Privacy

London Real’s Privacy Notice

At London Real, we respect your privacy and are committed to protecting your personal data. This privacy notice tells you about how we look after your personal data when you visit our website or use our app or otherwise communicate with us and it tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

1. [IMPORTANT INFORMATION AND WHO WE ARE]

2. [THE DATA WE COLLECT ABOUT YOU]

3. [HOW IS YOUR PERSONAL DATA COLLECTED]

4. [HOW WE USE YOUR PERSONAL DATA]

5. [DISCLOSURES OF YOUR PERSONAL DATA]

6. [INTERNATIONAL TRANSFERS]

7. [DATA SECURITY]

8. [DATA RETENTION]

9. [YOUR LEGAL RIGHTS]

 1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information about how London Real collects and processes your personal data through your use of our website or otherwise when you communicate or interact with us.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Longstem Limited, trading as London Real is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.

If you have any questions about this privacy notice, including any requests to exercise [your legal rights], please contact us using the details set out below.

Contact details

We are: Longstem Limited, trading as London Real with our registered office at 30 Market Place, London, W1W 8AP.

If you need to get hold of us for any reason in connection with your personal data, please email us at privacy@londonreal.tv

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns about data protection before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 23 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Website subscribers

  • Subscriber Data includes username, email address and password
  • Profile Data (all optional) includes your name, your biography, your interests, your skills, your location, your photo and your website comments
  • Usage Data includes information about how you use our website
  • Technical Data includes internet protocol (IP) address, your 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 this website.
  • Marketing Data includes your preferences in receiving marketing from us.

Academy subscribers

  • Subscriber Data includes name, phone number, email address, residential address
  • Payment Data includes bank card details
  • Online Training Data includes your responses to our questionnaire such as why you wish to join, your personal opinions/goals/objectives and any opinions expressed in your weekly course books. You may choose to provide us with “Sensitive Data” which includes information about your health or religious and political opinions. You do not have to give this to us. If you do, we will take this as a clear affirmative action signifying your agreement to the processing of your Sensitive Data for the purpose of online training. You may withdraw this right for us to process your Sensitive Data on your behalf at any time.
  • Correspondence Data includes email correspondence, website live chat, Zoom or Facebook video calls
  • Usage Data includes information about how you use our website and app
  • Technical Data includes internet protocol (IP) address, your 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 this website.
  • Marketing Data includes your preferences in receiving marketing from us.

For our business associates and others that interact with us

  • Contact Data includes name, position, business, email, phone, business address
  • Correspondence Data includes email correspondence notes and recordings of telephone conversations and Contact Data
  • Usage Data includes information about how you use our website.
  • Technical Data includes internet protocol (IP) address, your 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 this website.
  • Marketing Data includes your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 3.How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. We collect the majority of your data when you choose to give this to us on our website, by email, over the phone or otherwise.
  • Automated technologies or interactions.
    • Your email address if you choose to login through Google or Facebook
    • Third party payment service providers (such as Stripe or Paypal) when you make a payment for our academy courses
    • As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
    • We may receive Technical and Usage Data about you if you visit other websites employing our cookies including Google, Youtube and Facebook.
    • We may receive Technical and Usage Data about you from third party analytics providers) like Google and GoSquared, third party advertising networks and search information providers.

Our cookies: You can choose to disable or refuse certain cookies that we use where these are not essential for the operation of our website. If you choose to do so, some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, and how to disable them, please see our Cookie Policy.

 4.How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To provide the services to you in accordance with our Website terms of use or our Academy terms and conditions or other agreement that we have with you; or
  • Where it is necessary for our legitimate interests (or those of a third party) and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to manage our relationship with you and to improve the service that we offer).
  • Where we need to comply with a legal or regulatory obligation;
  • Where we have your freely given, specific and informed consent to use your data for a particular purpose.

Please contact us at privacy@londonreal.tv if you need details about the specific legal ground we are relying on to process your personal data.

Opting out

We may use your Subscriber, Profile, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have opted in to do so or if you have created an account with us and, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the unsubscribe links on any marketing message sent to you.

You can also opt out from any non-marketing message we send you (e.g. with free tips and advice), simply by following the unsubscribe link.

 5.Disclosures of your personal data

We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

  • Our service providers acting as processors who may have servers based in the US or outside the EEA who provide customer relations support, IT support, IT backup, data storage, email management and system administration services.
  • Analytics and advertising service providers which may have servers based in the US or outside the EEA – for the purpose of analysing user behaviour & retargeting
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Debt collection agents where we need to recover debts owed to us.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 6. International transfers

A number of our service providers processing your personal data on our behalf are based or have servers based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that either:

  • we have a specific contract with that processor in a form approved by the European Commission which ensures that service provider gives your personal data the same protection it has in Europe; or
  • if the provider is based in the US, it is a member of the US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us at privacy@londonreal.tv if you want further information on the specific mechanisms used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to erase your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right in certain circumstances to:

  • Request access to your personal data (a “data subject access request”).
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.

For more information on these rights and when they apply is available here:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

  • You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
  • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.