Privacy Policy

January 27, 2024

Policy version: 28 January 2024

https://blockscholes.com (our website), https://app.blockscholes.com/dashboard/options (our platform) and BlockScholesBot, BlockScholesPremiumBot, and blockscholes (our Telegram bot and community page) - (each and collectively referred to as the Channels) - are provided by Block Scholes Ltd (we, our or us). We are the controller of personal data obtained via our Channels, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our Channels. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).

Given the nature of our Channels, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website or via our Channels, please let us know so that we can delete that data.

WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of our Channels.

In the course of your use of our Channels we may link to websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on the particular activities carried out through our website and our platform. We will collect and use the following personal data about you:

your name, address and contact information, including email address and telephone number and company details where relevant
information to check and verify your identity, e.g. date of birth

location data, if you choose to give this to us
your billing information, transaction and payment card or other payment method information
bank account and payment details
details of any information, feedback or other matters you give to us by phone, email, post or via social media
your account details, such as username and login details
your Telegram user IDs when you interact with our Telegram bot or community
your activities on, and use of, our Channels
your personal or, where relevant, your professional interests
information about the services we provide to you
your contact history, purchase history and saved items
information about how you use our Channels
your responses to surveys, competitions and promotions
your usage history of our Channels, including history of the analysis performed on our Channels.

You must provide this personal data to use our Channels and the services on them unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case, we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our Channels or any services on them.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

HOW YOUR PERSONAL DATA IS COLLECTED

We collect personal data from you:

directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase services via our Channels, post material to our website or our platform and complete customer surveys or participate in competitions via our website or our platform, and
indirectly, such as your browsing activity while on our website or your activity when using our Channels including your activity while using our Telegram bot or community groups that our Telegram bot is part of; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.

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HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, for example:

where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

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The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price. To perform our contract with you or to take steps at your request before entering into a contract.
Providing services to you	To perform our contract with you or to take steps at your request before entering into a contract.
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us.	To comply with our legal and regulatory obligations. For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us.
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: - To comply with our legal and regulatory obligations; - In other cases, for our legitimate interests, i.e. to protect our business, interests, and rights.
Customise our Channels and our content to your particular preferences	Depending on the circumstances: - Your consent as gathered when you register with us. - Where we are not required to obtain your consent, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
Collect and process Telegram user IDs	To fulfil our contractual obligations to provide premium services you have requested. For our legitimate interests, i.e., ensuring the smooth operation and delivery of all Telegram services to our users.
Retaining and evaluating information on website usage	Depending on the circumstances: - Your consent as gathered when you register with us. - Where consent is not required, for our legitimate interests, i.e. to improve our website and services.
Communications with you not related to marketing	Depending on the circumstances: - To comply with our legal and regulatory obligations. - For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
Protecting the security of systems and data	To comply with our legal and regulatory obligations. Additionally, for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us.
Statistical analysis to understand our customer base	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
Updating and enhancing customer records	Depending on the circumstances: To perform our contract with you or take steps at your request. To comply with our legal and regulatory obligations. For our legitimate interests, e.g., ensuring effective communication with customers.
Disclosures and other activities necessary to comply with legal and regulatory obligations	To comply with our legal and regulatory obligations.
Marketing our services to existing and former customers	For our legitimate interests, i.e. to promote our business to existing and former customers. See ‘Marketing’ below for further information.
Sharing personal data with third parties in case of business transactions	Depending on the circumstances: - To comply with our legal and regulatory obligations. - In other cases, for our legitimate interests, i.e. to protect, realise, or grow the value in our business and assets.

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HOW AND WHY WE USE YOUR PERSONAL DATA: SHARING

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

MARKETING

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us using the details set out in this Privacy Policy; or
using the ‘unsubscribe’ link in emails or texting ‘STOP’ to the number referenced in the text message.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations outside of our group for marketing purposes without your consent.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with:

third parties we use to help deliver our services to you, e.g. payment service providers, warehouses and delivery companies;
other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers; and
our banks.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency — usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

WHO WE SHARE YOUR PERSONAL DATA WITH: FURTHER INFORMATION

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will not keep your personal data for longer than we need it for the purpose for which it is used including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. If you stop using your account, we will delete or anonymise your account data after seven years. Following the end of the relevant retention period, we will delete or anonymise your personal data.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, Germany.
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers as mentioned above.

COOKIES AND OTHER TRACKING TECHNOLOGIES

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to manage your preferences, to remember your previous actions when navigating our website in the same session, and for maintaining session credentials to enable you to access secure areas of the website).

The table below provides a summary of the cookies we use and why:

Name	Purpose	Is this cookie essential?
Sentry (sentry.io domain)	Record application errors	Yes – we will therefore not request your consent before placing this cookie
AWSALB	Application Routing	Yes – we will therefore not request your consent before placing this cookie
ph_* (Posthog)	To understand usage patterns and analytics of how our platform is being used.	No – we will therefore request your consent before placing this cookie

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

THIRD-PARTY LINKS

Our channels may include links to third-party websites, plug-ins 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 policy of every website you visit.

YOUR RIGHTS

You generally have the following rights, which you can usually exercise free of charge:

The table below provides a summary of the cookies we use and why:

Right	Description
Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in the personal data we hold.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to transfer the personal data you provided to us, in a structured, commonly used and machine-readable format to you or to a third party — in certain situations.
To object to processing	The right to object: at any time to your personal data being used for direct marketing (including profiling) — in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us by email. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

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If you would like to exercise any of those rights, please email, call or write to us — see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself and any additional identity information we may reasonably request from you; and
let us know which right(s) you want to exercise and the information to which your request relates.

KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy from time to time — when we make significant changes we will take steps to inform you, for example via email.

HOW TO CONTACT US

Individuals in the UK

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

27 Old Gloucester Street,

London WC1N 3AX

info@blockscholes.com

07737 652 583

Our Data Protection Manager contact details

Eamonn Gashier

27 Old Gloucester Street, London WC1N 3AX eamonn@blockscholes.io

07737 652 583

HOW TO COMPLAIN

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to make a complaint with:

the Information Commissioner in the UK; or
a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a complaint or by telephone: 0303 123 1113.

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