Privacy Policy

1. Introduction & Controller Identity

This Privacy Policy explains how sojrevixu ("we") collects, uses, and protects your personal data when you visit sojrevixu.co.uk (the "Site"), when you submit a registration form, and when you contact us by email or through a contact form.

The data controller for the personal data processed through this Site is:

• Legal entity: Sojrevixu Education Ltd
• Address: Unit C1 Willow Court Lotherton Way, Garforth, Leeds, England, LS25 2GB
• Email: [email protected]

We do not appoint a Data Protection Officer (DPO) for this Site because we do not conduct large-scale processing of special-category data. If you have privacy questions, contact us using the email above.

Effective Date: March 14, 2026.

2. Personal Data We Collect

We collect personal data in a few straightforward ways: when you provide it directly in a form, when you email us, and when your browser sends technical information as part of normal web access. The categories below describe what we collect and typical examples.

• Identity and contact data: your name and email address when you register interest or send a message. If you choose to include additional details in your email signature, we may also receive those details.
• Form content: any text you submit in a message field, including training objectives, team size, delivery constraints, and questions about course modules.
• Technical data: IP address, browser type and version, device type, operating system, language settings, and basic diagnostic information.
• Usage data: pages visited, time spent on pages, referrer information, and click paths. This is typically collected via analytics tools only if you consent to analytics cookies.
• Cookies and identifiers: cookie choices and identifiers stored in browser cookies (see Section 4). We also record consent status in a browser cookie so the Site can remember your preferences.
• Conversion events: events such as a successful form submission and the page sequence leading to it. These may be measured through analytics and marketing tools only if you consent.

We do not intentionally collect special-category data (such as health data, religious beliefs, political opinions), financial account details, or government-issued identification numbers through this Site. Please do not submit such information in forms or email.

3. Why We Process Personal Data & Legal Basis (GDPR Article 6)

We process personal data only for defined purposes connected to providing course information, answering questions, operating the Site, and measuring whether our pages are useful. Under the GDPR/UK GDPR, each purpose requires a legal basis:

• Registration and contact forms: we process your name and email to respond with course details and next steps. Legal basis: GDPR Article 6(1)(b) (steps at your request prior to entering into a contract) and Article 6(1)(a) (consent, because you choose to submit the form and must confirm you consent to be contacted).
• Site analytics (optional): we may analyse how visitors use the Site so we can improve content clarity and navigation. Legal basis: GDPR Article 6(1)(a) (consent).
• Marketing and remarketing (optional): we may measure advertising performance and build remarketing audiences. Legal basis: GDPR Article 6(1)(a) (consent).
• Security and fraud prevention: we use basic logging and security controls to protect the Site and prevent abuse. Legal basis: GDPR Article 6(1)(f) (legitimate interests in securing our systems).
• Legal compliance: if we must retain certain correspondence or records to comply with legal obligations. Legal basis: GDPR Article 6(1)(c) (legal obligation).

Automated Decision-Making (GDPR Article 22): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.

4. Cookies & Tracking

Cookies are small text files stored on your device. The Site uses cookies for essential functions (like remembering your cookie choice) and, with your permission, for analytics and marketing measurement. Some tracking can also occur via pixel tags or similar technologies that send event data to service providers.

Cookie categories used on this Site

• Essential cookies (always active): required for the Site to function, including keeping the Site stable, preventing abuse, and remembering your cookie preferences. Examples include _site_session and cookie_consent. Retention: session to 12 months (depending on the cookie).
• Analytics cookies (optional, consent required): used to understand usage and improve content. We reference Google Analytics 4 (GA4) as our analytics provider, with IP anonymisation. Example cookies include _ga (2 years) and _ga_XXXXXXXXXX (2 years). Data retention is typically 14 months.
• Marketing cookies (optional, consent required): used to measure advertising performance and support remarketing audiences. Example cookies include _gcl_au (Google Ads, 90 days), _fbp (Meta, 90 days), and _fbc (Meta click identifier, 90 days when set).

Beyond cookies, marketing and analytics systems may process device identifiers derived from technical signals such as IP address and User-Agent, and may measure conversion events like a form submission. If used, these are activated only after consent for the relevant category.

5. Consent (EEA/UK)

Users in the EEA and UK receive a consent notice under GDPR/UK GDPR. Analytics and marketing cookies activate only after explicit, informed, freely given consent (GDPR Article 6(1)(a)).

Your choices are recorded in the cookie_consent browser cookie (typically retained for 12 months). You may withdraw consent at any time by using the "Manage cookie preferences" link in the footer or by clearing cookies in your browser settings. Withdrawal does not affect the lawfulness of processing carried out before you withdrew consent.

6. Sharing With Advertising & Service Partners

We use a small number of service providers to operate and improve the Site. Depending on your cookie choices, certain providers may receive limited data such as cookie identifiers, usage events, and conversion signals.

• Google LLC (Google Analytics 4, Google Ads, Google Tag Manager, remarketing): may receive cookie IDs, usage data, conversions, and audience signals when analytics/marketing consent is given. https://policies.google.com/privacy
• Meta Platforms (Meta Pixel, Custom/Lookalike Audiences, Conversion API where implemented): may receive page view events, conversions, audience membership signals, and (where used) hashed identifiers when marketing consent is given. https://www.facebook.com/privacy/policy
• Cloudflare (CDN and security): may process IP addresses and security telemetry to protect the Site from abuse. https://www.cloudflare.com/privacypolicy/

We do not sell personal data. Where service providers process data on our behalf, they do so as processors or service providers under contractual terms. We do not permit these providers to use Site data for their own independent commercial purposes.

7. International Transfers

Some providers we use (such as Google and Meta) may process data outside the UK/EEA, including in the United States. Where international transfers occur, we rely on appropriate safeguards such as:

• EU-US Data Privacy Framework (primary, since July 2023) and the UK Extension to the DPF where applicable
• Swiss-US Data Privacy Framework where applicable
• Standard Contractual Clauses (EU 2021/914) as a fallback
• UK International Data Transfer Addendum (UK IDTA) as a fallback

If you would like more details about transfer safeguards for a specific provider, email us at [email protected].

8. Retention

We keep personal data only for as long as necessary for the purposes described in this Policy, unless a longer retention period is required by law.

• Contact and registration submissions: up to 2 years from the last interaction, to follow up and provide course information.
• Email correspondence: for the duration of the relationship plus 1 year, unless a shorter period is appropriate.
• Server logs: typically up to 90 days for security and troubleshooting.
• Analytics data: typically 14 months (where analytics consent is given and analytics is enabled).
• Marketing cookies: retained according to cookie lifetimes (for example 90 days) where marketing consent is given.
• Cookie consent record: we may retain a record of consent choices for up to 3 years for audit and compliance purposes.
• Legal and tax obligations: where applicable, retention may be 6–10 years depending on the record type.

9. Your Rights (GDPR & UK GDPR)

Depending on your location, you may have rights over your personal data, including:

• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure (Article 17)
• Right to restriction (Article 18)
• Right to data portability (Article 20)
• Right to object (Article 21)
• Right to withdraw consent at any time (Article 7(3))
• Right to lodge a complaint with a supervisory authority (Article 77)

To exercise your rights, email [email protected]. We respond within 30 days, although this may be extended by up to 60 days for complex requests. We may ask for reasonable verification to protect your data.

Supervisory authorities and guidance:

• EU: European Data Protection Board (EDPB) https://edpb.europa.eu
• UK: Information Commissioner’s Office (ICO) https://ico.org.uk
• Germany: BfDI https://www.bfdi.bund.de
• France: CNIL https://www.cnil.fr
• Poland: UODO https://uodo.gov.pl
• Spain: AEPD https://www.aepd.es

10. Children

This Site is not directed at individuals under 16. We do not knowingly collect personal data from minors. If we learn that we have collected personal data from a child under 16 without verifiable parental consent, we will delete it promptly.

11. Do Not Track

This website does not respond to Do Not Track (DNT) browser signals. Third-party providers may have their own DNT handling and opt-out mechanisms.

12. Data Deletion Requests

To request deletion of personal data we hold about you, email [email protected] with the subject line Data Deletion Request. We aim to complete requests within 30 days after reasonable identity verification. We may retain limited information where required to comply with legal obligations or to establish, exercise, or defend legal claims.

13. Business Transfers

In the event of a merger, acquisition, asset sale, financing, or insolvency, personal data may be transferred to a successor entity. If such a transfer materially changes how personal data is used, we will provide notice on the Site.

14. California (CCPA / CPRA)

If you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA) as amended by the CPRA. In the last 12 months, the Site may have collected the following categories:

• Identifiers: name, email, IP address, cookie IDs (shared with service providers and advertising partners based on consent).
• Internet or network activity: browsing interactions and usage events (shared with analytics and advertising partners based on consent).
• Inferences: interests or preferences inferred from browsing behaviour for advertising measurement (based on marketing consent, where enabled).

We do not sell personal information as defined by the CCPA. We do share certain data for cross-context behavioral advertising when marketing cookies are enabled. California residents may opt out of sharing via the cookie preferences panel.

You may request to Know, Delete, or Correct your personal information, or to opt out of sale/sharing, by emailing [email protected] with the subject line California Privacy Request. We may require identity verification. Authorized agents may submit requests with written proof of authorization.

15. Virginia (VCDPA)

If you are a Virginia resident, you may have rights under the Virginia Consumer Data Protection Act (VCDPA), including access, correction, deletion, portability, and the right to opt out of targeted advertising.

To submit a request, email [email protected] with the subject line Virginia Privacy Request. We do not sell personal data or engage in profiling producing legal or similarly significant effects.

If we decline your request and you wish to appeal, email us with the subject line Appeal of Refusal — Privacy Request. We will respond within 60 days. If your appeal is unsuccessful, you may contact the Virginia Attorney General.

16. Nevada

Nevada residents may submit a verified opt-out request by emailing [email protected] with the subject line Nevada Do Not Sell Request. We do not currently sell personal information under Nevada Revised Statutes Chapter 603A.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Site, our training delivery practices, or legal requirements. Material changes will be announced via a Site notice at least 14 days before taking effect. The "Last Updated" date at the top of this page will change whenever we revise the Policy.

18. Contact

If you have questions about this Privacy Policy or wish to exercise your rights, contact:

• Sojrevixu Education Ltd
• Unit C1 Willow Court Lotherton Way, Garforth, Leeds, England, LS25 2GB
• [email protected]