This Privacy Policy describes what happens to the personal information which you supply to ClickTrain AI Ltd (“we”, “us”, “our”) when you use our website www.clicktrain.com (the “Website”) and/or ClickTrain | PPC Management Platform (the “Platform”), whether as a visitor or a registered user. It also describes how we use cookies and IP addresses. We reserve the right to change this Policy from time to time and revised terms will be posted on our website.

  1. ABOUT US

We are registered in England and Wales under Company Number 13450941 and our registered office is at 265-269 Wimbledon Park Road, London, SW19 6ND. Our VAT Number is 387 9647 19.

  1. WHAT INFORMATION DO WE HOLD ABOUT YOU AND HOW DO WE COLLECT IT?

If you supply us with your contact details through our Website and/or Platform or make an inquiry through one of our web forms then we will store and collect this personal information.

  1. WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?

We will use your personal information, and may share your personal information with other third parties acting on our behalf, for one or more of the following purposes:

      • to create and maintain your ClickTrain account if you become a registered user of our Platform; 
      • to provide our services to you;
      • to obtain payment from you, if applicable;
      • to provide you with information about our products and services;
      • to enable our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions, as may be required, in order to fulfil our contract with you;
      • to send you personalised marketing communications where you have agreed that we may do so in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you; 
      • to respond to any enquiry or complaint you may make to us;
      • [to serve personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our websites, and other data obtained through the use of “cookies” placed on your devices. Please see our Cookie Statement;]
      • to ensure the security of your ClickTrain account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;
      • for market research purposes, where we may contact you to ask for your feedback, and for developing and improving our products and services, for example, by reviewing visits to our Website and Platform and their various subpages, demand for specific goods and services and user comments;
      • to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law; and
      • for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase or investment in the business.

If at any time after you have consented to us using your personal information for marketing purposes and you wish us to stop using your information for these purposes, please email us at dpo@clicktrain.com.

  1. GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION

To process your personal information lawfully we need to rely on one or more valid legal grounds. For example, we may rely on legal grounds, such as:

      • your request for content or services necessitating steps including processing of your Personal Information to be taken prior to entering into a contract with you and any processing that is necessary for the performance of such contract;
      • your consent to us using your personal information for marketing purposes;  
      • our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your personal information to prevent or detect fraud or abuses of our website; or 
      • our compliance with a legal obligation to which we are subject.
  1. DISCLOSURE OF YOUR PERSONAL INFORMATION

There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third parties. This will only take place in accordance with the law and for the following purposes:

      • to our subsidiaries, branches or associated offices;
      • to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our users, for example, the disclosure to our data centre provider for the safe keeping of your personal information, web hosting provider through which your personal information may be collected, identity verification partners in order to verify your identity against public databases;
      • to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;
      • subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by clicking here;
      • to third-party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
      • to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal information will be permanently transferred to a successor company; 
      • to public authorities where we are required by law to do so; and
      • to any other third-party where you have provided your consent.
  1. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

We may transfer your personal information to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 2 above. In particular, your personal information may be transferred throughout our group and to our outsourced service providers located abroad. In these circumstances, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.  Please contact us at dpo@clicktrain.com for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

  1. RETENTION OF PERSONAL INFORMATION

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

  1. YOUR LEGAL RIGHTS UNDER DATA PROTECTION LAW

Data protection law provides individuals with certain rights, including the right to access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information.  Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

      • Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you. If you would like to obtain a copy of this information, please email us at dpo@clicktrain.com. You may be required to submit proof of your identity and an admin fee may be charged. 
      • Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information.
      • Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
      • Right to object to processing. You may, as permitted by law, request that we stop processing your personal information.
      • Right to erasure. You may request that we erase your personal information and we will comply unless there is a lawful reason for not doing so.
      • Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
  1. LINKED WEBSITES

Please note that any websites that may be linked to our Website and/or Platform are subject to their own privacy policy.

  1. CONTACT US

To contact us please email us at support@clicktrain.com.