Privacy Policy

Business Name: Group by ITS LLC
Address: 54 West 39th Street, 2nd Floor, NYC, NY 10018
Email: info@independenttrainingspot.com
Last Updated: June 2024

1. INTRODUCTION
This Privacy Policy describes how Group by ITS LLC (“we,” “us,” or “our”) collects, uses, shares, and safeguards your personal information when you visit our website at www.itsstudios.com (“Site”).

By using our Site, you confirm that you are over 13 years of age and agree to the practices described in this policy.

2. WHAT DATA WE COLLECT AND WHY
We may collect and process the following categories of personal data:

• Communication Data – Includes communications you send via email, forms, social media, etc. Used to respond, maintain records, and manage legal claims. Lawful basis: legitimate interest.
• Customer Data – Includes your name, billing/delivery address, email, phone number, payment and purchase details. Used to deliver services and manage purchases. Lawful basis: contract.
• User Data – Includes data about how you use our website, including published content. Used to manage and secure our Site. Lawful basis: legitimate interest.
• Technical Data – Includes IP address, browser details, login data, visit history, time zones, and device data collected via cookies and analytics tools. Used to improve our Site and marketing. Lawful basis: legitimate interest.
• Marketing Data – Includes preferences regarding marketing communications. Used to promote products/services and manage campaigns. Lawful basis: legitimate interest or consent.

We do not knowingly collect Sensitive Data (e.g., race, religion, health, or biometric data). If we ever require such data, we will obtain your explicit consent.

Failure to provide required data may prevent us from delivering services. We will notify you if this applies.

3. HOW DATA IS COLLECTED
We collect data through:

• Direct interactions (e.g., forms, email)
• Automated technologies (e.g., cookies, analytics)
• Third-party integrations (e.g., Google, Facebook, payment processors)
• Public sources (e.g., Companies House)

4. MARKETING COMMUNICATIONS
You may receive marketing communications from us based on your consent or our legitimate interest. You may opt out at any time via unsubscribe links or by emailing us. We will never share your personal data with third parties for their own marketing purposes without your explicit consent.

5. DATA SHARING
We may share your personal data with:

• IT and infrastructure service providers
• Legal, accounting, insurance, or other professional advisers
• Government or regulatory bodies where required
• Business partners or acquirers in the event of a sale or restructure

All partners must process your data in accordance with applicable data protection laws.

6. INTERNATIONAL TRANSFERS
If your data is transferred outside of the United States or European Economic Area (EEA), we ensure appropriate safeguards are in place. These may include:

• Transfers to countries deemed adequate by the European Commission
• Standard contractual clauses approved by regulators
• Privacy Shield-certified U.S. entities (where applicable)

7. DATA SECURITY
We implement appropriate security measures to prevent unauthorized access, misuse, loss, or disclosure. Only authorised personnel have access to personal data under strict confidentiality.

8. DATA RETENTION
We keep your data only as long as necessary for legal, contractual, and operational purposes. Financial data is typically retained for six years to comply with tax laws. We may anonymise data for analytical use.

9. YOUR LEGAL RIGHTS
Under data protection laws, you have rights including:

• Access to your data
• Correction or deletion
• Restriction or objection to processing
• Data portability
• Withdraw consent where consent was the basis for processing

To exercise any of these rights, contact us at info@independenttrainingspot.com. We may require identity verification. We aim to respond within one month.

10. COMPLAINTS
If you are dissatisfied with how we handle your data, please contact us first so we can resolve the issue. You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk).

11. THIRD-PARTY LINKS
Our Site may contain links to other websites. We are not responsible for their privacy practices. Please review their policies independently.

12. CHILDREN’S PRIVACY
We do not knowingly collect data from children under 13. If we discover such data, we will delete it immediately.

13. CHANGES TO THIS POLICY
We may update this Privacy Policy periodically. Any updates will be posted on this page with a new “Last Updated” date.

14. COOKIES
Cookies are used to enhance your experience and analyse website traffic. You can manage cookie preferences through your browser. For full details, see our Cookie Policy.