Privacy Policy


This privacy policy applies between you, the User of this Website (www.cdmacademy.co.uk) and CDM Academy LTD, the owner and provider of this Website. CDM Academy LTD takes the privacy of your information very seriously. This privacy policy explains what information CDM Academy LTD collects about you and why, what is done with the information, and how it is handled. 

CDM Academy LTD is a company registered in England and Wales under number 11834470 whose registered office is at The Coach House, Church Road, Oxley, Wolverhampton, WV10 6AB. In this privacy policy, CDM Academy LTD is referred to as ‘CDM Academy’, ‘we’, ‘us’ or ‘our’. 

 This privacy policy should be read alongside, and in addition to, the Terms and Conditions, which can be found at: www.cdmacademy.co.uk/terms. 

 

Please read this privacy policy carefully. 

Definitions and interpretation

In this privacy policy, the following definitions are used: 

Data

Collectively all information that you submit to CDM Academy LTD via the Website or otherwise. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws; 

Cookies

A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws

Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR

The General Data Protection Regulation (EU) 2016/679;

CDM Academy LTD, CDM Academy, we, us, or our

CDM Academy LTD, a company registered in England and Wales under number 11834470 whose registered office is at The Coach House, Church Road, Oxley, Wolverhampton, WV10 6AB.

UK and EU Cookie Law

The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011

User or you 

Any third party that accesses the Website and is not either (i) employed by CDM Academy LTD and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to CDM Academy LTD and accessing the Website in connection with the provision of such services; and

Website

The website that you are currently using, www.cdmacademy.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:  

  • the singular includes the plural and vice versa; 

  • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy; 

  • a reference to a person includes firms, companies, government entities, trusts and partnerships; 

  • "including" is understood to mean "including without limitation"; 

  • reference to any statutory provision includes any modification or amendment of it; 

  • the headings and sub-headings do not form part of this privacy policy. 

Scope of this privacy policy

This privacy policy applies only to the actions of CDM Academy and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites. 

For purposes of the applicable Data Protection Laws (the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR)), together with any implementing legislation, in particular, the Data Protection Act 2018, CDM Academy is the "data controller". This means that CDM Academy determines the purposes for which, and the manner in which, your Data is processed. This privacy policy applies to any and all information obtained by CDM Academy by your use of the information and services made available through the Website. 

In other words: CDM Academy is responsible for protecting your Data. This privacy policy applies to information obtained through your use of the Website and its services.

Collection of your Data

We collect information that, alone or in combination with other data, could be used to identify you (Personal Data), such as your name, contact information such as e-mail addresses and telephone numbers, and physical address. We may also collect anonymous demographic information which is not unique to you, such as your postal code, age, gender, preferences, interests and favourites (Non-Personal Data). Non-Personal Data is not linked to your Personal Data.

In other words: We collect information that could be used to personally identify you, such as your name and contact details. We may also collect information that is not personal to you and not linked to your personal information.

Data that is given to us by you

We will collect Data that you give us voluntarily, including your name, e-mail address, physical address, or telephone number. This is collected in a number of ways, for example: 

  • when you contact us through the Website, by telephone, post, e-mail or through any other means; 

  • when you register with us and set up an account to receive our products/services; 

  • when you enter a competition or promotion through a social media channel; 

in each case, in accordance with this privacy policy.

In other words: When you use the Website and the services made available through the Website, we will collect personal information that you provide voluntarily, such as your name, email address, telephone number, and physical address.

Data that is collected automatically

When you visit the Website, we automatically collect information about your visit. This information helps to make improvements to Website content and navigation, and includes your IP address, web browser type and version, the date, times and frequency with which you access the Website and the way you use and interact with its content. Data is collected automatically via cookies, in line with the cookie settings on your browser which you can change at any time. For more information about cookies, and how they are used on the Website, see the section below, headed "Cookies".

In other words: We automatically collect certain information about your visit when you use our Website. This information is used to analyse your use of the Website and improve our services.

Other information collected

We also collect the following information when you use the Website and its services: 

  • User uploads. This consists of all text, documents, content or information (for example; video or audio recordings which you submit to your tutor to demonstrate your instrumental practice) uploaded, entered, or otherwise transmitted by you in connection with your use of the Website. Please keep in mind that if you directly disclose personal information through the public sections of the Website, this information will be available for anyone on the internet to review and see.  

  • Lesson Recordings. When you use the online tuition services made available through the Website, we will use call-recorder technology to record video and audio content of all your lessons. We will only collect this Data with your written consent, which you can provide via a separate consent form when you decide to use our tuition services. 

In other words: If you upload any user content to the Website, or through any other means in connection with the Website, this may contain your personal information, which may be collected and used for the purposes described here.

We will also create and store audio and video recordings of your voice and musical performance during your lessons with your tutor, but only with your consent.

Our use of Data

We collect and use your Data as necessary to perform our contract with you and for Legitimate Business Interests, including to:

  • operate the Website and deliver the services. 

  • understand and improve how users use and interact with the services. 

  • communicate with you about the services you use, as well as respond to requests for assistance, including account support if you’re having difficulty accessing your account. We will send a welcome e-mail following registration to all registered users and will also periodically send service updates to registered users. 

  • display user content associated with your account and make sure it is available to you when you use our services. 

  • understand and improve how our users use and interact with our services. 

When you contact us through the Website, by telephone, post, e-mail or through any other means, register an account, or use the services made available through the Website, the legal basis for this processing is the performance of a Contract between you and CDM Academy and/or taking steps, at your request, to enter into such contract.  

We may contact you via e-mail with marketing materials that may be of interest to you. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in: 

  • soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.

  • For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.

If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below. 

In other words: We collect your personal information to perform the contract you enter into with us when you sign up to use our services. We also collect certain information when we have good reason to do so. We may send you marketing emails, but only with your permission.

Who we share Data with

We may share your Data with third parties:

  • when we use third party service providers to assist us in meeting business or operating needs, such as delivering and improving services, hosting the Website, communicating with users, e-mail communication, invoicing and payments, customer support services, and analytics. These service providers may only access, process, or store Data as required to perform their duties to us, and in accordance with applicable laws and regulations; or 

  • when we have your explicit consent to share your Data; or 

  • when we determine that disclosure is required to protect the rights, property, or personal safety of CDM Academy and the users of the Website, or to respond to lawful subpoenas, warrants, or requests by public or regulatory authorities, including requests by law enforcement authorities; or 

  • if we sell some or all of our business or assets, we may disclose your Data to the prospective seller or buyer of such business or assets, and if the transaction closes, your Data may be transferred to the buyer; 

in each case, in accordance with this privacy policy. 

In other words: We share your Data with third parties such as service providers. We also share your Data when we have your explicit consent, or if we are required to do so by law.

Transfers outside the European Economic Area

As part of the services offered to you through the Website, Data which we collect from you may be transferred and stored in countries outside of the European Economic Area (EEA). For example, this could happen if one of our service providers is located in a country outside the EEA. We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your Data. 

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws. 

In other words: We may transfer your Data to locations outside of the EEA, but only where there are appropriate safeguards in place. We may transfer your Data outside the EEA if, for example, one of our service providers is located in such a location.

Keeping Data secure

We use a range of technical and organisational measures to safeguard your Data, including measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: privacy@cdmacademy.co.uk.

All Data we collect is stored on secure servers, with protections from unauthorised access, use or disclosure. When Data is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Whilst we are committed to safeguarding your Data, we cannot guarantee the security of data which is transmitted to the Website or to another website via the internet or similar connection.

If we have given you (or you have chosen) a password to access certain areas of the Website, it is your responsibility to keep this safe. 

In other words: CDM Academy is committed to keeping your Data safe, however we cannot guarantee the security of information transmitted over the internet or similar connection. You can do your part by keeping your password safe.

For detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.  Even if we delete your Data, we reserve the right to maintain a copy for legal, tax or regulatory purposes. 

In other words: We'll retain your data for no longer than is necessary. For more information, contact privacy@cdmacademy.co.uk.

Your rights

Under the GDPR, you have various rights in relation to your Data. Please note that these rights are subject to certain limitations set forth in applicable law.

  • Right to access - the right to request copies of the information we hold about you at any time, or that we modify, update or delete such information.  

  • Right to correct - the right to have your Data rectified if it is inaccurate or incomplete. 

  • Right to erase - the right to request that we delete or remove your Data from our systems. 

  • Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it. 

  • Right to data portability - the right to request that we move, copy or transfer your Data. 

  • Right to object - the right to object to our use of your Data including where we use it for our legitimate interests. 

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: privacy@cdmacademy.co.uk.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it. 

In other words: You have certain rights in relation to your Data. Contact us or the ICO for more information.

Links to other websites

This Website provides links to other websites. CDM Academy has no control over such websites and cannot be responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them. 

In other words: We may link to other websites, whose privacy practices may differ from our own. We encourage you to carefully read the privacy policy on any other website you visit.

Children

CDM Academy does not intend to solicit or collect Data from anyone under the age of 18. If you are under 18, do not enter information on this Website or engage our services. If you believe a child under the age of 18 entered Data on the Website, please contact privacy@cdmacademy.co.uk to have the Data removed.

In other words: No one under the age of 18 should use this Website. Whilst we may provide our tuition services to a child under the age of 18, this Website should only be used by their parent/guardian.

Cookies

This Website uses “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your computer by a web page server. These cookies do not run programs or deliver viruses to your computer. 

One of the primary purposes of cookies is to provide a convenient feature to save you time. The cookie tells the server that you have returned to a specific page. For example, if you personalise the Website pages, or register with the Website, a cookie helps the Website recall your specific information on subsequent visits. This simplifies the process of recording your Data, such as contact information or site preferences. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customised. 

This Website may place the following Cookies:

Necessary Cookies

These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, use a shopping cart or make use of e-billing services.

Functionality Cookies

These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Analytical/Performance Cookies

These cookies collect and report anonymous information which allows us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.

Marketing Cookies

These cookies record your visit to the Website, the pages you have visited and the links you have followed. We Will use the information to make our Website more relevant to your interests. 

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies, or delete existing Cookies, however certain features of the Website may not function fully or as intended.

You can also enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser. 

Please note that third parties (including those linked to on the Website) may also use cookies, over which CDM Academy has no control. 

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law. For more information generally on cookies, including how to disable them, please visit aboutcookies.org. You will also find details on how to delete cookies from your computer. 

In other words: This Website uses cookies to enhance your online experience. If you do not want to receive cookies, you can reject them by opting out or modifying your browser settings.

Changes to this privacy policy

We reserve the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

In other words: We may change this privacy policy from time to time. We encourage you to review the policy regularly.

Contact information

You may contact us at any time via e-mail to privacy@cdmacademy.co.uk or via post to:

CDM Academy LTD 

New Beacon Group

Stafford Education & Enterprise Park

Stafford

ST18 0BF

 

Last updated: August 2019