We are Verwick Online Education Limited, also known as Lex van Dam Trading Academy (LVDTA) or Lex van Dam Financial Education (LVDFE). This privacy notice is to let you know how we promise to look after your personal data. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
Lex van Dam Trading Academy and Lex van Dam Financial Education are the trading names for Verwick Online Education Limited registered in Gibraltar. Company Registration Number: 103734 Companies House, Gibraltar.
Address: Verwick Online Education Limited, 57/63 Line Wall Road, PO Box 199.
This Policy applies as between you, the User of this Web Site and Verwick Online Education Limited, the owner and provider of this Web Site and its connected persons and companies. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Web Site. If you do not agree to be bound by these terms and conditions, you should stop using the Web Site immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” Means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Web Site;
“Content” Means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
“Cookie” Means, a small text file placed on your computer by Verwick Online Education Limited when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site. Where e-commerce facilities are provided, Cookies may be used to store your Orders’, Shopping Basket etc, with Verwick Online Education Limited. Further details are contained in Clause 10 and Schedule 1 of this Policy;
“Data” Means, collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
“Verwick” means Verwick Online Education Limited., 57/63 Line Wall Road, Gibraltar
“Service” Means collectively any online facilities, tools, services or information that Verwick Online Education Limited makes available through the Web Site either now or in the future;
“System” Means, any online communications infrastructure that Verwick Online Education Limited makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
“User” / “Users” Means, any third party that accesses the Web Site and is not employed by Verwick Online Education Limited and acting in the course of their employment; and
“Web Site” Means, the website that you are currently using www.lexvandam.com and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2. Data Collected
Without limitation, any of the following Data may be collected:
2 Date of birth;
4 Job title;
6 Contact information such as email addresses and telephone numbers;
7 Demographic information such as postal and billing address, post code, preferences and interests;
8 Financial information such as credit / debit card numbers;
9 IP address (automatically collected);
10 Web browser type and version (automatically collected);
11 Operating system (automatically collected);
12 A list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
13 Cookie information (see clause 11 below).
14 Education, CV, Employment Status, Work Preferences, Employment Details.
3. Our Use of Data
3.1 Data that you may submit through any communications System that we may provide may be retained for a longer period of up to 24 Months. Please note: Financial information such as credit/debit card numbers are not held or stored by us; your payments are processed on a secure payment gateway such as WorldPay.
3.2 Unless we are obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
3.3 All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998 and The General Data Protection Regulation (GDPR).
For more details on security, see clause 10 below.
3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:
3.5 Internal record keeping;
3.6 Improvement of our products / services;
3.7 Transmission by email of promotional materials that may be of interest to you;
3.8 Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.
4. Third Party Web Sites and Services
Verwick Online Education Ltd may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services DO NOT have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that Verwick Online Education Limited requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998 and The General Data Protection Regulation (GDPR).
5.1 We will use Your Data to keep you informed of our products and services by letter, telephone (including text messages), electronically (including e-mail) or otherwise only if we have your consent to receive marketing related information from us as from May 25, 2018 when GDPR comes into effect. Our Associated Companies will also be able to contact you in these ways about their products and services. We work adhering to the highest professional and ethical standards, and we respect your privacy, therefore, we can assure you we will not distribute marketing offers frequently. We would contact you only on the occasions when we have your consent and when we think this could really benefit you in relation to your educational goals or when we have a legitimate interest. When we have a legitimate business or commercial reason to use your information we would still only do it in a way that does not unfairly go against what is right and best for you and complying with regulations that apply to us.
You consent to the use of Your Data in this way, but if you do not wish to give us your consent please refer to 5.2.
5.2. You can tell us any time that you do not wish us or our Associated Companies to use Your Data for some or any type of profiling and marketing reasons. In order for you to be able to do so, we have several options for you:
- you can use unsubscribe links which are available in all our email communication
- we have simplified navigation on our website for you to locate this information, therefore, you can find “Consent” in the footer of our website at all times which also includes guidance how to withdraw your consent any time even after you have given it to us. You can change your preferences any time
- if you are our customer already you can adjust your consent settings as soon as you log in and access “Manage Membership” section
- you can also write to us at: Verwick Online Education Limited, 57/63 Line Wall Road, Gibraltar, or e-mail our Customer Services Team on [email protected] and we will assist you normally within 24-72 hours.
Please kindly note that if you withdraw your consent, we may not be able to provide certain products or services to you. However, if you are our existing customer and have purchased a product and service you will receive all necessary information about that product or service, there is nothing to worry about! For more please also refer to our Terms & Conditions.
5.3 www.lexvandam.com, may from time to time contain links to and from the websites of our partner networks, advertisers and Associated Companies. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit Your Data to these websites.
6. Changes of Business Ownership and Control
6.1 Verwick Online Education Ltd may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
6.2 In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
7. Controlling Access to your Data
7.1 Wherever you are required to submit Data, you will be given options to review our privacy policies and should you not want to proceed you should immediately stop filling your details. This may include the following:
7.2 In relation to us using your Data for marketing purposes, refer to Section 5 (clause 5.1-3) outlined in this document.
7.3 You are entitled to notify us of any inaccuracies in any information we hold in relation to you as well as edit your personal information in your account area, section “Manage Membership’. In addition, you should inform us by email [email protected] if any of your personal details change, so that we can keep our records up to date.
7.4 You also have the right to object to certain ways that we use your personal data, or to ask us to delete, remove, or stop using your personal data if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’. Please refer to section 8 and 9.
7.5 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
8. Your Right to Withhold Information
8.1 You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data.
9. Accessing your own Data
9.1 You may access your Account at any time to view or amend the Data in the section “Manage Membership”. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change your consent at any time. For more information how to do it, please refer to the Section 5 (clause 5.2).
9.2 You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact Us for more details at [email protected]. Any access request may be subject to a fee permitted by the Act.
10.1 Data security is of great importance to Verwick Online Education Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.
10.2 Specifically we utilise the following systems: Personal Data Enrolment Forms, Payment Receipts (PDQ Payment Machine,) Card Detail Payment/Submission Forms, Bank Details for Direct Debit or Standing Order Service.
10.3 What happens if we send your data outside of the EEA?
We will only send your data outside of the European Economic Area (‘EEA’) to:
- Comply with a legal duty
- Provide our products and services
If we do transfer information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. To do this, we will use one or more of these safeguards:
- Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA, as deemed by the European Commission
- Ensure that a contract with the recipient is in place that means they must protect it to the same standards as the EEA
You can find out more about these safeguards on the European Commission Justice and Information Commissioner’s Office (ICO) websites.
11.1 Verwick Online Education Ltd, may set and access Cookies on your computer. Cookies that may be placed on your computer are detailed in Schedule 1 to this Policy.
11.2 A Cookie is a small file that resides on your computer’s hard drive and often contains an anonymous unique identifier and is accessible only by the web site that placed it there, not any other sites.
11.3 You may delete Cookies; however, you may lose any information that enables you to access the Web Site more quickly.
11.4 You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Web Site.
12. Summary of Your Rights under GDPR
Under the GDPR, you have:
12.1 the right to request access to, deletion of or correction of, your personal data held by Us;
12.2 the right to complain to a supervisory authority;
12.3 be informed of what data processing is taking place;
12.4 the right to restrict processing;
12.5 the right to data portability;
12.6 object to processing of your personal data;
12.7 rights with respect to automated decision-making and profiling (see section 14 below).
13. Changes to this Policy
If you have any questions, or wish to make a complaint, please contact us at Verwick Online Education Limited, 57/63 Line Wall Road, Gibraltar, or e-mail our Customer Services Team on [email protected] and we will do our best to answer your questions or otherwise resolve the matter to your convenience.