Price Exposures - Crude Oil

GDPR Privacy Policy

This policy describes how we use your personal data when you use our website (http://www.twotwofive.learnupon.com) or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe.  You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

We use sub-headings to help you find specific information that you may be looking for more easily.

Who we are and how you can contact us

We are TwoTwoFive Concepts Ltd, a company registered in England and Wales with the company number 7614676 and our registered office is 1 Pond Lane, Bentfield Road, Stansted Mountfitchet, Essex CM24 8JG.

You can contact us in writing at TwoTwoFive, 124 City Road, London EC1V 2NX or by emailing learnmore@twotwofive.com.  If you would like to speak to us please call us on +44 (0) 203 693 3946.

What personal data we collect about you

We collect:

• personal data that you provide to us.  There are lots of ways in which you may share your personal data with us, for example, you may register on our website to use our online system or contact us in connection with services that you would like to buy, or have already bought, from us. The personal data that you provide to us may include your name, job title, address, e-mail address and phone number.
• personal data that we receive from third parties.  If we work with other businesses or use sub-contractors these parties may collect personal data about you which they will share with us.  For example, we may have your name and contact details passed to us by one of our training course partners with whom we are running a course in which you are participating.
• personal data about your use of our website.  This is technical information and includes details such as your IP address, your login information, browser type and version, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages you viewed or searched for, page response times, download errors, length of visits to certain pages.

What we use your personal data for

We use your personal data in the following ways:

• personal data that you provide to us is used to:
  • provide you with the information and services that you request from us
  • manage and administer our business
  • review and improve our service
• personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
• personal data about your use of our website is used to:
  • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
  • as part of our efforts to keep our site safe and secure

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it.  In the day to day running of our business, we may use your personal data without asking for your consent because:

• we are entering into and carrying out our obligations under a contract with you
• we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights

In exceptional circumstances, we may wish to use your personal data for a different purpose which does require your consent.  In these circumstances, we will contact you to explain how we wish to use your data and to ask for your consent.  You are not required to give consent just because we ask for it.  If you do give consent you can change your mind and withdraw it at a later date.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you - this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the Who we are and how you can contact us section.

You also have rights to:

• have inaccurate personal data corrected, blocked or erased
• object to decisions being made about you by automated means
• object to our using your personal data in ways that are likely to cause you damage or distress
• restrict our use of your personal data
• require that we delete your personal data

You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

When we will share your personal data with others

We share your data with the following people in the day to day running our business:

• other companies that are part of the TwoTwoFive group
• any business partners, suppliers and sub-contractors we work with to provide you with services that you have requested from us
• analytics and search engine providers that assist us in the improvement and optimisation of our site

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use or our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure.  The security measures we take include:

• only storing your personal data on our secure servers
• keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
• maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you have requested information from us or purchased services from us and you have not opted out of receiving marketing
• you request marketing to be sent to you
• you have registered an account on our website and have indicated during the sign-up process that you are happy to receive marketing communications

We may send you marketing communications by email.

You can check and update your current marketing preferences or ask us not to send you any further marketing communications at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") by us or by our sub-contractors. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How long we keep your personal data

We only keep your personal data for as long as we actually need it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please note that we may anonymise your personal data or use it for statistical purposes.   We keep anonymised and statistical data indefinitely, but we take care to ensure that such data can no longer identify or be connected to any individual.

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the Who we are and how you can contact us section above.

If you are dissatisfied with a TwoTwoFive course, please submit your complaints by email to learnmore@twotwofive.com for consideration. Please include your name, company name, and telephone number.  All complaints will be reviewed promptly. If a refund is requested and authorised, you will be contacted to make arrangements for a refund or a voucher to take another TwoTwoFive course.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk.  Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law. 

The easiest way to check for updates is by looking for the latest version of this policy on our website or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.

Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.

This is policy version 5 which came into effect on 1st January 2024.

General Terms & Conditions

The following policy concerns the purchase of any content from the TwoTwoFive store. 'Delegate' refers to anyone purchasing a course.

Purchasing a Live Online Academy, a Live Online Course or an E-Learning course

Live Online Academies and Live Online Courses involve Live Sessions which will run between the dates specified at the time of booking.

There is a minimum attendance level of four (4) delegates and a maximum of twelve (12) delegates for each advertised Live Online Academy and Live Online Course.

Should the minimum number of delegates not be met for the Live Online Academy or Live Online Course you are booked on, then TwoTwoFive will notify you of any cancellation three (3) business days prior to the commencement of the course ('TwoTwoFive cancellation'). You will be entitled to either transfer to another date or a full refund.

Should the maximum number of bookings (12) be exceeded for the Live Online Academy or Live Online Course you are booked on, then TwoTwoFive will contact you immediately to advise you of this. You will be entitled to either transfer to another date or a full refund.

Should you wish to cancel either a Live Online Academy or Live Online Course ('Delegate cancellation') then you may do so by giving not less than ten (10) business days notice prior to the scheduled start date of the course and receive a full refund, less an admin fee of £150+VAT.

Delegate cancellations notified between five (5) and ten (10) business days prior to the commencement of the course will be entitled to a 50% refund of the course fee or transfer to another date free of charge. 

Delegate cancellations of less than five (5) business days will not be entitled to a refund, but delegates may transfer to another date free of charge.

Access to the learning materials for the Live Online Academies will expire on the first Friday after the published Academy dates.

Purchasing a TwoTwoFive E-learning course entitles the user to a set number of days of unlimited access to the specific course; the number of days is clearly stated when purchasing that specific course.  

For any course that includes access to a trading simulation, you will be sent login details and be given access to the trading simulator, herein referred to as 'Ignite' in accordance with the details specified on the course description page of our store.

The username and password for Ignite are confidential and remain the property of TwoTwoFive and must not be shared, assigned, or transferred to any third party without TwoTwoFive’s permission in writing. 

The Delegate acknowledges it must not permit the sharing of any username and password (or other access keys or credentials) and accepts that it will be wholly liable for any acts carried out or omitted to be carried out using those usernames, passwords keys and credentials. Should a Delegate become aware of any unauthorised use or other breach of security, the Delegate will immediately notify TwoTwoFive of such breach.

The Delegate shall not, and shall ensure that its representatives shall not interfere with or cause damage to Ignite or its hosting software, including but not limited to attempting to circumvent security, hack into or otherwise disrupt or corrupt any computer system, server, website, router or other device, whether knowingly or recklessly. The Delegate is responsible for the cost of making good any such damage, whether caused by itself or third parties engaged on its behalf.

The Delegate shall not access, store, distribute or transmit any Viruses, or any material during the course of its use of the E-Learning materials or trading simulator that:

(a)       are unlawful, harmful, threatening, defamatory, obscene, infringing, harassing or racially or ethnically offensive;

(b)       facilitate illegal activity;

(c)       depict sexually explicit images;

(d)       promote unlawful violence;

(e)       are discriminatory based on race, gender, colour, religious belief, sexual orientation, disability, or any other illegal activity; or

(f)        cause damage or injury to any person or property;

and TwoTwoFive reserves the right, without liability to the Delegate, to disable the Delegate’s access to any material that breaches the provisions of this clause.

The Delegate shall not:

(a)       attempt to copy, modify, duplicate, create derivative works from, frame, mirror, republish, download, display, transmit, or distribute all or any portion of the trading simulator and/or the E-Learning materials in any form or media or by any means; or attempt to reverse compile, disassemble, reverse engineer or otherwise reduce to human-perceivable form all or any part of the Software; or

(b)       access all or any part of the E-Learning materials in order to build a product or service which competes with TwoTwoFive; or

(c)       use the E-Learning materials to provide services to third parties