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Privacy Policy

Last updated: 2 May 2026 · Effective on launch

1. Who we are

This notice describes how Executive Protection London Ltd ("Tier 1 Protection", "we", "us") — a company registered in England and Wales (company number to be inserted), with its registered office at 35 Berkeley Square, Mayfair, London, W1J 5BF — handles personal data collected through our online training platform at tier1-protection.co.uk and any subdomain (the "Platform").

We are the controller of personal data collected through the Platform. You can contact us via our contact form.

2. What we collect, why, and our lawful basis

Account information

When you register, we collect your first name, last name, email address, and a hashed copy of your password (we never store the password itself in clear text). If you sign in with Google, we also receive your Google account ID and confirmation that the account's email is verified. We use this information to identify you, contact you about your account and your courses, and provide the Service.

Lawful basis: performance of our contract with you.

Course progress and test attempts

As you use the Platform we record which lessons you have completed, your quiz and test answers, your scores, and the time and date of each attempt. This is necessary to deliver the Service, enforce per-test cooldowns, generate certificates, and prevent abuse.

Lawful basis: performance of our contract with you; legitimate interests in maintaining the integrity of our certifications.

Identity verification

Before a certificate is issued, you complete a one-time identity check operated by Stripe Identity (a service of Stripe Payments Europe, Ltd.). Stripe collects an image of a government-issued document and a short live selfie directly from you and processes them on its own infrastructure. We do not see, receive, or store those images. Stripe returns to us only the verified first name, last name, and the issuing country, plus a verification timestamp and a Stripe session reference. These appear on your certificate and remain on your account.

Lawful basis: performance of our contract with you; legitimate interests in preventing forged or impersonated certificates. For more on Stripe's processing, see Stripe's privacy notice at stripe.com/privacy.

Payment data

Payments for course access are processed by Stripe. We do not see or store your full card number, expiry, CVC, or banking credentials. We retain a record of each purchase (course or bundle, amount, currency, Stripe session reference, date) for accounting, refunds, dispute handling, and legal record-keeping.

Lawful basis: performance of our contract with you; compliance with our legal accounting and tax obligations.

Final-test proctoring

While you take a final test, the Platform captures periodic webcam snapshots through your browser. These images are reviewed by an administrator to confirm the integrity of the test attempt. The Platform may also record signals such as tab-switching or loss of window focus during a test.

Retention. Snapshots are deleted as soon as they are no longer required:

  • If the test is failed, abandoned, or invalidated for focus violations, snapshots are deleted immediately on submission.
  • If the test is passed and the administrator approves the attempt, snapshots are deleted at the moment of approval.
  • If the test is passed but the administrator rejects the attempt (suspected impersonation, tampering, or other irregularity), snapshots are kept for up to 30 days to allow time for the affected student to dispute the decision, and then deleted automatically.
  • While an attempt is awaiting administrator review, snapshots are retained until reviewed.

Proctoring snapshots are not used for any purpose other than reviewing the integrity of that specific test attempt, and they are not shared with third parties.

Lawful basis: performance of our contract with you (the certificate is conditional on a proctored test); legitimate interests in preventing test fraud and protecting the value of our certifications.

Sessions and authentication tokens

We set a single, strictly necessary session cookie when you log in. The cookie holds only an opaque session identifier; it does not contain your name, email, or any other personal data. We send time-limited links by email for password resets (valid for 1 hour), email-address verification (48 hours), and email-address change confirmation (48 hours).

Lawful basis: performance of our contract with you. The session cookie is "strictly necessary" and does not require your consent under UK GDPR / PECR.

Server logs and security data

Our servers automatically log routine technical information about each request — IP address, request URL, response status, user-agent, and timestamp — for the purposes of troubleshooting, abuse prevention, rate-limiting, and security monitoring. These logs are retained for a short period (typically 30 days) and then rotated.

Lawful basis: legitimate interests in keeping the Service secure and operational.

Contact-form messages

If you submit our public contact form, we receive your name, email, and the message you wrote. We use this to reply to you and, if appropriate, to keep a record of the enquiry.

Lawful basis: legitimate interests in responding to enquiries; performance of pre-contractual steps where you are asking about our services.

3. Cookies

We use only one cookie: a strictly necessary session cookie that keeps you signed in. We do not use analytics, advertising, or third-party tracking cookies on the Platform. Some pages load the Inter and Instrument Sans webfonts via Google Fonts; Google Fonts does not set cookies in the user's browser, but Google may log the request as part of providing the font. If you would prefer not to load fonts from Google, you may block requests to fonts.googleapis.com and fonts.gstatic.com in your browser; the Platform will fall back to your system fonts.

4. Who we share data with

We share personal data only with service providers we engage to run the Service and only to the minimum extent needed for them to perform their role:

  • Stripe Payments Europe, Ltd. — payment processing and identity verification.
  • Google LLC — only if you choose to sign in with Google (we receive your account ID and email from Google).
  • Our hosting and email providers — used to operate the Platform infrastructure and deliver transactional email such as verifications and password resets.

We do not sell personal data, and we do not share personal data for the purposes of cross-context advertising. We may disclose data where we are required to by law, court order, or other legal process, or where it is necessary to protect our rights or the safety of others.

5. International transfers

Some of our service providers (notably Stripe and Google) may process personal data outside the United Kingdom, including in the United States. Where this happens, the transfer is covered by a UK-recognised mechanism — typically the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, the UK extension to the EU-US Data Privacy Framework, or another mechanism approved by the UK Information Commissioner's Office — ensuring an essentially equivalent level of protection.

6. How long we keep your data

We keep different categories of data for different periods:

  • Account, course progress, certificates, purchase records: retained for as long as your account is active. If you ask us to delete your account, we will delete or anonymise account data, except where we are required to retain certain records (typically purchase and tax records, for up to six years under UK accounting law).
  • Identity verification result (verified name, country, timestamp): retained for the lifetime of any associated certificate, so the certificate's holder name can be substantiated.
  • Proctoring webcam snapshots: deleted immediately when the test is failed, abandoned, invalidated, or approved by an administrator; kept up to 30 days where an attempt is rejected (dispute window); held until reviewed where pending.
  • Email tokens: 1 hour for password reset; 48 hours for email verification or email change.
  • Server logs: typically up to 30 days.

7. Security

We use industry-standard measures to protect your data, including encryption in transit, secure password hashing, server-side session management, hardened server configuration, and access controls limiting administrator access to authorised staff. No service is perfectly secure; if a personal-data breach occurs and is likely to result in a risk to your rights and freedoms, we will notify the UK Information Commissioner's Office within 72 hours and, where required, notify you directly.

8. Your rights

Under UK GDPR you have the right to:

  • Access the personal data we hold about you;
  • Have inaccurate data corrected;
  • Have your data erased ("right to be forgotten"), subject to our legal record-keeping obligations;
  • Restrict or object to certain processing;
  • Receive your data in a portable format;
  • Withdraw consent where we rely on it (note that most processing is based on contract or legitimate interests, not consent);
  • Lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

To exercise any of these rights, get in touch via our contact form. We will respond within one month, in line with UK GDPR.

9. Children

The Platform is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected such data, please contact us and we will delete it.

10. Changes to this notice

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent changes. Where changes materially affect how we use your personal data, we will notify registered users by email or in-app notice.

11. Contact

Privacy questions, data requests, or complaints can be sent via our contact form or in writing to the address in Section 1.

© 2026 Executive Protection London Ltd. Registered in England and Wales. Company number: to be inserted.