THINK
Privacy Policy

Last updated on: [01/05/2021]

  1. Introduction and Scope

At CFTE (as defined below), we take Data Privacy very seriously and are committed to protecting and respecting your data.

When you use the website ([THINK website]), including any subdomains thereof (the “Website”), sign-up for any of the subscription plans, courses or events available through the Website, enter into any transaction or contact us through the Website, live chat, email, at in-person events or other communication channel, we may obtain personal data about you. We will process such personal data in accordance with the applicable laws and regulations and with this Privacy Policy, as amended from time to time, and any applicable provision as may be individually agreed.

This Policy explains when and why we collect personal information about people who visit our Website, subscribe to our communications or subscribe to our plans. It also explains how we use it, the conditions under which we may disclose it to others and how we keep it secure.

It is important that you read this Privacy Policy together with the Cookie Policy, as well as any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

In this policy you can find more about:

(A) Who we are;

(B) How we collect your personal data;

(C) What personal data we collect;

(D) Why we need your personal data;

(E) When and with whom we share your personal data;

(F) How we protect your personal data; and

(G) How you exercise your data subjects rights.

  1. Who are we?

Centre for Finance, Technology and Entrepreneurship Ltd is a company incorporated under the laws of England and Wales, with registered office at 11 Blackheath Village, London SE3 9LA, the United Kingdom, registered with the United Kingdom Companies House under the number 10695038, with the VAT number 276 8566 45 (together with its affiliates, hereinafter referred to as “CFTE”).

We are an education platform and an exclusive professional network at the intersection of finance and technology whose mission is helping individuals and corporates create the digital world of financial services.

We are registered with the UK data protection authority (the Information Commissioner’s Office or ICO) under number [TBC].

  1. How do we collect your personal data?

We use different methods to collect data from and about you including through:

Direct interactions: You may provide us your data by filling in forms in our Website or by corresponding with us by email, phone, post, live chat or otherwise. This includes personal data you provide when you:

  • Create an account on our Website;
  • Request marketing to be sent to you;
  • Subscribe to our product/services through our Website;
  • Subscribe to our newsletters, events or publications;
  • Engage with our team through live chat, email, posts or otherwise;
  • Enter a promotion or survey; and/or
  • Give us some feedback or contact us.

Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties: (i) analytics providers; (ii) advertising networks; (iii) search information providers based inside or outside the EEA (as defined below);
  • Identity and Contact Data from data brokers or aggregators;
  • Identity and Contact Data from publicly availably sources (such as Companies House and the Electoral Register based inside the EEA (as defined below)).

Indirectly. We may have access to your personal data because someone who has it engaged us to provide a service that requires us to access and use that data. This is the case when you engage with the Website because your employer has signed up to a busines plan or entered into a collaboration agreement with us. In this case, we will be processing your personal data as data processors, on behalf of the data controller, who determines in exclusivity the types and purposes for which we will process the data about you that it has provided us and is solely liable to you for any data breaches not caused exclusively by us. If you contact us in relation to personal data that we process as data processors on behalf of a data controller, we will direct you to the contact person of the data controller.

However, we are data controllers for information provided directly by you or as a result of interacting with our Website and platform (and which is not the data about you that has been provided by the third party/your employer), including assessment data, a secondary email address, additional profile details such as job title, personal website URL, a short bio, social platform handles, and demographic information such as your gender, year of birth, and your work industry. For the avoidance of doubt, none of these additional profile details are required to use the Website or the platform, but we can offer you an enhanced experience if you provide them.

When you sign up as a user via any of our individual plans, we are the data controllers for all personal information provided by you.

  1. What personal data do we collect about you?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

  • Identity Data, which may include first name, last name, username or similar identifier, date of birth, address and country of residence, and any other identity data required by applicable laws and regulations;
  • Contact Data, which may include email address and other contact details provided by you or required by applicable laws and regulations;
  • Professional Data, which may include your role in a company and if you are representing a legal person;
  • Profile Data, which may include your username and password, feedback and survey responses, and other details provided by you or required by applicable laws and regulations;
  • Technical Data, which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website;
  • Usage Data, which may include information about how you use our Website, products and services, including, but not limited to, your progress and performance in the courses available in our Website;
  • Marketing and Communications Data, which may include your preferences in receiving promotion and marketing materials from us and our third parties and your communication and cookies preferences;
  • Third Party Data, which may include information from third parties or publicly available sources;
  • Any other personal data provided by you during your engagement with CFTE, including data for billing and payment processing.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this 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). We also do not willingly collect any information about criminal convictions and offences, except data collected on commercial databases and media searches for Anti-Money Laundering and Counter-Terrorist Financing due diligence purposes, if and as legally required. If we happen to unwillingly receive data of such kind, we will immediately delete it.

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

It is important that the personal data we hold about you is accurate, complete and up to date. Please keep us informed if your personal data changes during your relationship with us.

If you purchase a product/service from us, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions. The data which you supply to the payment processor is not within our control and is subject to the payment processor’s own privacy policy and terms and conditions.

  1. Why do we need your personal data?

CFTE 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 we have your consent;
  • Where we need to perform the agreement we are about to enter into or have entered into with you or with a data controller that has your personal data;
  • In order to comply with a legal or regulatory obligation, including to verify your identity in order to create your account and ensure that you are eligible to use the products/services provided by CFTE;
  • Where we have a legitimate interest and your interests and fundamental rights do not override those interests.

Specifically, in the instances where you gave us access to identifiable data, we may use it for the following purposes:

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To provide our products/ services, verifying your identity, manage client and alumni relationship and engagement (including, but not limited, to assistance and support to users and celebration of top achievers).

(a) Identity Data

(b) Contact Data

(c) Professional Data

(d) Profile Data

(e) Marketing and Communications Data

(f) Third-Party Data

(a) Performance of a contract with you;

(b) Necessary to comply with legal obligations;

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients and alumni use our products/services).

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Technical Data

(e) Usage Data

(f) Third-Party Data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise);

(b) Necessary to comply with legal obligations.

For advertisement and marketing, data analytics (including, but not limited to, learning analytics), providing recommendations about or associated with our products/ services, and to improve our Website, products/services and client and alumni relationship and experience.

(a) Identity Data

(b) Contact Data

(c) Professional Data

(c) Profile Data

(d) Technical Data

(e) Usage Data

(f) Marketing and Communications Data

(g) Third-Party Data

Necessary for our legitimate interests (to study how users use our services and Website, to define types of customers for our products and services, to keep our Website and social media updated and relevant, to engage our community, to grow our business and to inform our marketing strategy)

Website recording: Our web site may also use any website recording service. Site recording services may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal data. Data collected by website recording services is for CFTE’s internal use only. The information collected is used to improve our Website usability and is stored and used for aggregated and statistical reporting.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may have to process your personal data without your knowledge or consent, in compliance with the above rules, where this is required by law.

If you are in any doubt, please contact us about the specific legal ground we are relying on to process your personal data.

As you have to give an opt-in consent for marketing purposes, you can also ask us or third parties to stop sending you marketing messages at any time either through our Website (including your personal dashboard or reserved area) or contact details or by another means.

  1. When and with whom do we share your personal data?

CFTE does not disclose your personal data to third parties, except as described in this Privacy Policy or pursuant to your consent. In those circumstances where we have to share your personal data, we will take reasonable precautions to ensure that the third parties keep your personal data secure and confidential, in compliance with relevant legal requirements, and we will only disclose the personal data that is strictly necessary. By providing your personal data and expressly accepting the terms of this Privacy Policy you consent that CFTE may share your personal data with:

CFTE’s employees, agents and contractors: In order to provide a reliable and consistent service, your personal data may need to be accessed by more than one of CFTE’s employees, agents or contractors. When sharing your personal data, we adhere to applicable legal obligations and industry standards regarding the protection of personal data.

CFTE’s subsidiaries and affiliates: In the context of a business reorganisation or group restructuring exercise, for assistance in relation to content creation, development of courses, marketing, business development and performance reporting, we may need to disclose your personal data to other entities within our group. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data, even if they are located outside the EEA.

Business Plans and Company Partnership Subscriptions: We partner with certain third parties to provide our services to their employees or their community members. As part of such partnerships, a third party may pay for the subscription for its employees or community members or otherwise contract with CFTE to make your subscription available to you, and CFTE may share information about your use of our services with the third party. If your subscription was provided by your employer or community sponsor, we may share information you provide, or information we may otherwise collect through your registration and use of our services, with such third party. This information may include course viewing history, course viewing time, course or assessment completion, course quality ratings and feedback, certifications, performance-related metrics, and other personal information.

Third Party Service Providers working on our behalf: In order to provide a reliable and consistent service, your personal data may need to be accessed by our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to host the courses, to process payments and to send you emails) and/or of performing support services or somehow facilitate the provision of CFTE’s services, including those that provide professional, legal or accounting advice to CFTE. However, when we disclose your personal data to these third party service providers, we only disclose the personal data that is necessary to deliver the service and subject to a contract whereby they undertake to keep your information secure and confidential and that set out that they receive and must use your personal data only for the purposes established by CFTE, and not for their own purposes (unless you have consented or requested us to do so, or we are required to do so by law).

Third Party Product Providers we work in association with: We work closely with various third-party product providers to bring you a range of quality and reliable products and services designed to provide you the best learning experience. When you enquire about or purchase one or more of these products or services, the relevant third-party product or service provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. In some cases, they will be acting as a data controller regarding the processing of your personal data and therefore we advise you to read their privacy policy. These third-party product or service providers may share your personal data with us which we will use in accordance with this Privacy Policy.

Payments’ processing: When you are using our secure online payment page, your payment is processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.

Corporate reorganizations and compliance with the law: We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our terms of use, to protect the rights, property or safety of our supporters and customers, or to detect, prevent, or otherwise address fraud, security or technical issues. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Other situations: We may also disclose your personal data under your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent.

  1. Social media

The Website includes certain social media functions for Instagram, Facebook, Twitter and LinkedIn. These features may collect certain information, including your IP address or which page you are visiting and may set a cookie (or other technology) to enable this function to work accordingly. Any such feature will be hosted by a third party or directly on our Website, and any interaction with these will be governed by the privacy policy of the company providing it.

Certain social media services may also allow you to post information about your activities on the Website to your respective social media account/profile. CFTE will never post anything on your behalf to any of your social media accounts/profiles.

  1. How do we protect your personal data?

The security of your personal data is highly important to us. All information and personal data provided to CFTE is stored securely.

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 may require access to it in order to perform the services requested by you. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

More specifically, we have implemented the following security measures:

  • The use of specialized technology such as host-based security tools, network defence monitors, and intrusion detection systems;
  • Rely only on credible IT providers, with a proven track-record and resources to ensure the protection of any data hosted with them (such as Google);
  • Testing of the security and operability of products and services before they are introduced to the internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
  • Internal and external reviews of our Website and products/services;
  • Periodical monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
  • Implementing controls to identify, authenticate and authorize access to various systems or sites;
  • Protecting information during transmission through various means including, where appropriate, encryption; and
  • Providing CFTE’s personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

It is important to bear in mind that no method of electronic transmission or storage is 100% secure, so CFTE may not guarantee the infallibility of the abovementioned security measures.

Your account information is protected by a personal and non-transferable password, so you should choose it carefully and you shall not disclose it in any way to anyone. CFTE will never ask for your password, should you receive a request to do so, please notify us at or forward such request to privacy@cfte.education.

  1. Transferring your personal data outside of the UK and the European Economic Area

As part of the products/services offered to you through our Website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA or when we share your personal data with our subsidiaries or affiliates outside of the EEA. These countries may not have similar data protection laws to the UK or the European Union. By submitting your personal data, you are agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.

If you use our products/services while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with those services. Please contact us (privacy@cfte.education) if you want further information on the specific mechanisms used by us when transferring your personal data out of the EEA.

  1. How can you exercise your rights?

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete, inaccurate or outdated data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us in writing to privacy@cfte.education. You can also change your privacy preferences and / or unsubscribe to our email communications by a direct link that you can find in every footer of such email communications or through ticking or unticking the relevant boxes available at your personal dashboard or reserved area.

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 unreasonable, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.

  1. Personal data retention

CFTE will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data as indicated above.

CFTE may also collect and retain aggregated, anonymised or pseudonymised information indefinitely, in order to protect the safety and security of our Website, improve our services or comply with any mandatory obligations. Aggregated, anonymised or pseudonymised information will not directly identify you.

  1. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to the law or personal data practices. Our Privacy Policy will always be available via our Website and should we make material changes to this Privacy Policy, we will notify you via email or by means of notice via our Website.

Every time we modify any of the terms of this Privacy Policy, we will post the revised terms on our Website and update the “Last updated on” date at the top of this Privacy Policy.

  1. Miscellaneous

This Privacy Policy provides the general framework for our approach to the processing of personal data. You may, however, in connection with specific products or services offered by CFTE, agree to different privacy provisions that supplement this Privacy Policy.

The Website and services are not intended for children under 16 years of age. No one under age 16 may provide any personal data to or on the Website without parental consent and supervision, unless such user is subject to a law where parental consent is not necessary. We do not knowingly collect personal data from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, do not use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use, without parental consent. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@cfte.education.

Our Website may contain links to other websites run by other organisations. This Privacy Policy applies only to our Website‚ so we encourage you to read the privacy policies on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our Website. In addition, if you linked to our Website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

  1. Our contacts

If you wish to contact us for any matter related with this Privacy Policy or with how we process or protect your personal data, please contact us at privacy@cfte.education.

  1. Applicable Law and Jurisdiction

This Privacy Policy and all non-contractual obligations arising from or connected with them shall be governed by, and shall be construed in accordance with, English law and shall be subject to the jurisdiction of the English Courts.