This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Data we collect from you when you visit our world of learning at www.spartickles.com and use our services.

General Information
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.

What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

Who is responsible for data processing?
The entity responsible for data processing, is Spartickles Ltd of Office 1814, 182-184 High Street North, East Ham, London E6 2JA, United Kingdom (“Spartickles”, “we”, “us”, or “our”) acting as the data controller in accordance with the UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).

If you have any questions about this policy or our data protection practices, please contact us using info@spartickles.com, use our Contact Form or write to us at the above address.

What are the legal bases of processing?
We only process your Personal Data if we have to have at least one of the reasons:

Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.

Contract – This is where we process your information to fulfil a contractual arrangement we have made with you or reply to your messages, emails, calls, etc.

Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for archiving or the investigation of crime.

Data we collect automatically
Log data
Even if you do not log in or register on our website, but simply browse our website, data is collected and stored and processed by us. Specifically, this requires the IP address of your computer, Date and time of access, Name and URL of the accessed file, Browser used, Number of bytes transferred, Status of the page retrieval, Session ID, Referrer URL. The legal basis for this processing is our legitimate interest.

Hosting
We host our website using the services of Hostinger. In this sense, Hostinger processes all data and communication data including IP addresses, that are provided to us through our website. This means that all data submitted to our website are transferred to Hostinger. The legal basis for processing is our legitimate interest.

Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

Cookie consent
Our website uses a so-called cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; e) Time of your visit to the website. The basis for processing is our legitimate interest and your consent.

Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.

Data we collect directly
Contacting us
If you contact us, we store and process the following data from you: Name, e-mail address, telephone number as well as other Personal Data that you provide when contacting us. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted, provided there is no legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.

Create an account
It is also possible for you to register for an account. For this purpose, you are asked to provide your full name, email address and country of residence. Further, you can choose a password together with your email address, both of which will enable you to log in more easily without having to enter your data again when you access our course portal. We will hold your data as long as you have your account with us and you have the option to delete your account with us at any time. The legal basis for processing is the provision or initiation of a contractual service and your consent.

Payment data
If you make a purchase your payment will be processed via the payment provider Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract for the use of the service.

Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.

Marketing
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

If you have signed up to receive our daily emails, we will use your email address to send you information about us, our services, promotions, and news using the services of Mailchimp by Intuit Inc on our behalf. You can revoke your consent to receive these emails or to the creation of personalised user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data.

Economic analyses and market research
For business reasons, we analyse the data we have on business transactions, contracts, enquiries, browsing behaviour etc., whereby the group of persons concerned may include contractual partners, interested parties, and users of our services.

The analyses are carried out for the purpose of business evaluations and market research. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarised data).This represents a legitimate interest.

Storage and retention
As far as necessary, we process and store your Personal Data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods. The retention and documentation periods specified there are two to six years.

Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Do not sell
We do not sell your Personal Data.

Sharing and disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services including our shipping forwarder and, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

International transfer
In the course of my website operation, we process data. We usually do not transfer Personal Data to countries outside the UK and the EEA. However, if we do, we will make sure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses for a high level of data protection.

Your rights and privileges
Privacy rights
You can exercise the following rights:
Right to information
Right to rectification
Right to deletion
Right to data portability
Right of objection
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is the Information Commissioner’s Office (ICO) who is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk However, we would appreciate the opportunity to address your concerns before you contact the ICO.

Does this policy change?
We may update our Privacy Policy from time to time. This might be for a number of reasons, such as to reflect a change in the law or to accommodate a change in our business practices and the way we use cookies. We recommend that you check here periodically for any changes to our Privacy Policy. This Privacy Policy was last updated on, 22nd January, 2025.

Who should I contact for more information?
If you have any questions or comments about our Privacy Policy or wish to exercise your rights under applicable laws, please contact us using info@spartickles.com.