Privacy Policy

January 27, 2024

Policy version: 24 October 2022

https://blockscholes.com (our website) is provided by Block Scholes Ltd (we, our or us). We are the controller of personal data obtained via our website and via our platform, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website and our platform. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).

Given the nature of our website and our platform, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website or with our platform please let us know so that we can delete that data.

‍

WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of our website and our platform.

In the course of your use of our platform we may link to websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

‍

PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on the particular activities carried out through our website and our platform. We will collect and use the following personal data about you:

your name, address and contact information, including email address and telephone number and company details where relevant
information to check and verify your identity, e.g. date of birth
location data, if you choose to give this to us
your billing information, transaction and payment card or other payment method information
bank account and payment details
details of any information, feedback or other matters you give to us by phone, email, post or via social media
your account details, such as username and login details
your activities on, and use of, our website and our platform
your personal or, where relevant, your professional interests
information about the services we provide to you
your contact history, purchase history and saved items
information about how you use our website and our platform
your responses to surveys, competitions and promotions
you usage history of our platform, including history of the analysis performed on our platform.

You must provide this personal data to use our website, our platform and the services on them unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website, our platform or any services on them.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

‍

HOW YOUR PERSONAL DATA IS COLLECTED

We collect personal data from you:

directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase services via our website or our platform, post material to our website or our platform and complete customer surveys or participate in competitions via our website or our platform, and
indirectly, such as your browsing activity while on our website or your activity when using our platform; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.
We use Google Analytics 4 (GA4), a service provided by Google LLC, to track and analyse user behaviour on our website. This helps us understand how our website is being used and allows us to improve our services and user experience

‍

HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, for example:

where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party;
The data collected via GA4 is used for analytical purposes, such as optimising the functionality of our website and enhancing user experience. This data does not include personally identifiable information, such as your name or email address.
‍GA4 complies with data protection regulations, including the General Data Protection Regulation (GDPR) and the ePrivacy Directive. We ensure that all data collected respects user privacy preferences and adheres to current regulatory standards. For more information on how Google processes data, you can read the Google Privacy Policy.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

‍

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Create and manage your account with us

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

To perform our contract with you or to take steps at your request before entering into a contract

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us	To comply with our legal and regulatory obligations For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Customise our website, our platform and our content to your particular preferences based on a record of your selected preferences or on your use of our website	Depending on the circumstances: your consent as gathered when you register with us — see ‘Cookies and other tracking technologies’ below where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Depending on the circumstances: your consent as gathered when you register with us — see ‘Cookies and other tracking technologies’ below where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can

	deliver the best service to you at the best price
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

‍

HOW AND WHY WE USE YOUR PERSONAL DATA: SHARING

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

‍

MARKETING

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us using the details set out in this Privacy Policy; or
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations outside of our group for marketing purposes without your consent.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

‍

WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with:

third parties we use to help deliver our services to you, e.g. payment service providers, warehouses and delivery companies;
other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers;
our banks.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency — usually,

information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

‍

WHO WE SHARE YOUR PERSONAL DATA WITH: FURTHER INFORMATION

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

‍

HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will not keep your personal data for longer than we need it for the purpose for which it is used. If you stop using your account we will delete or anonymise your account data after seven years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

‍

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We may transfer your personal data to third parties located outside the UK who provide services to us or who assist us in the provision of our services to you.

As we are based in the UK we will also transfer your personal data from the EEA to the UK.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR;
in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR;
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to

Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

‍

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA: FURTHER INFORMATION

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

‍

COOKIES AND OTHER TRACKING TECHNOLOGIES

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to manage your preferences, to remember your previous actions when navigating our website in the same session, and for maintaining session credentials to enable you to access secure areas of the website).

‍

The table below provides a summary of the cookies we use and why:

Name	Purpose	Is this cookie essential?
blockscholesui_preferences	To manage your preferences	Yes – we will therefore not request your consent before placing this cookie
blockscholesui_state	To remember your previous actions when navigating our website in the same session, and	Yes – we will therefore not request your consent before placing this cookie
blockscholesui_credentials	For maintaining session credentials to enable you to access secure areas of the website	Yes – we will therefore not request your consent before placing this cookie

‍