Arise Academy Ltd respects your privacy and is committed to protecting your personal data. This privacy
policy will inform you as to how we look after your personal data when you visit our website (regardless of
where you visit it from) and tell you about your privacy rights and how the law protects you.
Please read the following carefully to understand our views and practices regarding your personal data and how
we will treat it. Please also use the Glossary to understand the meaning of some of the terms used in this privacy
We may change this policy from time to time by updating this page. You should check this page from time to
time to ensure that you are happy with any changes.
personal data through your use of this website, including any data you may provide through this website when
you sign up to our newsletter OR purchase a product or service OR take part in a competition OR over the
This website is not intended for children and we do not knowingly collect data relating to children.
we may provide on specific occasions when we are collecting or processing personal data about you so that you
privacy policies and is not intended to override them.
Arise Academy Ltd is a subsidiary company of Nexarise Ltd. Details of different legal entities forming part of
company in the Nexarise Corporation responsible for processing your data.
Arise Academy Ltd is the controller and responsible for this website. Arise Academy Ltd may share your data
with other companies in the Nexarise Corporation and suppliers of services which you may request through this
website or by telephone and those entities may share data about services you receive with Arise Academy Ltd
or each other.
Full name of legal entity: Arise Academy Ltd Email address: email@example.com
Postal address: 7 Navigation Business Village, Navigation Way, Ashton-On-Ribble, Preston, England, PR2
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance
versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
This website 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
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can
be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title,
date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services
you have purchased from us.
• Technical Data includes 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.
• Profile Data includes your username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third
parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this
data will 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
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). Nor do we collect any information
about criminal convictions and offences, although other members of the Nexarise Corporation may do so under
their separate Privacy Policies.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail
to provide that data when requested, we may not be able to perform the contract we have or are trying to enter
into with you (for example, to provide you with goods or services). 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.
3. How is your personal data collected
We capture, process and retain personal data from you and the devices you use when you navigate through our
website by registering an account, entering into a transaction or otherwise interacting with us.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using
experience while visiting the website. Cookies are small files saved to the user's computer's hard drive that
track, save and store information about the user's interactions and usage of the website. This allows the website,
through its server, to provide the users with a tailored experience within this website. We may also receive
Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We will receive personal data about you from various third parties
and public sources as set out below:
• Technical Data from the following parties:
(a) analytics providers such as Google based outside the EEA;
(b) advertising networks based inside OR outside the EEA;
(c) search information providers based inside OR outside the EEA;
(d) financial services and logistics providers;
(e) credit reference agencies, fraud prevention agencies, business directories and other commercially and
publicly available sources.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based
inside OR outside the EEA.
• Identity and Contact Data from data brokers or aggregators based inside OR outside the EEA.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral
Register based inside the EEA.
4. 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 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.
• Where we need to comply with a legal obligation.
Please read the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
We may contact you by e-mail, phone call or SMS in relation to managing your account or the performance of
contract with you including but not limited to:
• Setting up and providing access to your trading account;
• Delivering our products and services;
• Facilitating your withdrawals, deposits and funds transfer;
• Responding to your queries; or
• Giving you updates in relation to your account or order.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get
your consent before sending third party direct marketing communications to you via email or text message. You
have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where
Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal ground
we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(c) National Identifier
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(g) Usage Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our
products/services)To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them
(e) Marketing and Communications grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of 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 reorganisation or restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of
the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to
grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our
website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which products, services and offers
may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased
goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website
and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out
links on any marketing message sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as
a result of a product/service purchase, warranty registration, product/service experience or other transactions.
The right to object to profiling
You have the right to object to how your personal data is processed including your right to object to profiling as
quicker access to products, services and offers tailored specifically to your interests, we respect that you may
not feel the same way and understand if you decided to opt out.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
not function properly.
Change of purpose
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
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 process your personal data without your knowledge or consent, in compliance with the
above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our
law. We do not allow our third-party service providers to use your personal data for their own purposes and
only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within the Corporation and with suppliers providing goods or services requested by
you. This may involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our corporation companies to follow the same rules
when processing your personal data. These rules are called “binding corporate rules”.
Many of our suppliers are based outside the EEA so their processing of your personal data will involve a
transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to
it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of
protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission
which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your
personal data out of the EEA.
7. Data security
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 have a business need to know. They will
only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
We use encrypted transmission links whenever we can.
We use safeguards such as firewalls, authentication systems, and access control mechanisms to control
unauthorised access to systems and data.
We regularly review our information collection, storage and processing practices, including physical security
measures, to guard against unauthorised access to systems.
We restrict access to personal information to our employees, contractors and agents who need to know that
information in order to process it for us and who are subject to strict contractual confidentiality obligations.
If you are aged 13 or under you are not allowed to provide us with your personal data and should not use our
website and services.
8. Data retention
How long will you use my personal data for?
We 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, thepurposes 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.
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.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you)
for research or statistical purposes, in which case we may use this information indefinitely without further
notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 clearly unfounded, repetitive or excessive. Alternatively, we
could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.
Time limit to respond
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.
10. Glossary LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable
us to give you the best service/product and the best and most secure experience. We make sure we consider and
balance any potential impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for activities where our interests are
overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a
legal obligation that we are subject to.
Internal Third Parties
Tech by NeXarise Ltd. in the NeXarise Corporation acting as a processor and who are based in the UK and
provide web development and SEO services for businesses.
Nex Mobile Ltd. in the NeXarise Corporation acting as a processor and who are based in the UK and provide
mobile sim card services for consumers.
Nexarise European Services Ltd. in the NeXarise Corporation acting as a processor and who are based in all the
countries where we operate and provide direct selling opportunities for independent contractors.
Lifestyle by NeXarise Ltd. in the NeXarise Corporation acting as a processor and who are based in all the
countries where we operate and provide travel subscription services for consumers.
Wellness by NeXarise Ltd. in the NeXarise Corporation acting as a processor and who are based in all the
countries where we operate and provide wellness products for consumers.
Nex Protect Ltd. in the NeXarise Corporation acting as a processor and who are based in the UK and provide
introductions to insurance products for consumers.
External Third Parties
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers
based in who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, Financial Conduct Authority, Prudential Regulation Authority, Information
Commissioner's Office, other regulators and other authorities acting as processors or joint controllers based in
the United Kingdom who require reporting of processing activities in certain circumstances.
• Fraud prevention agencies that provide databases and services, such as CIFAS, National Hunter, SIRA and
ENI, to detect or prevent fraud.
• Law enforcement or government agencies.
• Credit reference agencies.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). 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 or
inaccurate 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
Request restriction of processing 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.