PRIVACY POLICY
Last updated 1 May 2020
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1. INTRODUCTION
We may update this Privacy Policy from time to time, for example to reflect changes to our data privacy practices or for other operational, legal or regulatory reasons. In the event of material changes to this Privacy Policy, we will notify you by posting the updated policy on this website and, where appropriate, by other means. By continuing to use this website or the support service after such changes have been posted, you accept the modified Policy.
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2. USER DATA
We collect your first name, last name, email address, Instagram account, telephone number and payment details (for example, your debit/credit card information) directly from you.
We use this data to provide you with our services; for example, to verify your identity, contact you, provide you with advertising and marketing, and for billing purposes. We also use this data to ensure that we comply with legal obligations.
We collect personal information when you subscribe to our services, when you access our services or otherwise provide us with data.
We at Cash Flow Academy Limited work with a number of third parties and service providers to deliver our services to you and may share personal data with them as part of this collaboration.
We may also disclose your data in the following circumstances:
• to prevent, investigate or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement relating to the services, or as otherwise required by law;
• to conduct marketing and/or advertising campaigns;
• to comply with legal obligations or respond to valid subpoenas, court orders, warrants or other requests from public authorities (for example, to meet national security or law enforcement requirements).
Personal data may also be shared with a company that acquires our business through merger, sale, bankruptcy, dissolution, reorganization or other transaction or similar proceeding. If this happens, we will post a notice on our homepage.
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3. VISITOR DATA
When you visit or browse the websites of Cash Flow Academy Limited , we do not collect information about the device and browser you use, your network connection, your IP address and cookies installed on your device.
If you contact our telephone support service, we collect your telephone number, the audio of the call and other personal information you provide during the call. Under our Terms of Service, we may request additional documentation during our call to verify your identity.
If you use our chat support service, we collect your name, email address, information about the device and browser you use, information about your network connection, IP address, chat transcript and other personal information you provide during the chat. Under our Terms of Service, we may request additional documentation during the chat to verify your identity.
We use this information to verify, provide and improve our services (including support or maintenance) and to respond to any questions you may have.
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4. HOW LONG WE KEEP YOUR DATA
We retain your data for the duration of your relationship with us. Once your relationship with us ends, we generally continue to keep a copy of your personal information for legitimate business purposes, such as defending ourselves against contractual claims or for audit purposes and to fulfill legal obligations, unless we receive a valid deletion request and your personal data is deleted in accordance with our standard deletion process.
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5. HOW WE KEEP YOUR DATA SAFE
We follow industry standards on data security management to safeguard sensitive data such as financial information, intellectual property, employee data and any other personal information entrusted to us. Our information security systems apply to people, processes and IT systems based on risk management.
We perform annual reviews to ensure that credit card data is managed in accordance with industry guidelines.
No method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your information.
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6. PRIVACY POLICY LAW
The purpose of this privacy policy is to provide maximum transparency regarding the information that the site collects and how it uses it.
In compliance with the obligations under national legislation (Italian Legislative Decree 30 June 2003 no. 196, Personal Data Protection Code, and subsequent amendments, hereby fully referred to) and European legislation (European Regulation on the protection of personal data no. 679/2016, GDPR, hereby fully referred to), this site respects and protects the privacy of visitors and users, making every possible and proportionate effort not to infringe users’ rights.
Cash Flow Academy Limited uses the data for the purposes for which it is provided.
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7. DATA CONTROLLER
The Data Controller and Processor pursuant to applicable law is Cash Flow Academy Limited , which can be contacted via the CONTACTS section.
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8. LEGAL BASIS FOR PROCESSING
This site mainly processes data based on users’ consent. Consent is given when purchasing the service, or through use or consultation of the site as a conclusive behavior, or again through registration on the site or subscription to the service. By using or consulting the site, visitors and users approve this privacy policy and consent to the processing of their personal data in accordance with the methods and purposes described below, including any disclosure to third parties if necessary for the provision of a service.
Providing data and therefore consenting to the collection and processing of data is optional but automatic following the behaviors described above; the user may refuse consent and may revoke consent already given at any time by notifying Online Studio Prime Limited by email competenzeartificiali@gmail.com. However, refusal of consent may make it impossible to provide some services and may compromise the browsing experience on the site.
Data for site security and for the prevention of abuse and spam, as well as data for site traffic analysis (statistics) in aggregate form, are processed on the basis of the Data Controller’s legitimate interest in protecting the site and its users. In such cases, the user always has the right to object to the processing of data.
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9. PURPOSE OF PROCESSING
The processing of data collected by the site, in addition to purposes related, instrumental and necessary for providing the service, is aimed at the following purposes:
• Main activities: collection of data and information for the performance of the service as described in more detail in the Terms and Conditions, which for example but not limited to consists of primary and ancillary activities linked to social media management work.
• Statistics (analysis): collection of data and information exclusively in aggregate form, both anonymous and non-anonymous, to verify the correct functioning of the site.
• Security: collection of data and information to protect the security of the site (anti-spam filters, firewalls, virus detection) and of users and to prevent or uncover fraud or abuse against the website. Data is recorded automatically and may also include personal data (IP address) that could be used, in accordance with applicable law, to block attempts to damage the site itself or cause harm to other users, or otherwise harmful or criminal activities. Such data is never used for user identification or profiling and is periodically deleted.
• Ancillary activities: communication of data to third parties who perform functions necessary or instrumental to the operation of the service, and to enable third parties to perform technical, logistical and other activities on our behalf. Providers have access only to personal data necessary to perform their tasks and undertake not to use the data for other purposes, and are required to process personal data in accordance with applicable regulations.
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10. PLACE OF PROCESSING
Data is processed at the Data Controller’s registered office indicated in the “CONTACTS” section.
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11. USER RIGHTS
Pursuant to European Regulation 679/2016 (GDPR), the user may, in accordance with the procedures and within the limits provided by current legislation, exercise the following rights:
• object in whole or in part, for legitimate reasons, to the processing of personal data concerning them for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication;
• request confirmation of the existence of personal data concerning them (right of access);
• know the origin;
• receive intelligible communication;
• obtain information about the logic, methods and purposes of processing;
• request updating, rectification, integration, deletion, transformation into anonymous form, blocking of data processed in violation of the law, including data that is no longer necessary for the purposes for which it was collected;
• in cases of processing based on consent, receive, at the sole cost of any support, their data provided to the Data Controller, in a structured and machine-readable format and in a format commonly used by an electronic device;
• the right to lodge a complaint with the Supervisory Authority (Data Protection Authority);
• as well as, more generally, exercise all rights recognized by current law (requests must be addressed to the Data Controller).
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12. HOW WE PROTECT YOUR DATA
Although Cash Flow Academy Limited is a foreign company and stores data primarily in Italy, we provide services to people all over the world and our technology processes data of users residing everywhere. As a result, Cash Flow Academy Limited may transfer your data outside the country, state or province in which you reside.
Cash Flow Academy Limited processes data in compliance with privacy regulations of each country in which it operates.
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13. RESIDENTS IN THE EUROPEAN ECONOMIC AREA (“EEA”)
Cash Flow Academy Limited works with users around the world, including in the EEA. If you reside in the EEA, your personal data is processed in compliance with the laws of your country. As part of our service, we may transfer your data to other countries. In order to ensure that your data is protected when transferred outside the EEA, Cash Flow Academy Limited relies on the most advanced technologies.
If you reside in the EEA, you have certain rights under European law in relation to your personal data. If you wish to exercise these rights, please contact us using the details provided in the “CONTACTS” section.
If you are not satisfied with the response you receive from us, we encourage you to contact us again to resolve the issue, but you also have the right to lodge a complaint with the competent data protection authority in your jurisdiction at any time.
In addition, if you reside in the EEA, please note that we generally process your data in order to fulfill any obligations we may have towards you (for example, in relation to orders you have placed through the site) or otherwise to pursue our legitimate business interests as described above, unless the law requires us to obtain your consent for a particular processing activity. We process your data to pursue legitimate interests and in particular:
• to prevent risks and fraud on our platform;
• to provide communications, marketing and advertising;
• to offer reporting and analytics;
• to help you achieve the goals for which you subscribed to the service;
• to troubleshoot issues, provide support or respond to questions;
• to test additional features or services;
• to improve our services, apps and websites.
When we process personal data to pursue these legitimate interests, we do so where we believe that the nature of the processing, the information processed and the technical and organizational measures adopted to protect such information help to reduce risks for the data subject and, by purchasing the service, you give your consent.
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14. CONTACTS
If you wish to make a legal request or serve a subpoena or similar document requiring information about us, their stores or other parties whose data we process, please review our guidelines for legal requests.
If you have questions about your personal data or this policy, or if you wish to make a complaint about how Cash Flow Academy Limited processes your personal data, please contact Cash Flow Academy Limited by email at competenzeartificiali@gmail.com or using the contact details below:
Cash Flow Academy Limited
Company Registration Number: 14986664
Registered Address: UNIT 5 DRAKES COURTYARD 291 KILBURN HIGH ROAD, LONDON , ENGLAND NW6 7JR
