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Privacy Policy

Effective 18 January 2021

Where this document refers to “Covert Venture Partners Limited”, “we”, “us” and “our” it means Covert Venture Partners Limited Covert Venture Partners Limited registered in England and Wales under registration number: 13004917 and has its registered office at 35 Swan Court, Chelsea Manor Street, London, SW3 5RX.

This Privacy Policy explains:

  • What information we collect and why;

  • how we collect, use and secure information collected;

  • international transfers of data;

  • the choices we offer, including how to access and update information;

  • how we will respond to data breaches.

What information do we collect and why?

We may collect personal information including the name, email address, phone number, country of residence and, where relevant, name of employer and position title. From time to time we might also collect other information volunteered by users (that is, entered on our system or our website or provided to our team) or given to us with consent of users or by use of cookies.

The reasons we collect, store, process and use this kind of information include:

  • to identify and authenticate users, including administrators and associated users;

  • for support or response purposes, when users request support or make an inquiry;

  • to plan, improve, tailor, optimise and promote our products and services for users;

  • to provide users with relevant information that we believe might be of interest to users, which we may do by email;

  • to manage users’ accounts;

  • to provide users with a digital learning record; and

  • for contractual and other lawful legitimate business purposes or for the establishment, exercise or defence of legal claims.

We do not collect more data than is necessary for the above purposes.

If we engage third party service providers, they may also be given access to some or all of the above information for similar purposes.

All such third parties are bound by the same laws and regulations that we are, wherever they are located in the world, and we require them to adopt and apply data protection policies and practices that are consistent with this policy.

Users need to understand that their choice not to provide certain personal information, as described above, will limit or prevent their ability to access and use our products and services.

How do we collect information?

We ordinarily ask for consent from users to collect, process, manage, store and use personal information, as set out in this policy, including when users purchase our products or services, as a prerequisite to such purchase. When users contact us they will voluntarily provide the kind of information set out above.

How long do we hold information?

We hold information only for so long as is necessary for the purposes set out above; in this, we are guided by our contractual obligations and by other lawful legitimate business interests.

Accessing, updating and deleting personal information

Upon registration, users have ongoing access to their online accounts, within which they can correct inaccuracies or update or add information. Additionally, they can request us to:

  • make changes to their accounts, including to personal information;

  • send to them, or to transmit to another controller, all of their stored personal information (in which case we will do so in a structured, commonly used and machine-readable format);

  • restrict processing of specific personal information; or

  • delete information.

As mentioned above, these actions or requests will limit the ability of users to access and use our products and services.

It may be the case that, for contractual or other lawful legitimate business purposes, we retain and use an archived version of users’ personal information, which may be pseudonymised, anonymised or otherwise de-identified.

We have facilities in place to request affiliates and other third parties, as necessary, to amend or delete personal information held on their systems.

Information security

We work hard to protect our users from misuse, interference, loss, unauthorised access, modification or disclosure of information we hold. In doing so, we apply technical and organisational measures to ensure a level of security appropriate to the risk including:

  • analysing and assessing privacy and security issues, risks and impacts during the design and development of new features and solutions for our products, services and delivery platform, governed by guidelines and security standards for our IT developers;

  • ensuring confidentiality, integrity, availability and resilience of processing systems and services;

  •  as we deem necessary, pseudonymisation and encryption (e.g., using SSL) of data; for example, for the purpose of transfers, when data is encrypted and access is restricted at rest.

We are guided in these activities by ISO/IEC 27001:2013, the international standard that describes best practice for an information security management system.

International transfers

Any international transfers are governed by internal controls and rules, consistent with this policy and the relevant legislation and regulation, including the GDPR.

Cookies and log files

We allow limited use of various technologies to collect and store information when users visit our website; this may include using cookies (i.e. a string of unique data that a website stores on a user’s computer and that the user’s browser provides to the website each time the user returns) or similar technologies to identify the user’s browser or device. This helps us to optimise our users’ experience and to continually improve and tailor our products and services for users.

We may log IP addresses, browser types and dates/times, which assist with our support efforts, diagnoses of user-initiated issues and queries, and audits for security purposes.

Privacy breach

We acknowledge the various data breach obligations in each of the jurisdictions in which we operate. We commit to promptly identify and respond to any breaches, to act to prevent harm and to report, if and as required, to the relevant supervisory authority and users.

Changes to Privacy Policy

Our Privacy Policy may change from time to time. We will keep prior versions of this Privacy Policy in an archive for review by users upon request.

Complaints, inquiries and requests

Requests to access, update, restrict or delete personal information can be made to Covert Venture Partners via emailing or writing to Covert Venture Partners, 35 Swan Court, Chelsea Manor Street, London, SW3 5RX.

Privacy Policy: Files
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