Privacy Policy

This page was last updated: 16th May 2018

Crystal Summit Ltd (“Us” / “We” / “Our”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.crystalsummit.net (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site and Services immediately.

1 Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

2 Information About Us

Our Site is operated by Crystal Summit Ltd, a limited company registered in England and Wales under company number 7016249.

Registered address: Crystal Summit Ltd, Suite 13400, 20-22 Wenlock Road, London, N1 7GU

VAT number: 997 8332 49.

3 What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site and Services. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4 What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5 What Are My Rights?

Under the GDPR, you have the following rights, which We will always work to uphold:

• The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions using the details in Part 15.
• The right to access the personal data We hold about you. Part 13 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 15 to find out more.
• The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We have. Please contact Us using the details in Part 15 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to Us using your personal data for a particular purpose or purposes.
• The right to data portability. This means that, if you have provided personal data to Us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6 What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see and Our Cookie Policy):

• Name;
• Date of birth;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Information about your preferences and interests;
• IP address;
• Web browser type and version;
• Operating system.

7 How Do You Use My Personal Data?

Under the GDPR, We must always have a lawful basis for using personal data. This may be because the data is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data, or because it is in Our legitimate business interests to use it. Crystal Summit Ltd will rely upon the Lawfulness of Processing Conditions section 6 (1) (f). 

Your personal data may be used for the following purposes:

• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying services to you. Your personal details are required in order for Us to enter into a contract with you;
• Personalising and tailoring Our services for you;
• Communicating with you. This may include responding to emails or calls from you;
• Providing you with information, products or services that you request from Us or which We feel may interest you, where you have consented to be contacted for such purposes;
• Carrying out Our obligations arising from any contracts entered into between you and Us;
• Notifying you about changes to Our service;
• Maintaining Our financial accounts.

8 How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

9 How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

Some of your data will be stored on Our web hosting management servers maintained and managed by Heart Internet Limited (whose registered office is at 5th Floor, The Shipping Building Old Vinyl Factory, 252 – 254 Blyth Road, Hayes, Middlesex, UB3 1HA and company number is 04866768) for the purpose of maintaining your online accounts with Us. Some of your personal data will be transferred to PayPal (UK) Limited (whose registered office is at 5 New Street Square, London, United Kingdom, EC4A 3TW  and company number is 05468033) for the purposes of processing your payment information. Some of your personal data will be transferred to Clear Books PLC (whose registered office is at Lyric House 149 Hammersmith Road West Kensington, London, W14 0QL and company number is 06636109) for the purposes of managing financial accounts. Some of your personal data will be transferred to Amazon Web Services (AWS), eu-west-1 region (Ireland) for the purpose of data backup. By submitting your personal data, you agree to this storing, processing and transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of 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 your data transmitted to Our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access. Specifically, your personal data will be stored in accordance with the Payment Card Industry Data Security Standard.

10 Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes apart from with Sub-Processors used by Us to fulfill Our contract with you.

If your personal data is required by a Sub-Processor We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11 How Can I Control My Personal Data?

• In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
• You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
• If you have an account with Us, you will have ability to edit your personal details.

12 Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see Our Cookie Policy.

13 How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

A Subject Access Request Form can be downloaded here.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within 2 weeks and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of Our progress.

14 How Do You Use Cookies?

Please see Our Cookie Policy

15 How Do I Contact You?

To contact Us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details.

Postal Address: Crystal Summit Ltd, Suite 13400 20-22 Wenlock Road London N1 7GU.

or use our contact form here.

16 Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.