Privacy Policy

1. Introduction

Crimson Pathways ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website crimson-pathways.com and use our investment education services.

2. Information We Collect

Personal Information

We may collect personal information that you provide directly to us, including:

• Name and contact details (email address, phone number, postal address)
• Educational background and investment experience
• Financial information relevant to your learning objectives
• Communication preferences

Automatically Collected Information

When you visit our website, we automatically collect certain information, including:

• IP address and location data
• Browser type and version
• Pages visited and time spent on our site
• Device information

3. How We Use Your Information

We use the information we collect to:

• Provide and improve our investment education services
• Communicate with you about our programmes and services
• Personalise your learning experience
• Send educational materials and updates
• Comply with legal obligations
• Protect against fraud and unauthorised access

4. Legal Basis for Processing (UK GDPR)

We process your personal data under the following legal bases:

• Consent: For marketing communications and optional services
• Contract: To provide our education services
• Legitimate Interest: To improve our services and prevent fraud
• Legal Obligation: To comply with UK financial regulations

5. Information Sharing

We do not sell, trade, or rent your personal information to third parties. We may share information in the following circumstances:

• With service providers who assist in our operations
• When required by law or legal process
• To protect our rights and prevent fraud
• In connection with a business transfer

6. Data Security

We implement appropriate security measures to protect your personal information, including:

• Encryption of sensitive data
• Regular security assessments
• Access controls and authentication
• Staff training on data protection

7. Your Rights (UK GDPR)

You have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing for legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

8. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Generally, we retain:

• Account information for the duration of your relationship with us
• Communication records for 6 years after last contact
• Financial records as required by UK regulations

9. Cookies and Tracking

We use cookies and similar technologies to enhance your experience. For detailed information about our cookie practices, please see our Cookie Policy.

10. International Transfers

Your personal data is primarily processed within the UK. If we transfer data internationally, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements.

11. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website and updating the "last updated" date.

13. Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

14. Supervisory Authority

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection matters.

ICO Website: https://ico.org.uk