The Privacy Policy

Privacy Policy

1. General Provisions

This Privacy Policy (hereinafter referred to as the "Policy") describes how RONIN ACADEMY LTD, a company registered in the United Kingdom (hereinafter referred to as the "Company"), collects, uses, and protects personal data of users (hereinafter referred to as the "User" or "You") when using the services of the investment academy. By using our services, You agree to the terms of this Policy. If You do not agree with these terms, please do not use the Company's services.

2. Personal Data We Collect

The Company may collect the following categories of personal data:

Contact details: name, email address, phone number.
Registration data: information provided when creating an account (login, password), age (to confirm 18+).
Payment data: card details or other payment information (processed through our payment partner, such as Stripe; the Company does not store full card details).
Education data: history of completed courses and lectures, test results, reviews, messages in the closed Telegram channel.
Technical data: information about Your device and software, IP address, geolocation, cookies, and similar technologies (see the "Cookie Policy" section below).

3. Purposes of Processing Personal Data

Collected personal data is used for the following purposes:

Provision of services: for registering You on the platform, organizing personal consultations, client management, and providing access to video courses, lectures, and the closed Telegram channel.
Customer support: for communicating with You, responding to inquiries, and notifying You about new courses, lectures, or changes in services.
Payment processing: for issuing invoices, confirming payments, and processing refunds in accordance with the Refund Policy.
Personalized learning: for recommending courses, tracking Your progress, and tailoring materials to Your needs.
Marketing communications: for sending You news, special offers, and other information about the Academy (with the ability to opt out at any time).
Compliance with the law: to fulfill legal requirements of the UK, EU, USA, CIS countries, or requests from government authorities, as well as to protect the Company's rights and interests in case of disputes.

4. Legal Basis for Processing

The Company processes Your personal data based on the following legal grounds:

Contract performance: processing is necessary to provide You with our services under the service agreement (offer) accepted upon agreeing to the Terms of Use.
Legitimate interests: processing is necessary to improve the quality of our services, develop new features, prevent fraud, and ensure security (while considering the impact on Your privacy and applying safeguards to protect Your rights).
Legal obligations: processing is required to comply with legal requirements (e.g., accounting laws, tax regulations, anti-money laundering laws).
Consent: for certain types of data or purposes (e.g., email marketing), we obtain Your explicit consent. You may withdraw Your consent at any time by contacting us via the methods listed below.

5. Disclosure of Personal Data to Third Parties

The Company respects Your privacy and shares Your data with third parties only when necessary and based on legal grounds:

Payment processors: Your payment details are processed by reliable third-party payment systems (e.g., Stripe) for payment processing. These operators act in accordance with their own privacy policies and PCI DSS security standards.
IT service providers: We may engage third-party companies for platform hosting, data storage, analytics (e.g., Google Analytics), or email delivery. These providers have signed confidentiality agreements and are not permitted to use the data for purposes other than providing services to the Company.
Successors: In the event of reorganization, merger, or business sale, personal data may be transferred to the successor entity, ensuring that Users' rights are preserved in accordance with the law.
Government authorities: The Company may disclose User information upon a lawful request from a court, law enforcement, or other competent authorities if required by law.

6. International Data Transfers

Since the Company is registered in the UK and serves clients worldwide, Your data may be transferred and stored outside Your country of residence. When transferring data internationally, we ensure compliance with applicable data protection laws:

For EU/EEA Users: If data is transferred outside the European Economic Area, we will rely on GDPR-approved mechanisms (such as Standard Contractual Clauses) to ensure an adequate level of data protection.
For Users from other regions: We apply similar measures in accordance with local legal requirements to ensure the confidentiality of Your data.

7. Data Retention and Security

We retain personal data only for as long as necessary for the purposes specified in this Policy or as required by law. The retention period depends on the type of data and our legal obligations (e.g., payment records must be kept for a minimum period under tax laws).

The Company has implemented technical and organizational measures to protect Your data from unauthorized access, loss, disclosure, or modification. These measures include encryption, restricted access to personal data databases, and regular security audits. However, no method of data transmission over the Internet or electronic storage guarantees absolute security, so we cannot fully prevent all possible security breaches.

8. User Rights

The Company respects Users' rights regarding their personal data, in compliance with applicable laws, including:

Right of access: You have the right to request information about what personal data we store and receive a copy.
Right to rectification: You may request corrections or updates to Your personal data if it is inaccurate or incomplete.
Right to erasure: In cases prescribed by law, You may request the deletion of Your personal data (e.g., if the data is no longer needed or You withdraw Your consent and the Company has no other legal basis for processing).
Right to restrict processing: You may request the temporary suspension of processing (except storage) under certain circumstances, such as verifying data accuracy or the legality of processing.
Right to data portability: For data processed based on consent or a contract and by automated means, You can request the data in a structured, machine-readable format for transfer to another party.
Right to object: You have the right to object to data processing based on the Company's legitimate interest or for direct marketing. In the latter case, processing for marketing will be stopped.
Right to withdraw consent: If processing is based on Your consent, You may withdraw it at any time, and we will stop processing the relevant data.

To exercise Your rights, please contact us using the details at the end of this Policy. We will review Your request and respond within the timeframes prescribed by law (e.g., within 30 days for GDPR requests).

9. Cookie Policy

The Company uses cookies and similar tracking technologies to improve platform functionality, personalize content, and analyze traffic. For more details on what cookies we use and how You can manage them, please see our Cookie Policy. By continuing to use our site, You agree to the use of cookies in accordance with this Policy.

10. Contact Us

If You have any questions about this Privacy Policy or wish to exercise Your data protection rights, You can contact the Company:

Email: support@ronin-project.com
Postal Address: RONIN ACADEMY LTD, Dept 5989, 196 High Road, Wood Green, London, United Kingdom, N22 8HH

11. Changes to the Policy

The Company reserves the right to update or modify this Privacy Policy. Changes will be communicated by publishing a new version on our website, with an indication of the effective date. We recommend that You periodically review the Policy for updates. Continued use of our services after changes take effect constitutes Your acceptance of the new Policy.

12. Processing of Minors’ Data

The Company does not collect or process personal data of individuals under the age of 18.

If we discover that we have received data from a minor without confirmed parental or guardian consent, we will delete such data.
If You are a parent or legal guardian and become aware that Your child has provided us with personal data, please contact us to request its deletion.

If a User provides false information about their age, the Company reserves the right to:

Immediately delete their account and cancel all subscriptions without a refund.
Report the incident to the relevant regulatory authorities if required by law.

13. Automated Data Processing and Artificial Intelligence

The Company may use automated algorithms and AI to:

Analyze User behavior on the platform.
Provide personalized recommendations for courses and lectures.
Detect suspicious activities to prevent fraud.

Important!

Decisions affecting the User’s financial status (e.g., account blocking) are never made solely by automated processing – human verification is always conducted.
The User has the right to request an explanation of the logic behind automated processing and object to its use if it affects their rights.

14. Company Actions in Case of Data Breach

The Company takes preventive security measures, but in the event of a personal data breach, we act in accordance with legal requirements, including GDPR, the UK Data Protection Act, and the CCPA (USA).

If we detect unauthorized access to personal data, the Company undertakes to:

Immediately investigate the incident and assess the risks.
Notify affected Users within 72 hours (if required by law).
Take measures to prevent future breaches, including strengthening security systems.
Report the breach to regulatory authorities (e.g., the ICO in the UK, GDPR bodies in the EU, CCPA regulators in the USA) if required by law.

If a User suspects that their data has been breached, they may immediately contact the Company at support@ronin-project.com.

15. Cookie Policy and Similar Technologies

Cookies and similar technologies (pixels, local storage, web beacons) are used to:

Improve the functionality of the website and platform.
Personalize content and offers.
Collect anonymous analytics (through Google Analytics, Yandex Metrika, and other services).
Ensure security (e.g., fraud prevention).

For more details on the types of cookies we use and how to manage them, see our Cookie Policy.

16. Policy on Third-Party Services

The Company uses third-party services (e.g., hosting providers, payment systems, analytics platforms). It is important to understand that these services operate under their own Privacy Policies.

Some key services that may process Your data:

Stripe – payment processing (Stripe’s Privacy Policy: here).
Google Analytics – visit analytics (Google’s Privacy Policy: here).
Telegram – message processing in the closed channel (Telegram’s Privacy Policy: here).

The User agrees that the Company is not responsible for data breaches or violations caused by third-party services, but will make every effort to protect the information.

17. Request for Data Deletion

The User has the right to request the deletion of their personal data.

What will be deleted:

The account and all associated data.

Personal information, except for data we are legally required to retain (e.g., payment transactions).

Course and subscription history (except in cases where the law requires retention).

How to submit a request:

Send an email to support@ronin-project.com with the subject "Data Deletion Request".

Processing time – up to 30 days from the date of receipt.

Important!

After deletion, You will lose access to all previously purchased courses and subscriptions.
Data deletion does not affect payment transactions stored by payment processors (e.g., Stripe).

18. Dispute Resolution

In the event of disputes related to the processing of personal data, the User may:

Contact customer support: support@ronin-project.com.
File a complaint with the ICO (Information Commissioner’s Office, UK).
Take legal action in a court at the Company’s place of registration if necessary.

The Company will make every effort to resolve issues out of court.

19. Contact Information

You have any questions regarding this Policy, You can contact us:

Email: support@ronin-project.com

Address: Dept 5989, 196 High Road, Wood Green, London, United Kingdom, N22 8HH
+442045773221

Last updated: February 27, 2025