Privacy Policy

Counteroll process your data and personal information as a processor as well as a controller as defined in the General Data Protection Regulation, and we will comply with the Data Protection Act 2018, the General Data Protection Regulation and all applicable laws and regulations relating to the processing of personal data and privacy (as amended or replaced from time to time), including where applicable the guidance and codes of practice issued by the Information Commissioner (in the United Kingdom) or other applicable supervisory authority.

We collect, use and or share your personal information from our site subscribers and user, including the sources from which the information was collected, the purpose for which the information was collected, and the third parties with whom we share or disclose personal information to, only according to this privacy policy.  We collect the following information at registration, subscription or sign up: Name of the subscriber, Date of Birth [Month / Year], Email address, Phone Number, Password and Bank Account details.

We use the personal information we collect from subscribers and users to provide and improve our service, for learning, security purposes, and or as allowed by law. And, for an account sign – up and profile information.

The Name is to assign a user account to you. The Date of Birth enable us to comply to our Terms and Conditions requirement that subscribers and users must be 18+ years old. Email address can be used for username and for correspondence. The Phone number is used for communication with users for messaging [text and WhatsApp] and calls if required. Password is Bank Account details will used for subscription direct debit payments.

We will not retain subscribers and users personal information for any longer than is necessary for learning, legal  and compliance purposes, or to provide the service for which we receive or collect our subscribers and users personal information.

• What Information is Shown Publicly? A subscriber’s account / profile is not made available, visible and or accessible to other subscribers, users, and the public.
• Sale of  Personal Information: We will never sell or rent your personal information or non-personal information. We will only share or disclose personal information as set forth in the Privacy Policy, such as with a limited set of third-party service providers necessary to provide or develop our Services (such as database hosting) or as required by law, and we will be transparent about who these service providers are. We will contractually require that these service providers process personal information in accordance with our instructions and consistent with this Privacy Policy. We ensure that these service providers employ reasonable and comprehensive data protection and security protocols.
• You own your data: We don’t own any content or information you provide, or we receive, and you own your personal information.
• Transparency and Decision Making: We will ensure that our practices are transparent for you to make your decision about how your personal information is used. If we make a material change, we will give you notice by posting a notice on our site page and/or we will notify you by email.

The security of your personal information is very important to us and as such, we use best security systems and practices to protect your information.

Your account is protected by a password or a QR code.  You can help us protect against unauthorized access to your account by always keeping your password or QR code secret. We work hard to protect our community, and we maintain technical and security safeguards designed to protect against unauthorized use, disclosure of, or access to personal information.

Our Systems engineering team will work tirelessly to keep your personal information safe and secure

Regular and scheduled application/systems security testing; penetration testing; quality assurance testing [risk and compliance].

Scheduled review of our information collection, storage, and processing practices [Performance Testing].

We will ensure newly developed features, are tested to ensure your personal information is safe and secure.

We encrypt data and information transmission by using secure socket layer technology (SSL/TLS) by default, which will ensure passwords are stored and trans secure

The Service is hosted on a third-party server, with whom we have a contract providing for enhanced security measures. For example, personal information is stored on a server equipped with industry-standard firewalls.

We restrict access to personal information to authorized Counteroll employees, agents and or contractors who need to know that information to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations

For additional information on our security practices, we make great efforts in utmost good faith to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you [subject to any applicable laws and standard reporting requirements] for you to take appropriate protective steps; and, we may post a notice on our homepage [www.counteroll.com] and may send email to you at the email address you have provided to us.

For more information security and safety questions on Counteroll, please contact us on our site contact page.