We understand that privacy and the security of your personal information is extremely important. This policy sets out what we do with your information and what we do to keep it secure. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you. This Policy explains how we do this and tells you about your privacy rights and how the law protects you.
This privacy notice applies to this online course platform (the "Services") when interacting with the platform (e.g, when you are a student/lead/subscriber) and other interactions (e.g, when you create an account with the Website, purchase or sign up for our product or service, sign up to our newsletter, signup to updates, open a support ticket, when you contact us by email or phone or contact us via social media ) you may have with us. If you do not agree with the terms, do not access or use the Services or any other aspect of this website.
This platform is hosted by Zenler. When we refer to "Zenler", we mean the Zenler or New Zenler entity that acts as the Controller or the Processor of your personal information, as explained in detail in the "Identifying the Data Controller and Data Processor" section below. Six String Fingerpicking is the "Customer" in the context of the relationship with Zenler.
If you have any questions about privacy practices, please contact the us using the contact us form on the Website or email firstname.lastname@example.org.
Identifying The Data Controller And Data Processor
Data protection law in certain jurisdictions especially in the EU differentiates between the "Data Controller" or "Controller" and "Data processor" or "Processor" of information. In general, Six String Fingerpicking is the controller of Student Data. In general, Zenler is the processor of Student Data related to users/students/leads/visitors who use Zenler Site and the controller of Customer Data and Other Information. Six String Fingerpicking is also a processor of student data.
What Data Do We Collect About you
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may collect and process your personal data in a different ways.
Students, leads or individuals ("Students") granted access to this Zenler Site by a Customer routinely submit Student Data to Zenler when using the Services. Zenler collects, on behalf and upon instructions of Customer, information relating to Student Data and this may include:
Identity Data that includes data relating to subscription/purchases of Zenler Site’s products and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
User Data that includes data about how you use Zenler Site and any online services together with any data that you post for publication on Zenler Site such as username and password, products and courses enrolled, course progress, files uploaded, purchases or orders, your interests, preferences, discussions, quiz, feedback and survey responses.
Technical Data that includes data about your use of Zenler Site such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings, email statistics(opens/clicks/views) and other technology on the devices you use to access Zenler Site. The source of this data is from Zenler Site’s analytics tracking system.
Marketing Data that includes data about your preferences in receiving marketing from Zenler Site and your communication preferences.
Any other personal information the Customer share with Zenler about their students.
Other Information Collected
Zenler may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment such as Stripe and Paypal and delivery services, such as data brokers or aggregators.
Zenler may also receive data from publicly available sources such as European Commision EU VAT database.
Six String Fingerpicking may also receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment such as Stripe and Paypal and delivery services, such as data brokers or aggregators.
Third parties or publicly available sources
Zenler may receive personal data about you from various third parties and public sources as set out below. When a Third Party Service is enabled by the Customer, Zenler are authorized to connect and access Other Information made available to Zenler in accordance with their agreement with the Third Party Provider. Zenler do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. Third party integrations may include
Zenler and Six String Fingerpicking do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Zenler and Six String Fingerpicking do not collect any information about criminal convictions and offences.
Where Zenler or Six String Fingerpicking are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
How we use your Personal Data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where we need to process data in accordance with Customer's instructions.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Student Data will be used by Zenler in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Zenler is a data processor of Student Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Zenler Site, enrol to products and configure settings, access, modify, export, share and remove Student Data and otherwise apply its policies to the Services.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact us form on the Website or using the privacy settings in your profile.
Purpose and Legitimate Basis for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
Communication Data: We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data: We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Technical Data: We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
User Data: We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Marketing Data: We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Zenler Processing of Student Data
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations(PECR), we may send you marketing communications from us if
- you made a purchase or asked for information from us about our goods or services or
- you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us via the contact us form at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc
Disclosures of your Personal Data
Zenler may have to share your personal data with the parties set out below:
- Other companies in the Zenler group who provide IT and system administration services and undertake leadership reporting.
- Service providers who provide cloud infrastructure, video hosting, live video platforms, email provider, IT and system administration services, including:
- - Amazon
- - Sendgrid
- - FileStack
- - Vimeo
- - Zoom
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Government bodies that require Zenler to report processing activities in certain circumstances.
- Third parties to whom Zenler sell, transfer, or merge parts of their business or our assets.
Six String Fingerpicking may have to share your personal data with:
- professional advisors including lawyers, bankers, auditors, bookkeepers/accountants and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Government bodies that require us to report processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Please email email@example.com if you want further information on the specific mechanism used by them when transferring your personal data out of the EEA.
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 such data. 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.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please reach us via the contact us form on the Website or email firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 30 days. Occasionally it may take us longer than 30 days 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.
Third Party Links
We may include links to third-party websites, addons 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.
By providing us with your data, you warrant to us that you are over 13 years of age.
How to contact us
Data Protection Authority
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us by email on email@example.com first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us or via the contact us form OR update your profile in your account.
Six String Fingerpicking's Privacy Notice
To view the Privacy Notice for Six String Fingerpicking Limited please go to www.sixstringfingerpicking.com/privacy