1. Introduction and Data Controller Status
Welcome to UCES LTD ("we", "our", or "us"). We respect your privacy and are committed to protecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
UCES LTD acts as the Data Controller for the personal data collected through our website, platform, and services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with the Universal Credit Ecosystem.
2. Information We Collect
We collect and process data that is necessary for the purposes described in this policy.
2.1 Information You Provide to Us
- Identity Data: Full name, username, title, and date of birth.
- Contact Data: Email address, telephone numbers, and billing address.
- Financial Data: Payment details (processed securely via our payment providers; we do not store full credit card numbers on our servers).
- Profile Data: Your username, password, purchases, course progress, feedback, and preferences.
2.2 Information We Collect Automatically
- Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and platform.
- Usage Data: Information about how you use our website, products, and services, including pages visited and time spent on the platform.
2.3 Special Category Data
We do not actively seek to collect special category data (such as health data, racial or ethnic origin) unless it is strictly necessary and you provide explicit consent.
2.4 Children's Privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take immediate steps to delete it.
3. How We Use Your Information & Lawful Basis
We use your personal data for specific purposes and rely on the following lawful bases under Article 6 of the UK GDPR:
- Service Delivery (Lawful Basis: Contract): To register you as a new member, process your orders, and provide access to the UCES platform and educational content.
- Financial Processing (Lawful Basis: Contract / Legitimate Interests): To process payments, manage billing, and collect money owed to us.
- Platform Management (Lawful Basis: Legitimate Interests): To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
- Communication (Lawful Basis: Legitimate Interests / Consent): To manage our relationship with you, including notifying you about changes to our terms or privacy policy, and sending relevant marketing communications (where you have opted in).
- Legal Compliance (Lawful Basis: Legal Obligation): To comply with legal, regulatory, and statutory obligations.
We do not carry out automated decision-making or profiling that produces legal or similarly significant effects.
4. How We Share Your Information
We do not sell your personal data. We may share your data with trusted third-party service providers who act as Data Processors under strict contractual agreements:
- Service Providers: Such as GoHighLevel (our CRM and platform host) and Stripe (our payment processor).
- Cloud Hosting: Amazon Web Services (AWS) or similar providers for secure cloud infrastructure.
- Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Regulators and Authorities: Such as HM Revenue & Customs or the Information Commissioner's Office (ICO), where required by law.
5. International Data Transfers
Some of our third-party service providers (such as GoHighLevel and Stripe) may process your data outside the United Kingdom, particularly in the United States.
Where this occurs, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the ICO, or that the receiving country has been deemed to provide an adequate level of data protection by the UK government.
6. Data Security
We have implemented robust technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:
- Encryption of data in transit using TLS.
- Secure payment processing via PCI-DSS compliant providers (Stripe).
- Access controls restricting data access to authorised personnel on a need-to-know basis.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours where required by law, and we will communicate the breach to affected individuals without undue delay.
7. Data Retention
We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.
8. Your Data Protection Rights
Under the UK GDPR, you possess several rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request the deletion of your data where there is no compelling reason for its continued processing.
- Right to Restrict Processing: Object to or request the restriction of processing your data.
- Right to Data Portability: Request the transfer of your data to another party.
- Right to Object: Object to processing based on legitimate interests or direct marketing.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.
To exercise any of these rights, please contact us at info@uces.uk. We will respond to your request within one month of receipt.
9. Cookies and Tracking Technologies
Our website and platform use cookies and similar tracking technologies to distinguish you from other users, provide a better experience, and improve our site. For detailed information on the cookies we use and how to manage your preferences, please see our separate Cookie Policy.
10. Complaints
If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues:
Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Website: https://ico.org.uk Telephone: 0303 123 1113
We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
11. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the new policy on our website.
12. Contact Us
If you have any questions regarding this Privacy Policy or our data handling practices, please contact us at: Email: info@uces.uk Post: 11 Old Bond Street, Mayfair, London W1S 4PN