Privacy Policy

Last updated: January 2024

Introduction

steady-return Advisory Services Ltd ("we", "our", or "us") is committed to protecting the privacy of individuals who engage with our services. This Privacy Policy explains how we collect, use, store, and safeguard your personal data when you use our website or services.

We are registered in England and Wales (Company Number 08234567) with our registered office at 47 Clerkenwell Road, London EC1M 5RS. For data protection purposes, we are the data controller.

Information We Collect

We collect information in several ways depending on how you interact with us:

Information You Provide Directly

When you contact us or use our services, you may provide:

• Name and contact details (email address, postal address)
• Professional background and employment information
• Educational history and learning objectives
• Payment information for service transactions
• Correspondence and consultation notes

Information Collected Automatically

When you visit our website, we may automatically collect:

• IP address and approximate geographic location
• Browser type and operating system
• Pages visited and time spent on our site
• Referring website address
• Device identifiers

How We Use Your Information

We process your personal data for the following purposes:

Service Delivery

To provide educational platform advisory services, including conducting consultations, preparing recommendations, and delivering reports. This processing is necessary to fulfil our contractual obligations to you.

Communication

To respond to your enquiries, send service-related information, and provide follow-up support. We may also send occasional updates about our services if you have consented to receive them.

Service Improvement

To analyse how clients engage with our services and website, helping us improve our offerings and user experience. This is based on our legitimate interest in developing our business.

Legal Compliance

To meet our legal obligations, including maintaining financial records for tax purposes and responding to lawful requests from authorities.

Legal Basis for Processing

Under UK data protection law, we rely on the following legal bases:

• Contract: Processing necessary to provide services you have requested
• Legitimate interests: Processing that supports our business operations where your rights do not override these interests
• Legal obligation: Processing required to comply with applicable laws
• Consent: Where you have given explicit permission for specific processing activities

Data Sharing

We do not sell your personal information. We may share data with:

• Service providers: Companies that support our operations (payment processors, hosting providers, communication tools). These parties are bound by data protection agreements.
• Professional advisers: Accountants, lawyers, or auditors when necessary for business purposes.
• Legal authorities: When required by law or to protect our legal rights.

Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Client records: Seven years from the end of our business relationship (for legal and accounting purposes)
• Marketing preferences: Until you withdraw consent
• Website analytics data: 26 months
• Enquiries that do not lead to engagement: 12 months

Your Rights

Under UK data protection law, you have the following rights:

• Access: Request a copy of the personal data we hold about you
• Rectification: Ask us to correct inaccurate or incomplete data
• Erasure: Request deletion of your data in certain circumstances
• Restriction: Ask us to limit how we use your data
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Where processing relies on consent, you may withdraw it at any time

To exercise any of these rights, contact us at [email protected]. We will respond within one month.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encryption, access controls, and regular security assessments.

While we take reasonable steps to protect your information, no method of transmission over the internet is completely secure. We cannot guarantee absolute security.

International Transfers

Your data is primarily stored and processed within the United Kingdom. If we transfer data outside the UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the UK Information Commissioner.

Cookies

Our website uses cookies and similar technologies. For detailed information about which cookies we use and how to manage your preferences, please see our Cookies Policy.

Changes to This Policy

We may update this Privacy Policy periodically. Significant changes will be communicated via our website or direct notification where appropriate. The "Last updated" date indicates when the policy was most recently revised.

Contact Us

For questions about this Privacy Policy or our data practices, contact:

steady-return Advisory Services Ltd
47 Clerkenwell Road
London EC1M 5RS
Email: [email protected]

Complaints

If you believe we have not handled your data appropriately, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection. You can contact the ICO at ico.org.uk or by telephone on 0303 123 1113.