its owners, cannot be held liable for any damages or implications caused by visiting any shortened links.
Changes to the Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us by using the contact information we provided on our Contact page.
Harp Academy Data Protection Officer
Harp Academy’s has appointed a Data Protection Officer who is responsible for matters related to privacy and data protection. Our Data Protection Officer can be reached at the following address:
Harp Academy
18 Orchard Avenue
Hove
East Sussex
BN3 7BL
richard@harpacademy.co.uk
Resources & Further Information