Privacy Policy

This Privacy Policy sets out how we, Thumbs up for Mastery Ltd, collect, store and use information about you when you use or interact with (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 25th April 2020. If you have any questions about this Privacy Policy, you can contact our data protection officer by emailing


When you subscribe to our newsletter and / or complete a query form with Thumbs Up for Mastery we collect information you voluntarily provide to us, such as your name, phone number and email address when you contact us.

Thumbs Up for Mastery does not target, as its customers, children under the age of sixteen. Although visitors of all ages may navigate through our websites, we do not knowingly collect or request personal information from those under the age of sixteen. If we discover, by any means, that a child under sixteen has provided information to us on our site, we will delete the personal information from our records.


We automatically collect some information about you such as that collected by server logs or 3rd party website analytics services, and by using cookies or similar technologies when you visit our website. We may collect information about the type of device you use and its operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the pages you view on our websites and how you interact with that content.


We may receive information about you from social media platforms when you interact with us on those platforms. We may also receive information from your Bank or from PayPal that tells us why a payment transaction on your chosen payment method might have failed.


We process your personal information in order to provide you with the service you have requested from us and signed up for. This processing is necessary for the performance of our agreement with you and helps us provide you with the best possible experience of Thumbs Up for Mastery. We also use your data to develop aggregate analysis and business intelligence that enables us to operate, make informed decisions about, and report on the performance of our business. We have a legitimate interest in processing your data for these reasons.


To help provide you with the best possible customer care we collect certain data by email or by using our contact form, and make tools available to our Customer Care team that process your personal data to help us respond to your enquiries.

We do not routinely offer customer care by telephone but should you contact us by phone, we may collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.

If you contact us by post, we will collect any information you provide to us in any postal communications you send us however we will not keep physical copies of your communication any longer than is strictly necessary to handle your enquiry.We have a legitimate interest in processing your data for these reasons.


We analyse how our website users interact with our website and its features. For example, we analyse total visitor numbers and unique visitors, the time and date of the visit, whether certain pages or sequences of pages were visited, whether a visit resulted in a subscription to our service, the operating system and browser used and approximately where visitors are when they are accessing our websites. We use the information gathered from the analysis of this information to improve our websites.

We have a legitimate interest in improving our websites so that we can provide a better experience for existing customers and to attract new customers to our service.


We use the data we collect to deliver and personalise our communications with you. For example, we may contact you by email to inform you about new products, special offers or to invite you to take part in a survey or provide product feedback. This processing is necessary to serve our legitimate interest.


We use cookies and similar technologies to help us understand how users are using our website.


A cookie is a small data file that is sent by our servers to your computer when you visit our website. When you visit our website again, this cookie can be read and your browser can be recognized. We use the following categories of cookies on our website:

Strictly necessary cookies – these cookies are essential for you to browse our website and use its features and you cannot opt out of receiving them. You can block them using your browsers’ cookie settings but this may prevent you from being able to use our websites. Performance cookies – we use Google Analytics to help us understand things like how long a visitor stays on our website, what pages they find most useful, and how they arrived at our home page. You can find out more about Google Analytics from Google.


Thumbs Up for Mastery may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about Thumbs Up for Mastery across the internet. Examples of this may include a Thumbs Up for Mastery advertisement on a Facebook or Google page, or on a site within Google’s advertising network.


Thumbs Up for Masterydoes not and will never sell personal information about our customers. We do, however, share your personal information with a number of 3rd parties where this is necessary to provide the service you ordered. This may involve your data being transferred outside the EEA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the EEA. We may share information with the following types of third parties:


Thumbs Up for Mastery uses a variety of third-party vendors to carry out critical services like website hosting, online product purchases and shipping, credit card processing printing, and email communications. We will only share your personal data when absolutely necessary. It is our legitimate interest to process your personal data for these purposes.


We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our website and inform you of your rights.


When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, investigative organisations, our affiliates or in legal proceedings.


We will retain your personal information for as long as we deem it necessary to enable you to use the website, to provide your subscriptions to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information please send an email to


While we are committed to protecting against the loss, theft or misuse of your personal information and though we take all reasonable precautions to secure the personal information we collect, no system should be considered completely safe from compromise.

We store the personal data you provide on computer systems that have restricted access and which have suitable backup policies in place. We ensure that our third-party data centre vendors provide adequate security measures. Additionally, your data is protected with encryption during transmission over the Internet.

If you send us any information by email you should be aware that email is not secure and as such this information could be read in transit within systems outside of our control. If you send us information in this manner you do so at your own risk.


Personal data collected by Thumbs Up for Mastery may be stored and processed within or outside the EEA and this is sometimes determined by where our service providers are located, or where they store data. Thumbs Up for Mastery has put in place adequate mechanisms to protect personal information whenever it is transferred internationally, for example by using the Model Contract Clauses as approved by the European Commission or, in the case of suppliers in the US, that they have certified under the EU-U.S. Privacy Shield program.


We want you to be in control of how your personal information is used by us. You have the following rights over your personal information that we hold:

You can ask us for a copy of the personal information we hold about you. You can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you – you can do this by contacting us at . In some situations, you can ask us to delete your personal information. You can object to certain ways in which we are using your personal information. You can also request that we send your personal information to a third party of your choice.

Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information. If you are not satisfied with the way we have handled any enquiry relating to the way we process your personal information you have the right to complain to The Information Commissioner’s Office.


You can opt out of receiving various types of email communications from Thumbs Up for Mastery by contacting us at


‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, bio metric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us. If, however, you inadvertently or intentionally transmit sensitive personal information to us, we will only use and process your sensitive personal information for the purposes of deleting it.


We may modify or update this Statement when necessary, to reflect customer feedback and changes in our products and service. Please review it regularly. When we update this Statement, we will revise the ‘Last Update’ date at the top of the Statement. If there are material changes to the Statement or in how Thumbs Up for Mastery uses your personal data, we will inform you either by posting a notice of such changes, prior to them taking place, or by directly sending you a notification. We encourage you to regularly review this Statement to learn more how Thumbs Up for Mastery is using and protecting your information.


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