Privacy Policy

Version 7, updated January 2024.

Introduction

  1. We are committed to safeguarding the privacy of our website visitors and service users.

  2. We are the data controller with respect to the personal data of our website visitors and service users; in other words, we determine the purposes and means of the processing of that personal data.

  3. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

  4. In this policy, “we”, “us” and “our” refer to Cartographer Studios Ltd. For more information about us, see Section 14.

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:

  • where you give us your consent;

  • where we need to perform the contract we are about to enter into or have entered into with you;

  • 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; or

  • where we need to comply with a legal or regulatory obligation.

In this section we have set out the general categories of personal data that we may process, the purposes for which we may process personal data, the legal bases of the processing. In the case of personal data that we did not obtain directly from you, we have specified the source and specific categories of that data.

  1. We may process your account data (”account data”). The account data may include your name and email address, your screen name, and details of qualifications held on our platform. The source of the account data is the information stored in your Cartographer user account. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is performance of a contract with you.

  2. We may process data about your use of our website and services (”usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is performance of a contract with you.

  3. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (”notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or legitimate interests.

  4. We may process information contained in or relating to any communication that you send to us (”correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

  5. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others and/or necessary to comply with a legal obligation.

  6. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

  7. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  8. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  9. We may also use your personal data for our further legitimate business interests generally, including: to improve our services; in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; to deal with any customer services you require for audit purposes; and to contact you about changes to this Privacy Policy.

Providing your Personal Data to Others

  1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

  2. We may disclose your personal data to our suppliers or subcontractors, such as trainers, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

  3. We may disclose your personal data to the Operators of your Workspaces (this means the companies and individuals responsible for the management of Workspaces on Cartographer), to help them coordinate their monitoring efforts and keep in contact with you.

  4. Workspace Operators may have their own privacy policies governing their use of your personal data. The name of the relevant Operator is included in the footer of all Workspace web pages on the Cartographer web site, together with a link to their privacy policy. If you do not agree with the way an Operator is processing your Personal Data, please contact our Support team immediately as described in Section 14.

  5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International Transfers of Your Personal Data

  1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom.

  2. The hosting facilities for our website are situated in the United Kingdom, the European Economic Area (EEA), and the United States of America (USA). Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the UK Government.

  3. We make use of subcontractors in the United Kingdom, the European Economic Area (EEA), and the United States of America (USA). Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the UK Government.

  4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and Deleting Personal Data

  1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

  2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

  3. We will retain your personal data as follows:

    1. usage data will be retained for a minimum period of 1 month, and for a maximum period of 10 years following its collection;
    2. account, service, notification, and correspondence data will be retained indefinitely while your account exists and for a maximum period of 1 month following a request to delete your account and your data.

  4. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Security of Personal Data

  1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

  2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

  3. Your password is stored in encrypted form on our servers using industry standard password encryption algorithms. Our staff do not have access to user passwords.

  4. Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

  5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

  6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

Marketing

  1. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

  2. Either way, you can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.

  3. If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. We will still contact you as necessary about your use of our website.

Amendments

  1. We may update this policy from time to time by publishing a new version on our website.

  2. You should check this page occasionally to ensure you are happy with any changes to this policy.

  3. We may notify you of changes to this policy by email or through the sign in process on our website.

Your Rights

  1. You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

    • Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.

    • Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.

    • Right to portability: You can request that we transfer your personal data to another service provider.

    • Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.

    • Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.

    • Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account.

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You can also contact the Information Commissioner, or your local regulatory authority if you are based outside of the United Kingdom.

Third Party Websites

  1. Our website includes hyperlinks to, and details of, third party websites.

  2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Personal Data of Children

  1. Our website and services are targeted at persons over the age of 16.

  2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Updating Information

  1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

About Cookies

  1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

  2. Our use of cookies is documented in our Cookie Policy.

Our Details

  1. This website is owned and operated by Cartographer Studios Ltd.

  2. We are registered in England and Wales under registration number 10790632, and our registered office is at Cartographer Studios, Suite 12, 2nd Floor, Vantage Point, New England Road, Brighton, BN1 4GW.

  3. Our principal place of business is at Cartographer Studios, The Skiff, 30 Cheapside, Brighton, BN1 4GD, United Kingdom.

  4. You can contact us:

    1. by post, to our principal place of business above;
    2. by telephone, on the contact number published on our website from time to time; or
    3. by email, using the email address published on our website from time to time.

Representative within the European Union

  1. Our representative within the European Union with respect to our obligations under data protection law is David Gurnell, whom you can contact using the means provided in Section 14.

Data Protection Officer

  1. Our data protection officer is David Gurnell, whom you can contact using the means provided in Section 14.