PRIVACY POLICY
Last Updated 22/12/2020
INTRODUCTION
Thank you for visiting the CTI Academy website. At CTI Academy, we value your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, and secure your data when you visit our websites, including cti-academy.com and citytradersimperium.com, and when you use our software applications. If you have any questions or concerns, please reach out to us via email at admin@cti-academy.com or support@cti-academy.com For reference, you can find the General Data Protection Regulation ((EU) 2016/679) (GDPR) online.
If you need to make a complaint regarding data protection issues, you have the right to contact the Information Commissioner’s Office (ICO), the supervisory authority for data protection in the UK. However, we encourage you to communicate with us first should any issues arise.
Below, you will find our contact details. If you require additional information, please do not hesitate to email us. Please note that we will not engage in any contact if you are under 18 years old.
We are committed to adhering to data protection laws and principles. As such, we ensure that your data is:
- Used lawfully, fairly, and transparently.
- Collected only for legitimate purposes that have been clearly explained to you, and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have informed you about and limited to only what is necessary.
- Accurate and kept up to date.
- Retained only for the duration required for the purposes we have communicated to you.
- Stored securely.
In the following sections, we will explain how we collect and process your data, including the information you provide to us. Please be aware that our new website, CTI Academy, is the platform for our trading courses.
If you have any further questions or need assistance, please don’t hesitate to reach out.
US AS A DATA CONTROLLER
It is vital that you are aware of our identity and contact details. Please find our complete information below:
Full name of legal entity: City Traders Imperium Limited Email address: admin@cti-academy.com
Postal address: 124 Kemp House, City Rd, EC1V 2NX, London, UK
Should you have any further questions or require additional information, please do not hesitate to reach out to us.
CHANGES ‎
We continuously review and update our Privacy Policy to ensure its accuracy and relevance. Your assistance in keeping your personal data up to date is valuable to us. Please promptly notify us using the contact details provided above if there are any changes to your personal information during our relationship. Ensuring the accuracy of your data is a mutual responsibility, and we appreciate your cooperation in helping us serve you better.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?‎
We collect personal information about you through the following methods:
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Direct Interactions: We collect information, including Identity, Contact, Financial, and Marketing and Communications Data, when you willingly provide it to us. This can happen when you fill in forms on our website or other service sites, or when you correspond with us via email or chat. Examples include registering to use our sites, subscribing to our services, searching for a service, or reporting any issues with our services or sites. Any correspondence you have with us will be recorded.
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Automated Technologies or Interactions: When you interact with our sites, we may automatically collect technical data about your device, browsing actions, and patterns. This is done through the use of cookies, server logs, and similar technologies.
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Information from Other Sources: We may receive personal data about you from third parties and publicly available sources, including:
- Technical Data: This may come from analytics providers like Google (based outside the EU), advertising networks, and search information providers.
- Contact, Financial, and Transaction Data: We may receive this data from providers of technical, payment, and delivery services.
- Identity and Contact Data: We may acquire this data from data brokers or aggregators, as well as publicly available sources.
Please be assured that we only collect personal information that is necessary and relevant for the purposes stated in our Privacy Policy.
If you have any questions or need further clarification, please feel free to reach out to us.
SO, WHAT DO WE COLLECT AND HOW DO WE HOLD IT?‎
We collect various types of personal data about you, which we may use, store, and transfer as necessary. This primarily includes:
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Identity Data: This includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
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Contact Data: This encompasses your billing address, delivery address, email address, and telephone numbers.
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Financial Data: This consists of your bank account and payment card details.
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Transaction Data: This incorporates details about payments made by you, products and services purchased from us, as well as information relating to any legal services we offer or propose to provide.
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Technical Data: This refers to your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
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Usage Data: This includes information about your use of our websites or services, such as traffic data, communication data, and the resources you access. This may be required for billing purposes or for other purposes related to providing our services.
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Profile Data: This encompasses your username and password, interests, preferences, feedback, and survey responses.
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Marketing and Communications Data: This covers your preferences in receiving marketing communications from us and our third parties, as well as your communication preferences.
To clarify the terms we use, personal data, or personal information, refers to any information that can identify an individual. However, it does not include data where the identity has been removed (anonymous data). We do not collect any Special Categories of Personal Data about you, which may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic and biometric data. Additionally, we do not collect any information about criminal convictions and offenses.
Please note that our website and business are explicitly not intended for individuals under the age of 18. Hence, if you fall under this category, please log out immediately.
If you have any queries or require further information, feel free to contact us.
THIRD PARTIES
When providing your consent to share personal data with us, we will also request your consent to disclose that data to third parties for the purposes outlined in this policy. These third parties, termed External Third Parties, function as processors and are based overseas. They offer IT and system administration services.
Additionally, third parties may consist of entities to whom we may choose to sell, transfer, or merge parts of our business or assets. Conversely, we may also consider acquiring or merging with other businesses. In such cases, the new owners may employ your personal data in the same manner as described in this privacy policy.
However, please be assured that we impose strict requirements on all third parties to uphold the security of your personal data and handle it in accordance with the law. We prohibit our third-party service providers from using your personal data for their own purposes. They are only permitted to process your personal data for specified purposes and in accordance with our instructions.
HOW AND FOR WHAT PURPOSE MIGHT WE USE INFORMATION ABOUT YOU?‎
We will only use your personal data when permitted by law. Below are some common reasons for using your data, although this list is not exhaustive:
Consent: When you have provided explicit consent for the processing of your personal data.
Contractual Necessity: When it is necessary to perform a contract that we have entered into or are about to enter into with you.
Legitimate Interests: When processing is necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests.
Legal or Regulatory Obligations: When we need to comply with a legal or regulatory obligation.
It is important to note that, in general, we do not rely on consent as the sole legal basis for processing your personal data, except in cases of sending third-party direct marketing communications via email or text message. You have the right to withdraw consent for marketing purposes at any time by contacting us using the details provided earlier in this policy.
To provide further insight into our purposes, below is a description of how we plan to use your personal data and the legal bases we rely on, including our legitimate interests where applicable. We may rely on more than one lawful ground for processing your personal data, depending on the specific purpose. If you require specific details about the legal grounds we are relying on, please contact us.
Purpose/Activity: To register you as a new customer Types of data: Identity, Contact Legal Basis: Your consent
Purpose/Activity: To process and deliver your order, manage payments, collect debts, and provide software application services Types of data: Identity, Contact, Financial Transaction, Marketing and Communications Legal Basis: Your consent, Performance of a contract with you, Necessary for our legitimate interests (debt recovery)
Purpose/Activity: To manage our relationship with you, including notifying you of service changes Types of data: Identity, Contact, Profile, Transactions, Marketing and Communications Legal Basis: Your consent, Performance of a contract with you, Necessary for our legitimate interests (record-keeping, customer analysis), Necessary to comply with legal obligations (terms and conditions updates)
Purpose/Activity: To administer and protect our business, troubleshoot, and conduct system testing Types of data: Identity, Contact, Technical Legal Basis: Necessary for our legitimate interests (business administration, IT services, network security)
Purpose/Activity: To use data analytics to improve our website, products/services, and marketing Types of data: Technical, Usage Legal Basis: Necessary for our legitimate interests (customer segmentation, website improvement, business development, marketing strategy)
Please note that we may process your personal data for multiple lawful grounds, depending on the specific purpose. If you require more detailed information about the legal grounds we rely on for specific processing activities, please contact us.
AND IF YOU DON’T GIVE US ANY PERSONAL DATA?‎
If you choose not to provide us with any personal data, it may impact our ability to fulfill our contractual obligations or provide you with the requested courses or services in accordance with the law. In such cases, we may be required to cancel a course or service that you have with us. If this situation arises, we will communicate with you and provide appropriate notification. Therefore, we kindly request that you provide us with the necessary details to ensure the proper performance of our contractual obligations. Please be assured that we have robust data protection measures in place to ensure the security and confidentiality of the information you provide. If there are any changes to your personal data, please promptly inform us of the updates.
YES, WE DO MARKETING OURSELVES
We may utilize your Identity, Contact, Technical, Usage, and Profile Data to analyze and better understand your preferences, interests, and requirements. This assists us in determining the courses, services, and offers that may be relevant to you (referred to as marketing). Rest assured, we will not inundate you with excessive marketing messages. However, unless you explicitly choose to opt out (instructions provided below), we may send you marketing communications if you have specifically requested information from us or have previously purchased services from us, provided that you have not opted out of receiving such marketing messages. We respect your control over the communications you receive from us.
THIRD-PARTY MARKETING
We prioritize the protection and confidentiality of your personal data. We want to assure you that we do not engage in third-party marketing practices. By entrusting us with your personal data, you can be confident that we will keep it private and secure. We will never disclose your personal data to any third party for marketing purposes.
OPTING OUT
As mentioned earlier, we firmly believe in giving you control over the communications you receive from us. If you wish to cease receiving marketing messages, you can exercise your right to opt out by reaching out to us at any time. Please contact us and let us know your preferences, and we will promptly stop sending you any further marketing messages.
COOKIES
Different individuals have varied opinions about cookies, with some expressing dislike towards them, while others appreciate the benefits they offer. We respect your preferences in this matter. Therefore, you have the option to configure your browser settings to either refuse all or certain types of browser cookies, or receive alerts when websites attempt to set or access cookies. However, it’s important to note that disabling or refusing cookies may restrict your access to certain parts or features of our website. To fully explore and enjoy the content on our website, it may be necessary to enable cookies.
CHANGE OF PURPOSE ‎
We have already provided you with information about the reasons and purposes for which we collect your personal data. It is important to note that we will only use your personal data for the purposes stated, unless we reasonably determine that we need to utilize it for another purpose that is compatible with the original intent. If you require further clarification regarding the compatibility of our processing for the new purpose in relation to the original purpose, please feel free to contact us at support@cti-academy.com If we identify a need to use your personal data for an unrelated purpose, we will inform you and provide an explanation of the legal basis for such processing. However, please be assured that any processing of your personal data, even without your knowledge or consent, will only occur in compliance with the aforementioned rules and where it is required or permitted by law.
INTERNATIONAL TRANSFERS
While we acknowledge that we live in a globalized world, it’s important to note that your personal data will not be transferred or stored outside of the European Economic Area (EEA) or the country where you and your authorized users are located, except for potential transfers to the United States of America. The transfer of your personal data to the United States is permitted due to an adequacy decision made in accordance with GDPR Art. 45. This means that the United States has met the necessary standards of data protection as determined by the European Union. If you require further details or information regarding these transfers, we are more than happy to provide you with additional information.
SECURITY AND RETENTION
We assure you that the information you provide us is stored on secure servers. However, it is essential for you to play your part in maintaining the security of your data. If we have provided you with a password to access certain parts of our sites or platforms, it is your responsibility to keep this password confidential and not share it with anyone else.
We have implemented strict procedures and security features to prevent accidental loss, unauthorized access, or improper use of your personal data. In the event of any suspected personal data breach, we have established procedures to address the issue, including notifying you and relevant regulatory authorities as required by law.
Additionally, we are obligated by law to fulfill certain requirements. We will retain basic information about our clients, including Contact, Identity, Financial, and Transaction Data, for a period of six years after the client relationship ends to comply with tax, regulatory, and insurance purposes. In some cases, we might anonymize your personal data for research or statistical purposes, rendering it no longer identifiable. If this occurs, we may use the anonymized information indefinitely without providing you with further notice.
Please note that our commitment to data security and retention aligns with legal obligations and industry best practices.
YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION - ACCESS, ‎CORRECTION, ERASURE, AND RESTRICTION ‎
At CTI academy, we believe in putting you in control of your personal information. In accordance with applicable laws, you have the following rights:
Access: You have the right to request access to your personal information, often referred to as a “data subject access request.” This allows you to obtain a copy of the personal information we hold about you and verify that we are lawfully processing it.
Correction: You have the right to request the correction of any personal information we hold about you. This enables you to rectify any incomplete or inaccurate information we may have.
Erasure: You have the right to request the erasure or deletion of your personal information. This allows you to ask us to remove or delete your personal information when there is no valid reason for us to continue processing it. You also have the right to request the erasure of your personal information when you have exercised your right to object to its processing (see below).
Objection: You have the right to object to the processing of your personal information when we rely on legitimate interests (or those of a third party) as the legal basis for processing. If there are specific circumstances related to your situation that make you want to object to the processing, you may do so. Additionally, you have the right to object to the processing of your personal information for direct marketing purposes.
Restriction: You have the right to request the restriction of processing of your personal information. This enables you to ask us to temporarily suspend the processing of your personal information, for example, if you want to verify its accuracy or the underlying purpose of processing it.
Data Portability: You have the right to request the transfer of your personal information to another party. This right applies when the processing of your personal information is based on your consent or the performance of a contract, and is carried out by automated means.
If you wish to review, verify, correct, or request the erasure of your personal information, object to the processing of your personal data, or request the transfer of your personal information to another party, please contact our data privacy manager in writing. Alternatively, you can reach out to us by phone, and we will be happy to assist you with the necessary arrangements.
NO FEE USUALLY REQUIRED ‎
We are committed to ensuring that you can exercise your rights regarding your personal data without any unnecessary financial burden. In general, you will not be required to pay a fee to access your personal data or to exercise any of the other rights mentioned above. However, please note that if your request is deemed to be clearly unfounded, repetitive, or excessive, we may ask you to pay a reasonable fee or choose to refuse your request in such cases. We will always provide a clear explanation if any charges apply and will ensure that they are in accordance with applicable laws and regulations.
WHAT WE MAY NEED FROM YOU
To protect the security and confidentiality of your personal data, we may need to request specific information from you in order to verify your identity and ensure your right to access your personal data or exercise any other rights. This is a necessary security measure to prevent unauthorized disclosure of personal data to individuals who are not entitled to access it. In some cases, we may also reach out to you to request additional information related to your request, which will help expedite our response and ensure its accuracy. We appreciate your cooperation in providing the requested information, as it allows us to effectively address your inquiries and protect your personal data.
TIME LIMIT TO RESPOND ‎
Our goal is to address all legitimate requests in a timely manner. Typically, we aim to respond to such requests within one month from the date of receipt. However, if your request is complex in nature or if you have submitted multiple requests, it may require more time to process. If this is the case, we will notify you and keep you informed of the progress. Rest assured that we are committed to handling your requests efficiently and will make every effort to provide you with a prompt and comprehensive response.
