Privacy Policy Last updated: 21 August 2025

This Privacy Policy (“Policy”) sets out how GLACIALNAIL ACADEMY LTD (“Company”, “we”, “our”, or “us”) collects, uses, stores, and protects your personal data when you use our website, purchase our digital products, or otherwise interact with our services. We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Data Protection Act 2018. By using our website or services, you acknowledge that you have read and understood this Policy.

1. Company Information • Company name: GLACIALNAIL ACADEMY LTD

• Company number: 16664402

• Registered address: 128 City Road, London, EC1V 2NX, UNITED KINGDOM

• Contact email: glacialnail@gmail.com We are the Data Controller of your personal data, meaning we determine the purposes and means of processing.

2. Categories of Personal Data We Collect We may collect and process the following categories of personal data:

• Identification Data: first name, last name, billing name.

• Contact Details: email address, billing/shipping address, telephone number (if provided).

• Payment Information: processed securely by third-party providers (Stripe, PayPal). We do not store full credit card details.

• Technical Data: IP address, browser type, operating system, device identifiers, access logs.

• Usage Data: interactions with our website, login activity, downloads, course participation.

• Marketing Data: your preferences for receiving marketing communications and newsletters. We do not intentionally collect or process special category data (such as health, political beliefs, religion). If you voluntarily provide such data, you acknowledge that you consent to its processing.

3. Purposes of Processing We process your personal data only where necessary and lawful, for the following purposes:

1. Performance of Contract – to deliver purchased products, provide customer accounts, and issue invoices.

2. Customer Support – to respond to inquiries, complaints, and requests for assistance.

3. Account Management – to enable you to log in, access courses, and track learning progress.

4. Payment Processing – to securely complete transactions via authorized providers.

5. Legal Compliance – to meet obligations under tax, accounting, and consumer law.

6. Marketing Communications – to send newsletters, offers, and promotions (only where consent has been provided).

7. Service Improvements – to analyze user behavior, improve website functionality, and enhance customer experience.

8. Fraud Prevention & Security – to protect against unauthorized access, cyberattacks, or abuse of our services.

4. Legal Bases for Processing We rely on the following legal bases under UK/EU GDPR:

• Contractual Necessity: processing required to provide the purchased product or service.

• Consent: for marketing communications, newsletters, and cookies.

• Legal Obligation: where processing is necessary for tax reporting, accounting, or compliance with applicable laws.

• Legitimate Interest: where we process data to improve our services, prevent fraud, and ensure the security of our systems.

5. Data Retention We retain personal data only as long as necessary for the purposes described in this Policy or as required by law. Retention periods include:

• Account and billing data: up to 6 years from the end of the financial year, for tax and legal compliance.

• Marketing data: retained until you withdraw consent or unsubscribe.

• Technical and usage data: typically up to 12 months, unless required for security or investigations.

• Customer support communications: up to 24 months to handle disputes or follow-up inquiries. Once the retention period has expired, data will be securely deleted or anonymized.

6. Data Sharing and Transfers We may share your data with trusted third parties where necessary, including:

• Payment Processors: Stripe, PayPal.

• Email Marketing Providers: Mailchimp, ConvertKit (only with consent).

• Hosting & Cloud Services: to securely host our website and digital content.

• Legal and Regulatory Authorities: where disclosure is required by law.

• Professional Advisors: accountants, auditors, and legal consultants. International Transfers: If personal data is transferred outside the UK/EEA, we ensure adequate safeguards are in place, such as Standard Contractual Clauses (SCCs), adequacy decisions, or binding corporate rules.

7. Your Rights Under GDPR As a data subject, you have the following rights:

• Right of Access: request a copy of your personal data.

• Right to Rectification: request corrections to inaccurate or incomplete data.

• Right to Erasure (“Right to be Forgotten”): request deletion of data where no longer necessary.

• Right to Restrict Processing: limit how we use your data under certain conditions.

• Right to Data Portability: receive your data in a structured, machine-readable format.

• Right to Object: object to processing based on legitimate interests or for marketing purposes.

• Right to Withdraw Consent: withdraw your consent at any time, without affecting prior lawful processing.

• Right to Lodge a Complaint: with the Information Commissioner’s Office (ICO) in the UK or your local EU authority. Requests can be made by contacting us at glacialnail@gmail.com.

8. Cookies and Tracking Technologies Our website uses cookies and similar technologies to:

• Enable essential functionality (e.g., login, checkout).

• Analyze traffic and improve website performance.

• Personalize marketing (with your consent). For more details, please refer to our Cookies Policy.

9. Data Security We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (SSL/TLS).

• Secure data storage on GDPR-compliant servers.

• Access controls and authentication procedures.

• Regular security audits and monitoring. While we take all reasonable precautions, no system can guarantee 100% security. Customers are responsible for keeping their account credentials confidential.

10. Third-Party Links Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those external websites. We encourage you to review their privacy policies before submitting any personal data.

11. Children’s Privacy Our services are not directed to individuals under the age of 16. We do not knowingly collect data from children without parental consent. If you believe we have collected data from a child, please contact us immediately to request deletion.

12. Changes to This Policy We may update this Privacy Policy from time to time to reflect legal, technical, or business developments. The revised Policy will be published on this page with a new “Last Updated” date. We encourage you to review this Policy periodically. Continued use of our services after updates constitutes acceptance of the revised Policy.

13. Contact Information For any questions, concerns, or data protection requests, please contact us at: 📧 glacialnail@gmail.com 🏢 GLACIALNAIL ACADEMY LTD 128 City Road, London, EC1V 2NX, UNITED KINGDOM