Mastered Privacy and Data Protection Notice

Written September 2018 by Eric Waring, Head of Engineering

Last updated Sept 2022 by Eric Waring, Head of Engineering

Next update Sept 2024 by Eric Waring, Head of Engineering

This document is written for brevity in plain language. It is not an exhaustive list of all aspects of our privacy and data protection practices. If you would like more information on these, please contact us for more details.

General

At Mastered, we’re committed to protecting and respecting your privacy. This privacy and data protection notice applies to data collected from our members and customers by Mastered Studios Ltd (referred to as “Mastered”, “We”, “Us”, etc).

This policy explains:

What we collect
Why we collect it
What our lawful basis is for processing it
What you can expect us to do with the data
The conditions under which we may disclose it
How long we keep it for
How we keep it secure
You choices
Your rights

In this policy, we refer to the Mastered Community. You are considered to be a member of the Mastered Community if you have ever had an active enrollment with us (including free and funded enrollments).

We may change this policy from time to time so please check this page occasionally to ensure that you’re happy with any changes.

Point of contact

Any questions regarding this policy and our privacy practices should be sent to us by email to hello@mastered.com or by writing to Mastered Studios Ltd, 124 City Road, London, EC1V 2NX, United Kingdom.

Mastered Studios Limited, known as Mastered, is a private company limited by shares with company registration number 11585221 and whose registered address is at 124 City Road, London, EC1V 2NX.

Personal data we collect

Device, analytics, and location information

Whenever you visit our website and/or watch any videos of ours, we may capture your activity, any device information provided to us by your browser, and approximate location via your IP address. We use this data to understand how our marketing activities are performing and how users are interacting with our site.

We collect this whenever you interact with our site, including when you apply, enrol or participate on an accelerator or bootcamp, when you you interact with as a member of the Mastered community or a Mastered Alumni.

Lawful basis for collecting and processing device, analytics, and location information

Legitimate interest: We process this data in order to assess the performance of our marketing, improve lessons, coaching and mentoring and troubleshoot issues with the service we deliver. In aggregate form we will use this data to analyse the usage of our services to identify areas for improvement.

How you can expect us to use this data

If you become a member of the Mastered community we may use this data to personalise our communications with you based on how you’ve interacted with our site. For example, if you are participating in an accelerator we may contact you if we notice you haven’t visited the site recently, or haven’t watched a video recently. We may also use this data to help improve the tools and user experience of the website.

When we share this data

We use third party software to collect and process this data, but we remain the data controller.

How long will we retain this data

We will retain this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community.

Contact and profile information

When you register or apply for one of our accelerators or bootcamps we will ask you for contact information such as email address and phone number, social media identifiers, as well as qualifications and experience level. If we offer you a place on an accelerator you will also be asked to set up an account and create a password.

If applying for a government or local authority funded or co-funded Skills Bootcamp we will also need to collect information on your gender, ethnicity, place of residence, employment status, benefits claimed and health and learning problems.

Lawful basis for collecting and contact and profile information

Consent: Where you have chosen to receive marketing materials related to third party products and services, we will contact you with those offers. You can withdraw consent at any time.

Legitimate interest: At the point of applying, we use the contact information you provide to process your application and to ensure you understand the services we offer. We will also use this data for our legitimate interest in developing our business.

If your contact information has been supplied to us via a member of the Mastered community as a referral, we record this information in order to reward you as a referee and the referrer.

For those applying for a government or local authority funded or co-funded SKills Bootcamp gender, ethnicity, place of residence, employment status, benefits claimed and health and learning problems are required by the government/local authority in order to fund your place and for research purposes. The exact requirements for each Bootcamp is clearly stated in separate privacy statements for each bootcamp from the relevant funding agency.

Performance of contract: If you participate in an accelerator or become a member of the Mastered community we require this information in order to deliver services you have contracted us to deliver.

We may use third party data processes in order to collect your data (eg. event management software), but we remain the data controller.

How you can expect us to use this data

Where you have provided consent: You can expect to receive marketing emails about third party products and services

Where we have a legitimate interest: You can expect that we will email and call you about your application. You can also expect that we will use retargeting on social media to display ads to you if you do not complete your application. You can also expect that we will contact you about future accelerators that are related to your area of interest while your personal data remains within our data retention policy (see below). You can opt out of emails at any time.

If your contact information has been supplied to us via a member of the Mastered community as a referral, you can expect that we will try to contact you up to 3 times.

Where we are performing duties of a contract: You can expect us to use the information you provide to personalise our interactions with you in order to keep track of your progress. We will contact you via any contact details you provide, including social media, in order to help you get the most out of our service.

As a participant in an accelerator or bootcamp, or a member of the Mastered community, we will share your contact and profile information, and accelerator information with third parties (eg. coaches, mentors, experts, exposure partners, event hosts and other members of the community) that are delivering part of the accelerator or bootcamp you are participating in. This will be clearly outlined to you throughout your accelerator or bootcamp and is a core service we provide. You will have a choice about participating service and be able to choose which third parties you interact with.

As an applicant for a government/local authority Skills Bootcamp we will share your contact, profile, health and employment information with the funding government/local authority. Details will be clearly listed in their own privacy notices which we will send you as part of the application process and to which you must agree before we submit any data to them.

As a member of the Mastered community or a Mastered Alumni, you can expect us to share your contact and profile information with third parties (eg. exposure partners, other members of the community) that are beneficial for you. You can expect us to check with you before we do this.

When we share this data

We may share your personal data with individuals or organisations in order to deliver a service you have contracted us to deliver. We will do this in the following situations:

Feedback, mentoring and coaching calls: As part of our accelerators and bootcamps we will share your contact information and anything else you choose to share with the experts and coaches we have engaged to deliver those services. Your personal data will only be shared with the individual you choose to book in with. Your personal data may be shared on our platform, in calendar invitations and automated emails.
Exposure opportunities: As part of our accelerators and bootcamps, and as a member of our community, we may share your contact details with organisations we choose to partner with to provide career opportunities. We will only do this once we have informed you of the opportunity.
Events: We will share your contact details with event hosts of events you have agreed to attend for the purpose of keeping you up to date with changes to event details.
The Mastered community: On our platform you are able to control which contact details other members of the Mastered community are able to access. You can control this from your Profile settings.
Government/local authority Skills Bootcamp: we will share your gender, ethnicity, place of residence, employment status, benefits claimed and health and learning problems information to the relevant government/local authority to apply for Skills Bootcamp funding for you to do the bootcamp.

We may use third party software to collect and process this data, but we remain the data controller.

We share this personal data with any accelerator partners who work with us to deliver an accelerator on which you have enrolled. We will let you know the identity of any accelerator partner on the landing page for the relevant accelerator. We share your personal information only as required to enable the accelerator partner to deliver the services we require from them.

How long will we retain this data

We will retain this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community. If your contact information has been supplied to us via a member of the Mastered community as a referral we will keep it for a period of 12 months so that we can reward the referrer.

Payment information (not applicable to Skills Bootcamps)

When you pay for your accelerator we will capture information related to the payment transaction. When you are using our secure online payment pages, your payment is processed by third party payment processors, who specialises in the secure online capture and processing of credit/debit card transactions.

Lawful basis for collecting and payment information

Necessity: We are legally obliged to keep a record of all financial transaction.

How you can expect us to use this data

You can expect that we will keep a record of any payments you have made to us, and any future payments you have commited to as part of entering into a contract with us. We will issue you with invoices for payments made, and you can expect us to contact you about any failed payments. You can also expect us to share this information with our financial auditors

When we share this data

If you make a payment, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions. We use Stripe or PayPal as our payment providers. They remain the data controller and data processor of you payment instrument data.

We may share our records of financial transactions with approved auditors in order to comply with financial reporting obligations. We may share this information with regulatory bodies where required to do so by law.

We use third party software to collect and process this data, but we remain the data controller.

How long will we retain this data

We will retain this data for 7 years for financial records.

Accelerator information (not applicable to Skills Bootcamps)

When you participate in one of our accelerators or courses we will ask you to submit responses to the exercises included within the accelerator. This may include free form text responses, videos, files you have prepared for upload, and images. Please be aware that many modern devices such as digital cameras and smartphones may capture your location and embed the GPS coordinates in the image file. We do not attempt to access this data, but also do not remove it from your images.

Lawful basis for collecting and accelerator information

Performance of contract: If you participate in an accelerator or become a member of the Mastered community we require this information in order to deliver services you have contracted us to deliver.

How you can expect us to use this data

You can expect us to use the information you provide to personalise our interactions with you in order to keep track of your progress and deliver transformational learning experiences. We will contact you via any contact details you provide, including social media, in order to help you get the most out of our service.

As a participant in an accelerator, or a member of the Mastered community, we will share your contact and profile information, and accelerator information with third parties (eg. coaches, experts, exposure partners, event hosts and other members of the community) that are delivering part of the accelerator you are participating in. This will be clearly outlined to you throughout your accelerator and is a core service we provide. You will have a choice about participating service and be able to choose which third parties you interact with.

As a member of the Mastered community or a Mastered Alumni, you can expect us to share your accelerator information with third parties (eg. exposure partners, other members of the community) that are beneficial for you. You can expect us to check with you before we do this.

When we share this data

We may share your personal data with individuals or organisations in order to deliver a service you have contracted us to deliver. We will do this in the following situations:

Feedback and coaching calls: As part of our accelerators we will share your contact information and anything else you choose to share with the experts and coaches we have engaged to deliver those services. Your personal data will only be shared with the individual you choose to book in with. Your personal data will be shared on our platform, in calendar invitations and automated emails.
Exposure opportunities: As part of our accelerators, and as a member of our community, we may share your contact details with organisations we choose to partner with to provide career opportunities. We will only do this once we have informed you of the opportunity.
Events: We will share your contact details with event hosts of events you have agreed to attend for the purpose of keeping you up to date with changes to event details.
The Mastered community: On our platform you are able to control which contact details other members of the Mastered community are able to access. You can control this from your Profile settings.

We may use third party software to collect and process this data, but we remain the data controller.

How long will we retain this data

We will retain this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community.

Survey response information

When you respond to a survey that we have invited you to complete, we will collect your answers to the survey.

Lawful basis for collecting and survey response information

Legitimate interest: At the point of applying, we use the survey information you provide to understand more about your experience and interest. Our intention is to ensure we can provide you with the information you need to make an informed decision about whether our services are right for you.

Performance of contract: If you participate in an accelerator or bootcamp or become a member of the Mastered community we require this information in order to deliver services you have contracted us to deliver.

We may use third party data processes in order to collect your data (eg. survey software), but we remain the data controller.

How you can expect us to use this data

You can expect us to use the information you provide to personalise our interactions with you in order to keep track of your progress and deliver transformational learning experiences. We may follow up and contact you about your survey response. We also use this data in aggregate form to analyse and improve the services we provide.

When we share this data

We may use third party software to collect and process this data, but we remain the data controller and will not share identifiable responses outside of Mastered.

How long will we retain this data

We will retain this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community.

Call booking information

When you book a call with a mentor, coach or expert, we will capture the time and date of the call you have booked and who the other participant is in the call.

Lawful basis for collecting and survey response information

Legitimate interest: At the point of applying, we use any call booking information to contact you.

We may use third party data processes in order to collect your data (eg. call booking software), but we remain the data controller.

How you can expect us to use this data

You can expect us to use the information to deliver one-to-one services to you at your preferred time.

When we share this data

We may use third party software to collect and process this data, but we remain the data controller.

How long will we retain this data

The data will be retained on the third party provider in accordance with their data retention policy (YouCanBookMe). We will retain a partial copy of this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community.

Correspondence information

When we interact with you via email, SMS, phone, google hangouts, skype and other VOIP / video calling applications, we may keep a record of the conversation for our records. When you interact with us via social media channels (eg. Facebook, Instagram, etc) we will retain a copy of those interactions within the social media platform and any tools we use to manage our social media accounts.

Lawful basis for collecting and correspondence information

Legitimate interest: We keep track of our communication in order to keep track of your conversations with us. This allows us to investigate complaints, monitor compliance with our terms and conditions or understand miscommunications and to facilitate staff training.

We may use third party data processes in order to collect your data (eg. helpdesk software), but we remain the data controller.

How you can expect us to use this data

You can expect us to use your correspondence to inform our correspondence with you and to deliver a more personalised service.

When we share this data

We may use third party software to collect and process this data, but we remain the data controller.

How long will we retain this data

We will retain this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community.

Event attendance information

When you attend an event we host or facilitate we will keep a record of your attendance and the location and time of the event.

Lawful basis for collecting and event attendance information

Legitimate interest: We keep track of your attendance at events for marketing and service delivery purposes. This allows us to investigate complaints, monitor compliance with our terms and conditions or understand miscommunications.

Performance of contract: As an accelerator participant, or member of the Mastered community we will collect information on event attendance as part of delivering a service you have contracted us to provide.

We may use third party data processes in order to collect your data (eg. event management software), but we remain the data controller.

How you can expect us to use this data

You can expect us to use the information to deliver or facilitate events that you can attend.

When we share this data

We will share your attendance information with any event hosts in order to deliver the event. We may use third party software to collect and process this data, but we remain the data controller.

How long will we retain this data

The data will be retained on the third party provider in accordance with their data retention policy (Eventbrite). We may retain a partial copy of this data for up to 3 years after your last interaction with us, or while you are a member of the Mastered community.

Our cookie policy

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use cookies and similar technologies (like browser caching and HTML5 local storage) to improve the experience on our site, including recognising you between visits, storing usage preference and to reduce page load speeds.

Your choices

We collect personal information when you provide it to us by either filling out a form on our website, interacting with our site in other ways or by corresponding with us. You do not need to provide us with any personal information, however we are unable to provide a service to you without the minimum contact information of Name, Email and Phone number.

Occasionally we may find and use publicly available information about you, such as a social media profile. You are able to control access to what information is publicly available about you on those services you have engaged with.

If you have enrolled in an accelerator, you are able to request a refund within the timeframes set out in our terms and conditions.

Your rights

The GDPR provides the following rights for individuals. We will respond to any rights requests as soon as we can, and in no more than 30 days if you email us at hello@mastered.com.

The right to be informed

This policy explains how we intend to use your data, and we will also let you know when you interact with us or our sites. You can also ask what we’re doing with your data at any time .

The right of access

You have the right to access your personal data. If you would like a copy of the data we hold on you, please let us know

The right to rectification

You have the right to correct any information we hold on you. We’re more than happy to update our records so that they are accurate. If you think we have incorrect data on you, please let us know immediately.

The right to erasure

You have the right to ask us to delete your data which we will do, where it is within our power, and we are able to. In certain situations we may not be able to fully delete your data due to legal obligations, but where this is the case we will notify you.

The right to restrict processing

You have the right to ask us to stop processing your data without deleting it.

The right to data portability

You have the right to a copy of the information we collect on you in a machine readable format. Please inform us of the format you would like the data in.

The right to object

You have the right to object to our processing of you data which we will do, where it is within our power, and we are able to. In certain situations we may not be able to fully stop processing your data due to legal obligations, but where this is the case we will notify you.

Rights in relation to automated decision making and profiling

You have the right to know when we use automated decision making and profiling and to withdraw from that processing where it is not essential to the service we provide.

Consent

Where you have provided consent, you have the right to withdraw consent from us at any time. You can do so by updating your marketing preferences from any marketing email you receive from us, or by contacting us at hello@mastered.com at any time.

Automated decision making

We do not use automated decision making or profiling without manual oversight and verification.

Security

Mastered takes security seriously and have Cyber Essentials certification. In order to safeguard your data we take various steps to protect it from loss, misuse, and unauthorised access or disclosure. We follow accepted industry standards, including the use of encrypted transmission (https) of data on all of our sites and services we use to collect and process your personal data. No method of transmission, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security.

Transferring your information outside of the European Union

Mastered may store your data outside of the EU. This occurs when our servers are based in non European Union countries, or service providers we use are located in non European Union countries. These countries may not have the same data protection laws as the UK or the EU. Whenever your personal information is stored outside of the EU we take equivalent steps to ensure its security and that your privacy is protected.

Data Breaches

If the personal data we hold about you is breached or accessed by an unauthorised party, we will inform the Information Commissioner’s Office (ICO). We will also inform you of any breaches or unauthorised access to your data.

Other websites

Our site contains links and references to other websites. Please be aware that this privacy policy does not apply to those websites.

Children

Our services are not directed to children under 18, and we do not offer the service to children under the age of 14. When a child between the ages of 14 and 18 does use our service, it is only with explicit consent of a parent or guardian, and we do not store any age related information. If you learn of a child accessing our services without consent of a parent or guardian, please let us know immediately at hello@mastered.com.

Complaints or queries

We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. Please bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Mastered’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to hello@mastered.com.

If you want to make a complaint about the way we have processed your personal information, you can contact us at hello@mastered.com or at the address below:

Mastered

124 City Road

London, EC1V 2NX

United Kingdom.