Privacy Policy - Fintech Circle

This Privacy Policy sets out how we, FINTECH Circle Ltd, collect, store and use information about you when you use or interact with our websites, www.FINTECHCircle.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 15 April 2018.

Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
Information we collect when you place an order on our website
How we collect or obtain information about you from third parties
Our use of automated decision-making and profiling
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
Children’s Privacy
Copyright, credit and logo

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: FINTECH Circle Ltd
How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us, signing up as a new member, co-author, lecturer, student, placing an order on our website and by signing up to your e-newsletter and/or surveys),
- from your use of our website, using cookies and similar technologies, and
- occasionally, from third parties.
Information we collect: name, contact details, payment information e.g. your credit or debit card details (if applicable), IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable), and if you complete the joining form you provide us with the following information which we collect such as your linkedin ID, your title/position, your areas of expertise, membership in other networks, membership type, investor categorization, amount, objectives for joining, any comments and declaration of experience status.
How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: www.fintechcircle.com/cookies-policy
Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the following countries: USA and Canada. Where we do so, we will ensure appropriate safeguards are in place for data transfers outside the European Economic Area e.g. the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
Use of automated decision making and profiling: we use automated decision making and profiling e.g. use of web analytics, cookies, web beacons or server logs analysis tools

Your rights in relation to your information

to access your information and to receive information about its use
to have your information corrected and/or completed
to have your information deleted
to restrict the use of your information
to receive your information in a portable format
to object to the use of your information
to withdraw your consent to the use of your information
to complain to a supervisory authority
Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is FINTECH Circle Ltd, Company Number:
09141483 of FINTECH Circle Ltd, 167-169 Great Portland street, 5th Floor, London, W1W 5PF You can contact the data controller by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The 167-169 Great Portland street, 5th Floor, London, W1W 5PF or sending an email to info@fintechcircle.com

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use third party servers to host our websites called:

WP Engine, the privacy policy of which is available here: https://wpengine.co.uk/legal/privacy/

Amazon Web Services, AWS, the privacy policy of which is available here: https://aws.amazon.com/privacy/

Our website servers automatically log the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our servers are located in the United States and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Use of website server log information for IT security purposes

We and our third party hosting providers collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: www.fintechcircle.com/cookies-policy

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Google Mail (Gmail). Their privacy policy is available here: https://policies.google.com/privacy

Emails you send us will be stored outside the European Economic Area on our third party email provider’s Gmail servers in North America. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Contact form

When you contact us using our contact form, we collect your name, email address, IP address and your request for information. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as your company name, title, phone number or social media profile.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Transfer and storage of your information

Messages you send us via our contact form will be stored outside the European Economic Area on our third party hosting and email provider’s servers in North America. Our third party email provider is Google/Gmail and our hosting provider is WP Engine or Amazon Web Services AWS, both located in North America. Their privacy policy is available below:

Google’s privacy policy is available here: https://policies.google.com/privacy

WP Engine’s privacy policy is available here: https://wpengine.co.uk/legal/privacy/.

Amazon Web Services, AWS’ privacy policy is available here: https://aws.amazon.com/privacy/

We also use a third party contact form provider to store messages you send us. Our contact form provider is located in North America. Their privacy policy is available here: https://www.wufoo.co.uk/privacy/. Messages you send to us via our contact form will be stored outside the European Economic Area on our contact form provider’s servers in North America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider, Vodafone, located in the European Economic Area. Their privacy policy is available here:https://www.vodafone.co.uk/about-this-site/our-privacy-policy/

Information about your phone call will be stored by our third party telephone service provider within the European Economic Area.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news and offers from us by entering your name and email address and clicking subscribe or by ticking a box at checkout indicating that you would like to receive our e-newsletter, we collect your name and email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, MailChimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our Mailchimp servers in North America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: www.fintechcircle.com/cookies-policy

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://mailchimp.com/legal/privacy/

Registering on our website

When you register and create an account on our website (where applicable), we collect the following information: name, email address, IP address and any other information you provide to us when you complete the registration form, including your company name, title and country.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored outside the European Economic Area on our third party hosting provider’s servers in North America. Our third party hosting provider is WP Engine and AWS located in North America. Their privacy policy is available below:

WP Engine, the privacy policy of which is available here: https://wpengine.co.uk/legal/privacy/.

Amazon Web Services, AWS, the privacy policy of which is available here: https://aws.amazon.com/privacy/

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), VAT number (if applicable), and which product you want to purchase.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use the third party payment processor PayPal.

Paypal collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link: https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Transfer and storage of your information

Paypal is located in North America. Information relating to the processing of your payment is stored outside the European Economic Area on Paypal’s servers in North America.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email, and text message by ticking a box indicating that you would like to receive such communications.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third party service to administer our mailing list, MailChimp.

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in North America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files)] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our emails, see our cookies policy which is available here: www.fintechcircle.com/cookies-policy

For more information about our third party mailing list provider and how they use web beacons, please see their privacy policy which is available here: https://mailchimp.com/legal/privacy/

How we collect or obtain information about you from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, business directories, media publications, social media, and websites (including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email if we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Our use of automated decision-making and profiling

We use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: www.fintechcircle.com/cookies-policy

Automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement. We currently do not use automated decision making.

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your personal preferences, interests, behaviour, or location.

Use of profiling for web analytics

Our web analytics service, Google Analytics collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy www.fintechcircle.com/cookies-policy

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie management tool) and your location will be analysed based on your IP address.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy www.fintechcircle.com/cookies-policy

Logic involved: By analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, and click through rates.

How to object: You can object to our use of web beacons by emailing info@fintechcircle.com

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

Disclosure and additional uses of your information

This section sets out the circumstances in which we disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. These include the following:

Telephone provider(s), including Vodafone. Their privacy policy is available here:

https://www.vodafone.co.uk/about-this-site/our-privacy-policy/

Email provider(s), including Google. Their privacy policy is available here:

https://policies.google.com/privacy

Hosting provider(s), including AWS and WP Engine. Their privacy policy is available here:

https://aws.amazon.com/privacy/https://wpengine.co.uk/legal/privacy/

Apart from Vodafone which are located in the UK, our service providers are located in the United States.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are located in the European Economic Area.

Advisors

Occasionally, we obtain advice from advisors, such as financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice. Our advisors are located in the European Economic Area.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services. Our affiliates are located both inside and outside of the European Economic Area.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services. Our affiliates are located both inside and outside of the European Economic Area.

Independent contractors

We use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business. Our independent contractors are located in the UK.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them. Our insurers are located in the UK.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement of our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 6 years.

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 12 further months after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
using secure servers to store your information;
verifying the identity of any individual who requests access to information prior to granting them access to information;
using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting companies, AWS and WP Engine. You can access their privacy policy here:

https://aws.amazon.com/privacy/

https://wpengine.co.uk/legal/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: AWS and WP Engine have self-certified their compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Contact form

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party hosting and email provider’s servers. Our hosting provider are WP Engine and AWS, our form provider is Wufoo and our email provider is Google/Gmail. You can access their privacy policy here:

https://aws.amazon.com/privacy/

https://wpengine.co.uk/legal/privacy

https://www.wufoo.com/privacy/

https://policies.google.com/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: AWS, WP Engine, Wufoo and Google have self-certified their compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: Google. You can access their privacy policy here:

https://policies.google.com/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Mailchimp. You can access their privacy policy here:

https://mailchimp.com/legal/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Mailchimp has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Online Surveys

Information you submit to us when you sign up for our online surveys is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Survey Monkey. You can access their privacy policy here:

https://www.surveymonkey.com/mp/legal/privacy-policy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Survey Monkey has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The Office Group, 50 Liverpool Street, London, England, EC2M 7PY or sending an email to info@fintechcircle.com:

to request access to your information and information related to our use and processing of your information;
to request the correction or deletion of your information;
to request that we restrict our use of your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain information

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The Office Group, 50 Liverpool Street, London, England, EC2M 7PY or sending an email to info@fintechcircle.com:

to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message;
sending an email to info@fintechcircle.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: www.fintechcircle.com/cookies-policy.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@fintechcircle.com.

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

PROTECTED BY COPYRIGHT INFRINGEMENT DETECTION SOFTWARE.

Our details

FINTECH Circle Ltd (we, our and us) operates the website.

FINTECH Circle Ltd is a limited liability company incorporated in England and Wales (company number 09141483). Our registered address is FINTECH Circle ltd, c/o Intelletec Ltd, The Office Group, 50 Liverpool Street, London, England, EC2M 7PY or sending an email to info@fintechcircle.com. Our VAT registration number is GB 201520868.

Our contact email address is info@fintechcircle.com

FINTECH Circle Institute offers Online Content and Courses from educators/lecturers and educational institutions globally (“Course Providers“).

2. Using the Website (Learner conduct)

2.1 By accessing and/or using this Website and the Online Content and Courses (by whatever means or device and whether as a Visitor or a Learner), you confirm that you have read, agree and are in compliance with these Terms, the Privacy Policy, and all applicable local, national and international laws, rules and regulations (each as amended from time to time). Use of the Website and access to the Online Content and Courses by anyone under the age of 13 is strictly prohibited.

2.2 Your use of and access to this Website and the Online Content and Courses is subject to the following conditions (“Acceptable Use Conditions”), and you agree that failure to comply with any one of the Acceptable Use Conditions will be a breach of these Terms by you:

you agree to use the Website and access the Online Content and Courses only for lawful purposes and in no way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;

you agree not to use the Website or access the Online Content and Courses for the purpose of harming or attempting to harm minors in any way;

you agree not to distribute all or any part of the Website or Online Content and Courses in any medium without our prior written consent, unless such distribution is offered through the functionality of the Website and permitted by these Terms including, without limitation, under section 7.11;

you agree not to alter or modify any part of the Website or any of the Online Content and Courses;

you agree not to access the Website or Online Content and Courses through any technology other than the software provided by us or enabled via API’s or other generally available third party web browsers such as Chrome, FireFox, Safari or Internet Explorer;

you agree not to (and not to attempt to) circumvent, disable or otherwise interfere with any security related features of the Website or features that (i) prevent or restrict use or copying of content or (ii enforce limitations on us, the use of the Website or access to the Online Content and Courses;

you agree not to knowingly transmit any data or send or submit any content that contains viruses, Trojan horses, worms, time-bombs, key-stroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware;

you agree not to use or access the Website or Online Content and Courses or any part of them for any commercial uses or for the benefit of any third party, including but not limited to: the sale of access to the Online Content and Courses or any associated content; the solicitation of business in the course of trade or in connection with a commercial enterprise; and the solicitation of, for commercial purposes, any Visitors or Learners of the Website with respect to their content

you agree to use the Website and access the Online Content and Courses in a way which does not infringe the rights of anyone else or restrict or prevent anyone else’s use and enjoyment of the Website, Online Content and Courses;

you agree not to ask for, collect or harvest any personal data of any Visitor or Learner of the Website or Online Content and Courses;

you agree not to post, upload, email or otherwise transmit to or otherwise cause us to email, transmit or otherwise distribute chain letters, surveys or studies, calls to action, junk mail, pyramid schemes, incentives (monetary or click-based), spimming or spamming, or bulk communications of any kind, whether or not for commercial or non-commercial purposes;

you will not copy, reproduce, create derivative works of, distribute, transmit, broadcast, display, sell, license, or otherwise exploit any content contained on the Website (including without limitation the Online Content and Courses) for any other purposes other than as permitted by these Terms without our prior written consent or the prior written consent of the respective licensors/owners of the Courses and Content on the Website;

you agree not to use the Website or the Online Content and Courses in any manner intended to damage, disable, overburden or impair any FINTECH Circle Institute server or the network(s) connected to any FINTECH Circle Institute server, or disobey any requirements, procedures, policies or regulations of any servers or networks connected to the Website;

you agree not to use any high volume, automated, or electronic means to access the Website or the Online Content and Courses (including without limitation robots, spiders or scripts);

you agree not to frame the Website or the Online Content and Courses, place pop-up windows over its pages, or otherwise affect the display of its pages;

you agree not to access or attempt to access any other Visitor or Learner’s account or falsely state, impersonate, or otherwise misrepresent your identity, including but not limited misrepresenting your affiliations with a person or entity, past or present;

you agree not to force headers or otherwise manipulate identifiers in order to disguise the origin of any communication transmitted through the Website; and

you agree not to send, knowingly receive, submit, download, use or re-use any material which does not comply with these Terms and our Privacy Policy.

2.3 You agree to comply with these Terms in relation to any Learner Content (as defined in paragraph 7.1 below) provided by you in connection with the Online Content and Courses and in connection with the ability to post messages (as further detailed in paragraphs 7.6 to 7.9 below).

2.4 We grant the operators of public search engines permission to use spiders to copy materials from the site for the sole purpose of creating publicly available searchable indices of the materials, but not caches or archives of such materials. We reserve the right to revoke these exceptions, either generally or in specific cases.

2.5 You acknowledge and agree that the form and nature of the Website and Online Content and Courses which we provide may change from time to time without prior notice to you.

2.6 Whilst we do all we can to ensure that the Online Content and Courses are of a high standard, you understand and acknowledge that, in using the Website and Online Content and Courses, you may be exposed to content from our Course Providers that is factually inaccurate, offensive if taken out of context, indecent to certain people, or otherwise objectionable to you. We are not responsible (legally or otherwise) for any claims you may have against us in relation to this type of content.

2.7 You acknowledge and agree that we may stop (permanently or temporarily) providing the Website, Online Content and Courses (or any part of the Online Content and Courses) to you or to Learners generally for whatever reason, at our sole discretion, without prior notice to you.

2.8 You agree that you are solely responsible for (and that we have no responsibility to you or to any third party for) any breach of your obligations under the Terms and for the consequences (including, but not limited to, any loss or damage which we or any third party may suffer) of any such breach.

3. Registration and Accounts

3.1 Any Visitor can view the Website, but in order to participate fully in all activities on the Website and take part in the Online Content and Courses, you must register for a personal account on the Website (a “Learner Account”) by providing a name, an email address and a password. You agree that you will never divulge or share access or your access information to your Learner Account with any third party for any reason.

3.2 In setting up your Learner Account, you may be prompted or required to enter additional information, including but not limited to your gender, date of birth and location. Additional information may also be required to confirm your identity, including (but not limited to) photographic identification for verification purposes.

3.3 You undertake to us that all information provided by you in relation to your Learner Account is and will continue to be accurate, current and complete at all times and that you will maintain and update your information to keep it accurate, current and complete.

3.4 You acknowledge that if any information provided by you in relation to your Learner Account is untrue, inaccurate, not current or incomplete, we reserve the right to suspend or terminate your access to and use of the Website and your enrolment in the Online Content and Courses

4. Student Conduct

4.1 By registering with FINTECH Circle Institute for a Learner Account, you agree (in addition to your obligations as a Learner above) that you:

(a) will not let anyone else use your Learner Account;

(b) credit the author if you quote anything from another place and that the comments and assignments you post are your own work.

(d) if you disagree with someone’s ideas you will discuss their ideas, rather than criticise or attack them personally.

(e) will not cheat on any assignment or exam relating to the Online Content and Courses, nor share solutions to homework assignments or exams; and

(f) you are here to learn, not to advertise products or services. You will not use the FINTECH Circle Institute for campaigning.

(g) you add to conversations and do not “spam” other learners by posting the same comment multiple times or by posting comments that are unrelated to the course.

4.2 If you are disqualified for any reason under paragraph 4.1 we may prohibit your access or participation in the Online Content and Courses.

5. Course Providers

5.1 Our Educators/Lecturers and partner institutions (together “Course Providers”) may make certain Online Content and Courses available to Learners.

5.2 Your access to such Online Content and Courses is provided to you through your Learner Account. You acknowledge and agree that any Online Content and Courses affiliated with a Course Provider may be subject to terms, policies and procedures of the applicable Course Provider in addition to these Terms.

5.3 We and the Course Providers reserve the right to cancel, interrupt or reschedule any Online Content and Courses or modify, revise, or alter its content, as well as the associated values, assignments, tests, quizzes, exams, projects and other evaluations of progress without cause or notice to you.

5.4 For some Online Content and Courses, subject to your satisfactory performance in the Online Content and Courses as determined, you may (in the sole discretion of us and the Course Providers) be eligible to purchase (or be awarded, as the case may be) products recording your participation in the relevant Online Content and Courses, including (but not limited to) a statement, certificate, acknowledgment or similar (a “Product”) issued by us and/or the Course Provider.

5.5 We may make certain revision books and study aids available for purchase while you are participating in the Online Content and Courses. We will provide links to third party websites to enable you to make these purchases. Enrolling in a recommended course as a member of a specific organisation on the FINTECH Circle Institute, or by direct invitation:

5.7 An organisation (which may be a FINTECH Circle Institute Partner, your employer, or a third party otherwise working together with the FINTECH Circle Institute) may invite you to (i) participate in a specific Course, or (ii) join their organisation on the FINTECH Circle Institute. By accepting the organisation’s invitation:

(a) you agree to abide by any additional terms and conditions, policies and procedures issued or made available to you prior to your acceptance of the invitation sent to you by the inviting organisation; and

(b) you agree that your information, including certain of your personal information and your progress and results throughout the duration of any Course you are invited to or which is recommended to you by the organisation, will be held by the FINTECH Circle Institute and the inviting organisation as data controllers in common (together, “we” or “us”) and you consent to us using your information to (i) provide you with information and services that you request; (ii) enable us to provide you with information that we feel may be of interest to you; (iii) allow us to log and maintain your information as part of your records for the purpose of assessing the effectiveness of the course, or track your progress for accreditation purposes; (iv) enable us to determine the levels of engagement, progression and
performance on the course; and/or (v) for other legitimate business interests.

6. Learners Licence to use

6.1 Subject to your compliance with these Terms, we grant you a fully revocable, worldwide, non-exclusive, non-transferable, non sub-licensable limited right and licence:

(a) to access, internally use and display the Website and Online Content and Courses as an individual only at your location solely as necessary to browse and/or participate in the Online Content and Courses as permitted by these Terms; and

(b) to download permitted content from the Online Content and Courses so that you may exercise the rights granted to you by these Terms.

6.2 You must abide by all copyright notices or restrictions contained on the Website or the Online Content and Courses. You may not delete any attributions, legal or proprietary notices on the Website or the Online Content and Courses.

6.3 Certain Partner Institutions may, at their own discretion, make available certain Online Content and Courses under a Creative Commons licence (non-commercial). Should Partner Institutions choose to do this, it will be clearly identified on the appropriate Online Content and Courses page of the Website and we acknowledge that the Creative Commons licence will override certain of these Terms as appropriate. A full copy of the relevant Creative Commons licence will be available from a link at that point.

7. Your Learner Content

7.1 Throughout your use of the Website, Courses and Content, we may provide you with the ability to provide content in the form of uploading notes and replies, Learner discussions, profile pages, and other content and media for social interaction, or certain information and materials for use with the Website or Online Content and Courses, e.g., written assignments, surveys, questions, hypothetical, examples, etc. (collectively, “Learner Content”).

7.2 We do not claim ownership of any Learner Content you may submit or make available for inclusion on the Website or Online Content and Courses. Accordingly, subject to the licence granted to us and any applicable Partner Institution, the Learner will be the sole and exclusive owner of any and all rights, title and interest in and to the Learner Content.

7.3 With respect to any Learner Content you submit to us (including, but not limited to, for inclusion on the Website or Online Content and Courses) or that is otherwise made available to us, you grant us an irrevocable, worldwide, perpetual, royalty-free and non-exclusive licence to use, distribute, reproduce, modify, adapt, publicly perform and publicly display such Learner Content on the Website and/or in the Online Content and Courses or otherwise exploit the Learner Content, with the right to sublicense such rights for any purpose associated with the provision of the Website and the Online Content and Courses. We reserve the right to remove any Learner Content without notice at any time and for any reason.

7.4 To the extent that you provide any Learner Content, you represent and warrant that:

(a) you have all necessary rights, licences and/or clearances to provide such Learner Content and permit us to use and publish such Learner Content as provided in paragraph 7.1 to 7.3 above;

(b) such Learner Content is accurate and complete to the best of your knowledge and belief;

(c) as between you and us, you are responsible for the payment of any third party fees related to the provision, publication and use of such Learner Content; and

(d) such use and/or publication of your Learner Content does not and will not infringe or misappropriate any third party rights or constitute a fraudulent statement or misrepresentation.

7.5 With respect to any submissions of Learner Content, you agree to comply with all applicable laws including but not limited to laws regarding online conduct and acceptable content. Specifically, you agree to comply with all applicable laws regarding the transmission of technical data exported from the country in which you reside.

7.6 The Website and/or the Online Content and Courses may provide you with the ability to post notes and replies, take part in group discussions, submit assignments or send similar messages and communications to third party service providers, other Learners and/or us.

7.7 You agree to use communication methods available on the Website and/or the Online Content and Courses only to send communications and materials related to the subject matter for which we (or any applicable educational partner) provided the communication method, and you further agree that all such communications by you are subject to and governed by these Terms and our Privacy Policy.

7.8 By using any of the communications methods available on the Website and/or the Online Content and Courses, you agree that:

(a) all communications methods constitute public, and not private, means of communication between you and the other party or parties;

(b) communications sent to or received from third party service providers or other third parties are not endorsed, sponsored or approved by us in any manner (unless expressly stated otherwise by us); and

(c) most content will be reactively moderated if flagged by Learners or Visitors but we reserve the right to pre-review or post-review Learner Content to ensure that it complies with generally acceptable standards of communication.

7.9 Additionally, through such communication methods set out in paragraph 7.8 above, we may make certain types of services available to you. For instance, we may make available to you, in connection with your participation in any Online Content and Courses, chat room services that allow you to communicate with our staff members and/or staff members of our Course Providers so that you may ask questions about the academic materials in the Online Content and Courses or about your general experiences on the Website.

7.10 You acknowledge and agree that the services set out in paragraphs 7.6 to 7.9 above (including without limitation chat room services) may be monitored or recorded for quality control purposes and that the information or material provided as part of the services is included within these Terms and is provided for educational purposes only.

7.11 Any Learner Content that is published on the public discussion areas of the Website (for example, the forums or areas where posts are made) will be subject to a Creative Commons Licence. We will not make available any Learner Content related to your assignments or assessments.

8. Online Courses/Content provided by Courser Providers/Lecturers

provider/lecturer) with the ability to provide content in the form of online classes, uploading background course materials, notes and replies, Learner discussions, profile pages, and other content and media for social interaction, or certain information and materials for use with the Website or Online Content and Courses, e.g., written assignments, surveys, questions, hypothetical, examples, etc. (collectively, “Course Provider Content”).

8.2 We do not claim ownership of any Course Provider Content you may submit or make available for inclusion on the Website or Online Content and Courses. The Course Provider/Lecturer will be the sole and exclusive owner of any and all rights, title and interest in and to the Content.

8.3 With respect to any Content you submit to us (including, but not limited to, for inclusion on the Website or Online Content and Courses) or that is otherwise made available to us, you grant us an irrevocable, worldwide, perpetual, royalty-free and non-exclusive licence to use, distribute, reproduce, modify, adapt, publicly perform and publicly display such Course Provider Content on the Website and/or in the Online Content and Courses or otherwise exploit the Course Provider Content, with the right to sublicense such rights for any purpose associated with the provision of the Website and the Online Content and Courses. We reserve the right to remove any Courses without notice at any time and for any reason.

8.4 To the extent that you provide any Online Courses, you represent and warrant that:

(a) you have all necessary rights, licences and/or clearances to provide such Content and permit us to use and publish such Content as provided in paragraph 8.1 to 8.3 above;

(b) such Content is accurate and complete to the best of your knowledge and belief;

(c) as between you and us, you are responsible for the payment of any third party fees related to the provision, publication and use of such Content; and

(d) such use and/or publication of your Content does not and will not infringe or misappropriate any third party rights or constitute a fraudulent statement or misrepresentation.

8.5 With respect to any submissions of Content, you agree to comply with all applicable laws including but not limited to laws regarding online conduct and acceptable content. Specifically, you agree to comply with all applicable laws regarding the transmission of technical data exported from the country in which you reside.

8.6 The Website and/or the Online Content and Courses may provide you with the ability to post notes and replies, take part in group discussions, provide assignments or send similar messages and communications to third party service providers, your students/Learners and/or us.

8.7 You agree to use communication methods available on the Website and/or the Online Content and Courses only to send communications and materials related to the subject matter for which we provided the communication method, and you further agree that all such communications by you are subject to and governed by these Terms and our Privacy Policy.

8.8 By using any of the communications methods available on the Website and/or the Online Content and Courses, you agree that:

(a) all communications methods constitute public, and not private, means of communication between you and the other party or parties; ,/p>

(c) most content will be reactively moderated if flagged by Learners or Visitors but we reserve the right to pre-review or post-review Content to ensure that it complies with generally acceptable standards of communication.

8.9 Additionally, through such communication methods set out in paragraph 8.8 above, we may make certain types of services available to you. For instance, we may make available to you, in connection with your participation in any Online Content and Courses, chat room services that allow you to communicate with our staff members and/or your students so that you may ask questions about the academic materials in the Online Content and Courses or about their general experiences on the Website and progress in your course.

8.10 You acknowledge and agree that the services set out in paragraphs 8.6 to 8.9 above (including without limitation chat room services) may be monitored or recorded for quality control purposes and that the information or material provided as part of the services is included within these Terms and is provided for educational purposes only.

8.11 Any Content that is published on the public discussion areas of the Website (for example, the forums or areas where posts are made) will be subject to a Creative Commons Licence.

9. FINTECH Circle Institute’s Intellectual Property Rights

9.1 We are the owner or the licensee of all necessary intellectual property rights in all aspects of the Website and Online Content and Courses including but not limited to the technology, source code, all content, software, scripts, images, graphics and audio (the “Online Content and Courses IPR”). The Online Content and Courses IPR is protected to the fullest extent possible by copyright laws. All such rights are reserved. You agree that the Online Content and Courses IPR remains the property of us or the licensor, as applicable, and that all updates and modifications to the Online Content and Courses IPR will vest in us or the licensor, as applicable. You also agree that you have no rights in or to the Online Content and Courses IPR other than the right to use it in accordance with the terms of the licence
in paragraph 6 above. Unless otherwise stated, copyright in the Online Content and Courses belongs to the relevant Course Providers/Lecturers providing the Online Content and Courses.

9.2 Other than any content submitted to the Website by you, we own or are licensed to use all present and future copyright, registered and unregistered trade marks, design rights, unregistered designs, database rights and all other present and future intellectual property rights and rights in the nature of intellectual property rights existing in or in relation to the Website (“FINTECH Circle Institute IPR”).

9.3 If any Online Content and Courses IPR or FINTECH Circle Institute IPR vests in you, whether by operation of law or
otherwise, you duly assign to us all right, title and interest (whether legal or beneficial) in such Online Content and
Courses IPR or FINTECH Circle Institute IPR, as the case may be, throughout the world to the fullest extent possible,
including any and all renewals and extensions of such Online Content and Courses IPR or FINTECH Circle Institute IPR.
You unconditionally and irrevocably waive any and all moral rights you may have either now or in the future existing in
or in connection with the Online Content and Courses or the Website.

9.4 You agree to sign and provide all such deeds, documents, acts and things as we may reasonably require in order to
assign any Online Content and Courses IPR and/or FINTECH Circle Institute IPR to us, to carry out the intended purpose
of these Terms, or to establish, perfect, preserve or enforce our rights under these Terms.

Your responsibility for others who access our website using your device or internet connection

You must ensure that any persons who access our website on your computer(s) or device(s), or who are permitted or able
to access our website on your computer(s) or device(s), or who use your internet connection, are aware of these Terms
of Use and all other documentation referred to in them, and that such persons also agree to be bound by and to comply
with these Terms of Use. If for any reason whatsoever, such persons do not agree to these Terms of Use or do not wish
to be bound by them, they must not access or use our website, and you must not permit them to do so.

Availability of our website

We make no representations and provide no warranties that:

the website will be made available at any specific time or from any specific geographical location;
your access to the website will be continuous or uninterrupted; or
the website will be accessible or optimised on all browsers, computers, tablets, phones or viewing platforms.

We reserve the right to suspend access to all or part of the website for any reason, including for business or operational reasons, such as improving the appearance or functionality of the website, content updates, periodic maintenance, or to resolve any issues that we become aware of. Wherever we anticipate that we need to suspend access to the website for a considerable period of time, we will try to provide you with prior notice where reasonably practicable.

Our website is provided for users in the United Kingdom only. Although it may be possible to access the website from
other countries, we make no representation that our website is compliant with any legal requirements in force in any jurisdiction other than the United Kingdom, or that the content available on the website will be appropriate for users in other countries or states.

Changes we may make to these Terms of Use and other documentation

We reserve the right to update these Terms of Use, our privacy policy, our cookies policy and any other documentation
referred to in any of these documents from time to time. We may change our Terms of Use and other documentation for any
reason, including:

to reflect any changes in the way we carry out our business;
to account for any changes we make to our website, including, without limitation, any new features or
functionality we provide, any adjustments to the means by which we provide notices to you, or any changes in the
content, purpose or availability of the website;
to accurately describe our current data-processing activities so that you are kept up to date with our latest
practices;
to inform you of any changes in the way that we use cookies or similar information-gathering technologies; or
to ensure that our documentation complies and remains compliant with any and all current and future applicable
laws, regulations and official guidance.

If required by law, we will provide you with notice of any changes in these Terms of Use or the other documentation
referred to in them by posting a notice on the website and/or by posting an updated version of these Terms of Use or
other such documentation on our website with a new effective date stated at the beginning of them.

By continuing to access our website after we have updated our Terms of Use, terms of sale, and/or user content
agreement, you agree to be bound by those updated versions. You also acknowledge that by continuing to access our
website after we have updated our privacy policy and/or our cookies policy, that the practices set out in those updated
policies will apply to our handling of your information and our use of cookies and similar technologies.

You must check these Terms of Use and all other documentation referred to in them each time you access our website in
order to ensure that you are aware of the terms that apply to you at that time.

The date that these Terms of Use and/or any other documents (including our privacy policy and cookies policy) were last
amended is set out at the top of that document and is referred to as that document’s “effective date”.

Your account details

If we provide you with account information such as a user name, identification number, account code and/or password,
you must keep such information confidential and secret and not disclose it to anyone. All account information is
provided for use of the named account holder only, and not for any other person. You are responsible for any
consequences of unauthorised access to your account due to any disclosure of your account information to any third
party.

Where we provide you with the option to select your own login information, including a password, we recommend that you
supply login information unique to your own use of this website, and do not use information from other accounts you may
hold with other websites or any easily discoverable information about you. You are responsible for any consequences of
unauthorised access to your account due to any disclosure of your login information to any third party.

You must never use another user’s account without permission. When creating your account, you must provide accurate and
complete information. You agree that you will not solicit, collect or use the login credentials of other individuals.
We prohibit the creation of, and you agree that you will not create, an account for anyone other than yourself. You
also represent that all information you provide to us upon registration and at all other times will be true, accurate,
current, and complete. You agree to update your information as necessary to maintain its truth and accuracy.

We reserve the right to withdraw access to your account without notice for any actual or suspected breach of these
Terms of Use or any other documentation referred to in them, including, without limitation, where we suspect that there
has been unauthorised access to your account, or any unauthorised disclosure of your login information.

If you know or suspect that the confidentiality of your login information has been compromised, for example, by the
disclosure of such information to any third party, you must immediately change your password. If you are unable to
change your password, you must immediately notify us by email, at info@fintechcircle.com

Ownership of material on our website

All trade marks, service marks, trade names, logos, copyright and other intellectual property rights in our website and
its content are either owned by us or licensed to us. All such rights are protected by intellectual property laws
around the world, and all rights are reserved. Any use of the website and its contents, other than as specifically
authorised herein, is strictly prohibited. Any rights not expressly granted herein are reserved by us.

The trade marks, service marks, trade names, logos and other branding owned by third parties and used or displayed on
or via our website (collectively, “Third Party Mark(s)”) may be trade marks of their respective owners, who may or may
not endorse or be affiliated with or connected with us. Except as expressly provided in these Terms of Use, or in terms
provided by the owner of a Third Party Mark, nothing in these Terms of Use or on or via the website should be construed
as granting, by implication, estoppel, or otherwise, any licence or right to use any of our or any Third Party Marks
that are used or displayed on the website, without the respective owner’s prior written permission, in each instance.
All goodwill generated from the use of our trade marks will benefit us exclusively.

Information and content on our website provided on non-reliance basis

Our website is made available to you in order to provide you with general information about us, our business, and any
products or services that we offer from time to time. We do not make our website available for any other purposes,
except as expressly provided in these Terms of Use.

The content on our website is not intended to be construed as advice. You must not rely on any of the content of our
website for any purposes whatsoever, and you must seek your own independent professional advice before deciding to take
any course of action on the basis, whether in whole or in part, of any of the content available on our website at any
time.

We make no representations and provide no warranties whatsoever, whether express or implied, that any of the content or
materials available on our website from time to time are accurate, up to date or complete.

Permitted use of materials on our website

The content on our website is provided for your personal, private and non-commercial use only. You may print or share
the content from our website for lawful personal, private and non-commercial purposes, and you may also make others
within your organisation aware of the content on our website. You may not otherwise extract, reproduce or distribute
the content of our website without our prior written consent.

Whenever you print, download, share or pass on content from our website to others, you must not make any additions or
deletions or otherwise modify any text from our website, you must not alter or change any images, media or graphics
from our website in any way, you may not remove any accompanying text from such images, media or graphics, and you must
ensure that all content passed on to any third party is an accurate representation of the content as it appears on our
website.

You are prohibited from using any robots, spiders, data mining or scraping technology or any similar third party tools
for the extraction or reproduction of any data or content from our website without our prior written consent.

Whenever you pass on any content or materials from our website to anyone, you must acknowledge us as the authors of
such content or materials (or any other authors wherever credited by us) at the time when you pass on such content or
materials.

Prohibited uses of our website

You must not reproduce, duplicate, copy or resell any part of our website or any content from our website, save and
except to the extent expressly permitted in these Terms of Use.

You must not, without our prior written consent, access, interfere with, damage or disrupt in any way our website or
any part of it, our systems, any of our hardware or equipment or any networks on which our website is hosted, any
software that we use to create or modify the website or to make the website available to you, or any hardware,
equipment, network, server, software or technology owned or operated by us or any third party.

You must use our website for lawful purposes only and in accordance with these Terms of Use. You must not use our
website:

for any purpose that is unlawful or that in any way breaches any applicable laws or regulations, whether local,
national or international;
for any fraudulent purposes whatsoever;
to conduct any unsolicited or unauthorised advertising or direct or indirect marketing to anyone by any means, or
to otherwise spam, communicate with or market to anyone any goods, services or business not authorised by us;
to upload, host or transmit any viruses, malware, adware, spyware, worms, Trojan horses, keystroke loggers,
spyware, logic bombs, time bombs or any other harmful programs or code which could adversely affect the use or
operation of the website, our hardware or systems, or the computers, tablets, phones or other devices of any users
or other third parties, or to upload any content or materials containing any such content;
to communicate with, harm or attempt to harm children in any way; or
in any way or for any purpose that breaches these Terms of Use or the terms of any of the documents these Terms
of Use refer to.

You must not submit any information about you to us if you are under the age of 18, or about any other person who is
either:

under the age of 18; or
if they are aged 18 or above, where you have not received their prior written consent to submit information about
them to us.

You must not submit to us any information which is considered ‘sensitive personal information’. ‘Sensitive personal
information’ is information about you or any other person which reveals your or their racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership or which is genetic data, biometric
data, information which concerns your or their health, sex life or sexual orientation.

If you accidentally or intentionally submit such information to us, you will be considered to have consented to our
processing of that information on the basis of Article 9(2)(a) of the General Data Protection Regulation (Regulation
(EU) 2016/769).

Viruses and other harmful content

We do not guarantee that our website does not contain viruses or other malicious software.

We shall not be responsible for any bugs or viruses on our website, or any software that might be transferred to your
computer from our website, or any consequences which the presence or operation of such programs may have.
You must ensure that you have in place up-to-date and effective anti-virus protection on your computer or other
browsing device.

You must not upload or otherwise introduce to our website any viruses, malware, spyware, adware, Trojan horses, worms,
logic bombs, time bombs, keystroke loggers or any other programs or code that is harmful or malicious.

You must not use any third parties, software or technology to attempt to gain unauthorised access to our website, our
servers, systems, hardware, software or data.

You must not attempt to perform any denial of service type attack on our website.

You must not perform any action which would contravene the Computer Misuse Act 1990.

We may report any breach or suspected breach of this clause 19 (Viruses and other harmful content) to the relevant
authorities and may disclose your identity.

Links to other websites

Links to third party content or websites may appear on our website from time to time. We are not responsible for the
content of any websites accessible via any link(s) on our website. All content on third party websites is outside of
our control, and we do not represent or warrant that such content is related to us or our website, suitable or
appropriate for use or viewing, lawful or accurate.

Any third party website accessible via a link on our website may collect and process your information. We are not
responsible for any data-processing activities carried out by any third party website which is linked to from our
website, and we disclaim any and all liability in respect of the same. You should check the privacy policy of any such
third party to establish how they may use your information before you decide to use their website and its features.

Links to our website

You may not link to our website without our prior written consent. Where you have obtained our consent to link to our website:

you may provide links to our website on other websites owned by you, provided that such websites and the use of any links to our website comply with these Terms of Use;

wherever you post a link to our website on any other website, you agree that you will do so in an appropriate manner, and not in any way which is defamatory or disparaging towards us, which misrepresents us or our business, or which causes any harm whatsoever to us or our business; and you must not link to our website in order to suggest any form of joint venture, partnership, collaboration, affiliation, business relationship, approval or endorsement in connection with us where none exists and in any event, without having first obtained our prior written consent.

We may withdraw permission to link to our website at any time. In the event that we withdraw permission to link to our website and inform you of the same, you must immediately remove or cause to be removed any links to our website.

EXCLUSIONS AND LIMITATIONS OF LIABILITY

We do not exclude our liability to you where it would be unlawful to do so, for example, for death or personal injury caused by our negligence. If applicable law does not allow all or any part of the below limitations of liability to apply to you, the limitations will apply to you only to the maximum extent permitted by applicable law.

SUBJECT TO THE AFORESAID, IN NO EVENT SHALL WE (INCLUDING OUR PARENTS, SUBSIDIARIES, AFFILIATES, OFFICERS, DIRECTORS, MEMBERS, EMPLOYEES OR AGENTS) UNDER ANY CIRCUMSTANCES WHATSOEVER BE LIABLE TO YOU FOR ANY LOSS, DAMAGE (WHETHER DIRECT, INDIRECT, PUNITIVE, ACTUAL, CONSEQUENTIAL, INCIDENTAL, SPECIAL, EXEMPLARY, OR OTHERWISE) COSTS, EXPENSES, LIABILITIES
OR PENALTIES, WHETHER IN CONTRACT, TORT, BREACH OF STATUTORY DUTY OR OTHERWISE, WHETHER FORESEEABLE OR UNKNOWN, ARISING FROM, IN CONNECTION WITH OR RELATING TO:

YOUR USE OF OUR WEBSITE;

ANY CORRUPTION OR LOSS OF DATA;
ANY INABILITY TO ACCESS OUR WEBSITE, INCLUDING, WITHOUT LIMITATION, ANY INTERRUPTIONS, SUSPENSION OR WITHDRAWAL
OF OUR WEBSITE (FOR ANY REASON WHATSOEVER);
ANY USE YOU MAKE OF ANY CONTENT OR MATERIALS ON OUR WEBSITE, INCLUDING ANY RELIANCE YOU MAKE ON SUCH CONTENT OR MATERIAL;
ANY LOSS OF SAVINGS, PROFITS, SALES, BUSINESS OR REVENUE;
ANY LOSS OF REPUTATION OR GOODWILL;
ANY LOSS OF SAVINGS;
ANY LOSS OF A CHANCE OR OPPORTUNITY; OR
ANY OTHER SECONDARY, CONSEQUENTIAL OR INDIRECT LOSSES,
AND EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH LOSS OR DAMAGE, WITHOUT LIMITATION, YOU ASSUME AND SHALL BE LIABLE FOR THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR OR CORRECTION IN THE EVENT OF ANY SUCH LOSS, DAMAGE, COSTS, EXPENSES, LIABILITIES OR PENALTIES ARISING.

WE SHALL NOT BE LIABLE FOR ANY DAMAGE THAT YOU COULD HAVE AVOIDED BY FOLLOWING OUR ADVICE TO APPLY AN UPDATE OFFERED TO YOU FREE OF CHARGE OR FOR DAMAGE THAT WAS CAUSED BY YOU FAILING TO CORRECTLY FOLLOW INSTALLATION INSTRUCTIONS OR TO HAVE IN PLACE THE MINIMUM SYSTEM REQUIREMENTS ADVISED BY US.

You specifically agree that we shall not be liable for any content or the defamatory, offensive or illegal conduct of any third party and that the risk of harm or damage from the foregoing rests entirely with you.

YOU AGREE THAT IN THE EVENT THAT YOU INCUR ANY DAMAGES, LOSSES OR INJURIES ARISING OUT OF, OR IN CONNECTION WITH, OUR ACTS OR OMISSIONS, THE DAMAGES, IF ANY, CAUSED TO YOU ARE NOT IRREPARABLE OR SUFFICIENT TO ENTITLE YOU TO AN INJUNCTION PREVENTING ANY EXPLOITATION OF ANY WEBSITE, SERVICE, PROPERTY, PRODUCT OR OTHER CONTENT OWNED OR CONTROLLED BY US, AND YOU WILL HAVE NO RIGHTS TO ENJOIN OR RESTRAIN THE DEVELOPMENT, PRODUCTION, DISTRIBUTION, ADVERTISING, EXHIBITION OR EXPLOITATION OF ANY WEBSITE, PROPERTY, PRODUCT, SERVICE, OR OTHER CONTENT OWNED OR CONTROLLED BY US.

To the extent that any of the provisions of this clause 22 (EXCLUSIONS AND LIMITATIONS OF LIABILITY) are unenforceable as outright exclusions of liability, they shall be construed as limitations on liability, limiting our liability to you to the maximum extent permitted by law.

INDEMNIFICATION

You (and also any third party for or on behalf of whom you operate an account or activity on the website) agree to defend (at our request), indemnify and hold us harmless from and against any claims, liabilities, damages, losses and expenses, including, without limitation, reasonable legal and attorneys’ fees and costs, arising out of or in any way
connected with any of the following (including as a result of your direct activities on the website or those conducted on your behalf):

your uploads, access to or use of the website;
your breach or alleged breach of these Terms of Use;
your violation of any third-party right, including, without limitation, any intellectual property right,
publicity, confidentiality, property or privacy right;
your violation of any laws, rules, regulations, codes, statutes, ordinances or orders of any governmental and
quasi-governmental authorities, including, without limitation, all regulatory, administrative and legislative
authorities; or
any misrepresentation made by you.

You will cooperate as fully required by us in the defence of any claim. We reserve the right to assume the exclusive defence and control of any matter subject to indemnification by you, and you will not, in any event, settle any claim without our prior written consent.

DISCLAIMERS

THE WEBSITE IS PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. TO THE FULLEST EXTENT PERMISSIBLE BY LAW, WE DO NOT MAKE ANY REPRESENTATIONS OR WARRANTIES OR ENDORSEMENTS OF ANY KIND WHATSOEVER, EXPRESS OR IMPLIED, AS TO:

THE SERVICE;
THE WEBSITE CONTENT;
USER CONTENT; OR
SECURITY ASSOCIATED WITH THE TRANSMISSION OF INFORMATION TO THE WEBSITE.

IN ADDITION, WE HEREBY DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, TITLE, CUSTOM, TRADE, QUIET ENJOYMENT, SYSTEM INTEGRATION AND FREEDOM FROM COMPUTER VIRUS.

WE DO NOT REPRESENT OR WARRANT THAT THE SERVICE WILL BE ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, OR THAT THE SERVICE OR THE SERVER THAT MAKES THE SERVICE AVAILABLE IS FREE FROM ANY HARMFUL COMPONENTS, INCLUDING, WITHOUT LIMITATION, VIRUSES. WE DO NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT THE INFORMATION (INCLUDING ANY INSTRUCTIONS) ON THE SERVICE IS ACCURATE, COMPLETE OR USEFUL. YOU ACKNOWLEDGE THAT YOUR USE OF THE WEBSITE IS AT YOUR SOLE RISK. WE
DO NOT WARRANT THAT YOUR USE OF THE WEBSITE IS LAWFUL IN ANY PARTICULAR JURISDICTION, AND WE SPECIFICALLY DISCLAIM SUCH WARRANTIES. SOME JURISDICTIONS LIMIT OR DO NOT ALLOW THE DISCLAIMER OF IMPLIED OR OTHER WARRANTIES SO THE ABOVE DISCLAIMER MAY NOT APPLY TO YOU TO THE EXTENT SUCH JURISDICTION'S LAW IS APPLICABLE TO YOU AND THESE TERMS OF USE.

BY ACCESSING OR USING THE WEBSITE YOU REPRESENT AND WARRANT THAT YOUR ACTIVITIES ARE LAWFUL IN EVERY JURISDICTION WHERE YOU ACCESS OR USE THE SERVICE.

WE DO NOT ENDORSE CONTENT AND SPECIFICALLY DISCLAIM ANY RESPONSIBILITY OR LIABILITY TO ANY PERSON OR ENTITY FOR ANY LOSS, DAMAGE (WHETHER ACTUAL, CONSEQUENTIAL, PUNITIVE OR OTHERWISE), INJURY, CLAIM, LIABILITY OR OTHER CAUSE OF ACTION OF ANY KIND OR CHARACTER BASED UPON OR RESULTING FROM ANY CONTENT.

AGE RESTRICTIONS ON USE OF OUR WEBSITE

Our website and any products or services available on or via the website are not intended for use by individuals under the age of 18.

IF YOU ARE UNDER THE AGE OF 18, YOU MUST NOT USE OUR WEBSITE, PURCHASE OR ATTEMPT TO PURCHASE ANY OF OUR PRODUCTS OR SERVICES, OR SUBMIT ANY INFORMATION ABOUT YOU OR ANYONE ELSE TO US.

We do not knowingly or intentionally process information about any individual under the age of 18.

26. Copyright Policy

26.1 It is our policy that any content included on the Website or within the Online Content and Courses that infringes, or is likely to infringe, the intellectual property rights of any third party will be removed from the Website as soon as possible after we are made aware of such infringement or potential infringement.

26.2 If you are the owner of intellectual property rights, or are authorised to act on behalf of an owner, or authorised to act under any exclusive right, you should report any alleged infringements of your intellectual property rights taking place on or through the Website by emailing a Copyright Infringement Notice to learn@FINTECHCircle.com,
containing at a minimum the details outlined in section 10.4 below.

26.3 We will take whatever action, in our sole discretion, we deem appropriate, including the removal of the challenged content.

26.4 When you notify us, your written Copyright Infringement Notice must contain the   following:

a statement telling us you believe that you have found content on the Website   which you believe infringes your intellectual property rights;

which country your intellectual property rights apply to;

the title of the content concerned and the full URL for access to that content;

a statement explaining how the content infringes your intellectual property rights;

your mailing address, telephone number and email address so that we can   contact you;

a statement that the information contained in the notice is accurate and that you   are the owner of the intellectual property rights or have an exclusive right in law   to bring infringement proceedings in respect of its use; and

your signature (an electronic signature is sufficient).

Credit and logo

The copyright in these Terms of Use is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. Unless expressly indicated otherwise, all intellectual property rights in this document and elsewhere on our website, including any content on our website, are reserved.

These Terms of Use are based on a General Data Protection Regulation (Regulation (EU) 2016/769) (“GDPR”) compliant template provided by GDPR Privacy Policy. For further information, please visit www.gdprprivacypolicy.org

28. Other Important Terms

28.1 If any of these Terms are found to be illegal, invalid or unenforceable by any court of competent jurisdiction, the remainder of these Terms remain in full force and effect.

28.2 Only you and we are entitled to enforce these Terms. No third party is entitled to enforce any of these Terms, whether by virtue of the Contracts (Rights of Third Parties) Act 1999 (which is expressly excluded) or otherwise.

28.3 We may freely transfer or assign any part of our rights or delegate our obligations under these Terms. You are not entitled to transfer or assign, by operation of law or otherwise, any part of your rights or delegate your obligations under these Terms without our prior written consent.

28.4 These Terms and the Privacy Policy set out the entire agreement between you and us and replace any and all prior terms, conditions, warranties and/or representations to the fullest extent permitted by law. Any delay or failure by us to exercise any right we may have under these Terms does not constitute a waiver by us of that right.

Governing law and jurisdiction

These Terms of Use, any documents they refer to, and any disputes arising from or in relation to them or any documents they refer to, whether contractual or non-contractual, shall be governed by and construed in accordance with English law.

The courts of England and Wales shall have exclusive jurisdiction over any claims or disputes arising from or in relation to these Terms of Use and any documents they refer to.

Selection of Book Co-Authors and Competition Rules

Introduction

The AI Book Series is a range of globally crowd-sourced books on topics relevant for the financial technology community globally.

Entry is open to best Fintech entrepreneurs, investors, advisors, financial services experts and thought leaders globally, no matter if you work for a small fintech start-up or a large organization or where you are based or if you are already a well-known Fintech Thought leader or somebody who has not yet been discovered.

Guidelines

Use of a false name or details will result in disqualification.

All entries must be made directly by the person entering the competition.

Entries made online using methods generated by a script, macro or the use of automated devices will be void.

No responsibility can be accepted for entries lost or corrupted.

If your abstract is being selected and you are invited to write your complete article, this right is non-transferable to another individual or company.

We reserve the right to reject entries from entrants not entering into the spirit of the competition.

Promotion

The contributor agrees that your name, company name & title, profile photo (from LinkedIn or Twitter), company logo and your website/twitter account can be mentioned and promoted when your abstract is submitted and shared with the public prior to releasing the final book.

The Contributor authorises the Publisher and the Editors to make any amendments to the Contribution which the Publisher may deem desirable in the interests of uniformity and style of the Work and publish your abstract on our website www.FINTECHCircle.com.

Selection Process

Selection will be the result of public voting (ranking the abstracts based on how many users liked the content) to arrive at a shortlist which then will be further analysed by the Editors and Publisher to arrive at the final list of Contributors who will be invited to write an article for the book.

The decision of the Editors and the Publisher is final based on the criteria set out on this website. The crowd-sourcing and crowd-voting process may be modified and enhanced at any time.

A list of “final authors” will be available after the editing process is completed.

Quality of Contributions

The Contributor agrees to prepare an original and previously unpublished abstract.

You may not upload any material which  (a) is libelous, defamatory, obscene, pornographic, abusive, harassing or threatening, or otherwise objectionable,  (b) contains viruses or other contaminating or destructive features,  (c) violates the rights of others, such as by infringing any copyright, trademark, patent, or trade secret or violating any right of privacy or publicity,  (d) constitutes unauthorized or unsolicited advertising, junk or bulk e-mail, or any form of lottery or gambling, chain letters or marketing/pyramid schemes, or the selling or trading of any merchandise, (e) contains links to sites that violate these Terms of Use, such as pornographic sites, defamatory sites, and so on,
or (f) otherwise violates any applicable law.

Voting Process

The voting window will be published on our book website www.FintechCircle.com
Every registered user can vote for all his & her favourite abstracts by liking them and providing a Star rating. Each Contributor of an abstract can also vote for both his/her own abstract and also all the other abstracts which are of great interest.

Contributors are encouraged to share their abstracts with their own fintech communities, clients and partners and invite them to vote as well.

After the public voting process is completed, a shortlist of the most popular abstracts will be prepared for the Editors and the Publisher to review and make the final selection by January 2019.

>www.fintechcircle.com/cookies-policy

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Google Mail (Gmail). Their privacy policy is available here: https://policies.google.com/privacy

Contact form

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Transfer and storage of your information

Google’s privacy policy is available here: https://policies.google.com/privacy

WP Engine’s privacy policy is available here: https://wpengine.co.uk/legal/privacy/.

Amazon Web Services, AWS’ privacy policy is available here: https://aws.amazon.com/privacy/

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Transfer and storage of your information

Information about your phone call will be stored by our third party telephone service provider within the European Economic Area.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Information we collect when you interact with our website

E-Newsletter

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, MailChimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Use of web beacons and similar technologies in emails

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: www.fintechcircle.com/cookies-policy

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://mailchimp.com/legal/privacy/

Registering on our website

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us

Transfer and storage of your information

WP Engine, the privacy policy of which is available here: https://wpengine.co.uk/legal/privacy/.

Amazon Web Services, AWS, the privacy policy of which is available here: https://aws.amazon.com/privacy/

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use the third party payment processor PayPal.

Transfer and storage of your information

Paypal is located in North America. Information relating to the processing of your payment is stored outside the European Economic Area on Paypal’s servers in North America.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our goods and services

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third party service to administer our mailing list, MailChimp.

Use of web beacons and similar technologies in emails

For more information on how we use web beacons in our emails, see our cookies policy which is available here: www.fintechcircle.com/cookies-policy

For more information about our third party mailing list provider and how they use web beacons, please see their privacy policy which is available here: https://mailchimp.com/legal/privacy/

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Our use of automated decision-making and profiling

We use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

Automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement. We currently do not use automated decision making.

Profiling

Use of profiling for web analytics

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Use of profiling in marketing emails

Logic involved: By analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, and click through rates.

How to object: You can object to our use of web beacons by emailing info@fintechcircle.com

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

Disclosure and additional uses of your information

This section sets out the circumstances in which we disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. These include the following:

Telephone provider(s), including Vodafone. Their privacy policy is available here:

https://www.vodafone.co.uk/about-this-site/our-privacy-policy/

Email provider(s), including Google. Their privacy policy is available here:

https://policies.google.com/privacy

Hosting provider(s), including AWS and WP Engine. Their privacy policy is available here:

https://aws.amazon.com/privacy/https://wpengine.co.uk/legal/privacy/

Apart from Vodafone which are located in the UK, our service providers are located in the United States.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

Advisors

Affiliates

Business partners

Independent contractors

Insurers

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement of our legal rights

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

How long we retain your information

Retention periods

Server log information: we retain information on our server logs for 6 years.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
whether we have any legal basis to continue to process your information (such as your consent);
how valuable your information is (both now and in the future);
any relevant agreed industry practices on how long information should be retained;
the levels of risk, cost and liability involved with us continuing to hold the information;
how hard it is to ensure that the information can be kept up to date and accurate; and
any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
using secure servers to store your information;
verifying the identity of any individual who requests access to information prior to granting them access to information;
using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website.

Transmission of information to us by email

Transfers of your information outside the European Economic Area

Server log information

https://aws.amazon.com/privacy/

https://wpengine.co.uk/legal/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Contact form

https://aws.amazon.com/privacy/

https://wpengine.co.uk/legal/privacy

https://www.wufoo.com/privacy/

https://policies.google.com/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Email

https://policies.google.com/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

E-Newsletter

https://mailchimp.com/legal/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Online Surveys

https://www.surveymonkey.com/mp/legal/privacy-policy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Google Analytics

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Your rights in relation to your information

to request access to your information and information related to our use and processing of your information;
to request the correction or deletion of your information;
to request that we restrict our use of your information;
to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message;
sending an email to info@fintechcircle.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

Sensitive Personal Information

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Major changes to our Privacy Policy or the purposes for which we process your information

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Contents

Summary

Your rights in relation to your information

Our details

Information we collect when you visit our website

Web server log information

Use of website server log information for IT security purposes

Use of website server log information to analyse website use and improve our website

Cookies and similar technologies

Information we collect when you contact us

Email

Transfer and storage of your information

Contact form

Transfer and storage of your information

Phone

Transfer and storage of your information

Post

Information we collect when you interact with our website

E-Newsletter

Transfer and storage of your information

Use of web beacons and similar technologies in emails

Registering on our website

Transfer and storage of your information

Information we collect when you place an order on our website

Information collected when you place an order

Mandatory information

Processing your payment

Transfer and storage of your information

Marketing communications

Our goods and services

Transfer and storage of your information

Use of web beacons and similar technologies in emails

How we collect or obtain information about you from third parties

Information received from third parties

Where we receive information about you in error

Information obtained by us from third parties

Our use of automated decision-making and profiling

Automated decision making

Profiling

Use of profiling for web analytics

Use of profiling in marketing emails

Disclosure and additional uses of your information

Disclosure of your information to service providers

Disclosure of your information to other third parties

Transfer and storage of your information

Accountants

Advisors

Affiliates

Business partners

Independent contractors

Insurers

Disclosure and use of your information for legal reasons

In connection with the enforcement or potential enforcement of our legal rights

In connection with a legal or potential legal dispute or proceedings

For ongoing compliance with laws, regulations and other legal requirements

How long we retain your information

Retention periods

Criteria for determining retention periods

How we secure your information

Transmission of information to us by email

Transfers of your information outside the European Economic Area

Server log information

Contact form

Email

E-Newsletter

Online Surveys

Google Analytics

Your rights in relation to your information

Verifying your identity where you request access to your information

How we verify your identity

Your right to object to the processing of your information for certain information

Sensitive Personal Information

Changes to our Privacy Policy

Minor changes to our Privacy Policy

Major changes to our Privacy Policy or the purposes for which we process your information

Children’s Privacy

Copyright, credit and logo

Our details

2. Using the Website (Learner conduct)

3. Registration and Accounts