Last Updated: November 1st, 2020

We at The Box Academy Ltd. (“The Box Academy,” “we,” “us,” or “our”) have created this privacy policy (this “Website Privacy Policy”) to outline the information collection and use practices of The Box Academy in connection with our Portal located at https://www.theboxacademy.com (the “Website”).

Description of Users and Acceptance of Terms

This Website Privacy Policy applies to visitors to the Website (“Visitors,” “you,” or “your”).

By accessing our Website, Visitors are agreeing to the terms of this Website Privacy Policy and the accompanying Website Terms of Use located at https://theboxacademy.com/terms which are hereby incorporated by reference.

The Information We Collect and How We Use It

In the course of operating the Website, The Box Academy may collect or receive the following types of information:

Contact Information 

We collect contact information on our Website; the contact information collected varies depending on the webpage but typically includes some combination of your name, email address, institution information, and the information you provide in messages to us. We use such contact information for purposes such as responding to, and following up regarding, your inquiries, providing you with requested information, storing contact details into our customer relationship management database, providing you with a demo, speaking with you via our live-chat support option, or sending you email alerts (including marketing emails).

Server Logs

Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Website, or the pages you’ve clicked on while on our Website). We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

Cookies

We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We may use both 1st and 3rd- party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

· Session Cookies: We use session cookies to make it easier for you to navigate our Website. A session ID cookie expires when you close your browser.

· Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Website, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. We may also use persistent cookies to track and target the interests of our Visitors to personalize the experience on our Website.

In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Website (e.g., email open rates, URL click throughs).

If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of the Website may not function properly or as intended.

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you: 

* Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims. 

* Customer Data that includes data relating to any purchases of goods, subscriptions and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. 

* User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business. 

* Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy. 

* Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy. 

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). 

Sensitive Data We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences. Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). 

If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time. We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at hello@theboxacademy.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where this is required or permitted by law. We do not carry out automated decision making or any type of automated profiling.

Aggregate Data

In an ongoing effort to better understand our Visitors and the Website, we might analyze your information in aggregate form to carry out, maintain, manage, and improve operations in connection with the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services and the Website to current and prospective business partners and to other third parties for other lawful purposes.

Business Transfers

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Website Privacy Policy. This Website Privacy Policy shall be binding upon The Box Academy and its legal successors in interest.

Feedback

We welcome feedback and suggestions about how to improve the App and/or Services. However, by transmitting any ideas, suggestions, information, or other material, you represent and warrant that such feedback does not infringe, misappropriate or violate the intellectual property or proprietary rights of any third party and that you have all rights necessary to convey such feedback to us.  Any use of such feedback or suggestions will be without any compensation or recognition of any kind.

How We Protect Your Information

We take commercially reasonable steps designed to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Website Privacy Policy, subsequently authorized, or as allowed under applicable law.

Opt-Out for Email Marketing and Certain Other Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time. Before we share your personal data with any third party for their own marketing purposes we will get your express consent. 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 emailing us at support@theboxacademy.com at any time. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

Children

We do not knowingly collect personal information from children under the age of 13 through the Website. 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 Website Privacy Policy by instructing their children to never provide personal information to us. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at support@theboxacademy.com and we will endeavor to delete that information from our databases.

Important Notice to All Non-EU Residents

The Portal and Services are not meant for use or access by non-EU residents.  In addition, our servers are located in the EU. If you are located outside of the EU, please be aware that any information provided to us, including personal information, could be transferred from your country of origin to the EU. Your decision to provide such data to us, or allow us to collect such data through our Website, constitutes your consent to this data transfer.

YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. If you wish to exercise any of the rights set out above, please email us at hello@theboxacademy.com. 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 or refuse to comply with your request in these circumstances. 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. We try to respond to all legitimate requests within one month. Occasionally it may 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. If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Links to External Websites

The Website may contain links to third-party websites (“External Sites”). The Box Academy has no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting or submitting any information through such External Sites.

Changes to This Website Privacy Policy

This Website Privacy Policy is effective as of the ‘Last Updated’ date stated at the top of this Website Privacy Policy. We may change this Website Privacy Policy from time to time with or without notice to you. By visiting the Website after we make any such changes to this Website Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the  extent permitted by applicable law, and without prejudice to the foregoing, our use of your information is governed by the Website Privacy Policy in current effect. Please refer back to this Website Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Website Privacy Policy, please e-mail us at hello@theboxacademy.com with “Website Privacy Policy” in the subject line.

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