Privacy Policy — DriveX Academy

Last updated: 25 May 2025 | FOUR PEARLS CAPITAL LTD, Company No. 17152753

1. Data Controller

This Privacy Policy describes how FOUR PEARLS CAPITAL LTD ("we", "us", "our", or "the Company"), incorporated in England and Wales under Company Number 17152753, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX, collects, uses, stores, and protects personal data in connection with the DriveX Academy website at nfpassive.com (the "Website").

FOUR PEARLS CAPITAL LTD is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. If you have any questions about this Privacy Policy or our data practices, please contact us via the details set out in Section 11 below.

2. Information We Collect

We collect personal data that you voluntarily provide to us when you use the Website, including when you complete our enrolment form or contact form. The categories of personal data we collect include:

Full name (first name and last name)
Email address
Telephone number (including mobile numbers)
Any additional information you include in a free-text message field
Technical data, including IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology identifiers on the devices you use to access our Website
Usage data, including information about how you use the Website, products, and services
Cookie and tracking data as further described in Section 9 below

We do not knowingly collect special category personal data (such as data concerning health, racial or ethnic origin, or biometric data) through this Website.

3. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

To provide you with access to the DriveX Academy educational content and materials
To respond to enquiries you submit through the contact or enrolment forms
To send you relevant educational information, updates, and communications relating to HGV/LGV training, where you have consented to receive such communications
To improve the Website and our content based on how users interact with the site
To comply with legal obligations to which we are subject
To protect the security and integrity of the Website
To detect and prevent fraud, spam, and other unlawful activity

4. Legal Basis for Processing

We process your personal data on the following legal bases as set out in the UK GDPR:

Consent (Article 6(1)(a)): Where you have given us clear consent to process your personal data for a specific purpose, such as receiving marketing communications or accepting cookies.
Legitimate Interests (Article 6(1)(f)): Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes improving the Website, fraud prevention, and ensuring network and information security.
Legal Obligation (Article 6(1)(c)): Where processing is necessary for compliance with a legal obligation to which we are subject.
Performance of a Contract (Article 6(1)(b)): Where processing is necessary to fulfil a request you have made, such as providing access to our educational materials.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with:

Service providers and data processors who assist us in operating the Website, delivering content, and communicating with users (such as hosting providers, email platforms, and analytics services), subject to appropriate data processing agreements
Professional advisors such as lawyers and accountants, where necessary
Law enforcement authorities, courts, or government bodies where disclosure is required by law or to protect the rights, property, or safety of the Company or others

Where we transfer personal data to service providers outside the United Kingdom, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements, such as Standard Contractual Clauses or adequacy decisions.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal requirements.

Where you have submitted an enquiry or enrolment request, we will typically retain your contact data for up to 24 months unless you request earlier deletion or we no longer require it for the purposes described in this Policy.

7. Your Rights Under UK GDPR

You have the following rights in relation to your personal data under UK GDPR:

Right of access: You have the right to request a copy of the personal data we hold about you.
Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
Right to erasure: You have the right to request that we delete your personal data in certain circumstances.
Right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
Right to data portability: Where we process your data by automated means on the basis of your consent or for the performance of a contract, you have the right to receive your data in a structured, commonly used, and machine-readable format.
Right to object: You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis.
Right to withdraw consent: Where we process your data on the basis of consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the details in Section 11. We will respond to your request within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe we have not handled your personal data in accordance with applicable law.

8. Security of Your Data

We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental loss, unauthorised access, use, alteration, or disclosure. These measures include the use of secure server infrastructure and access controls. However, no transmission over the internet is completely secure, and we cannot guarantee the absolute security of data transmitted to or from the Website.

9. Cookies

The Website uses cookies and similar tracking technologies to distinguish you from other users and to improve your experience. Cookies are small text files placed on your device by the Website. We use the following categories of cookies:

Strictly necessary cookies: Required for the Website to function and cannot be switched off. These include cookies that record your cookie consent preference.
Analytics cookies: Allow us to count visits and understand how visitors interact with the Website. All information collected is aggregated and anonymous.
Functional cookies: Enable enhanced functionality and personalisation, such as remembering your preferences.

You can manage your cookie preferences at any time using the cookie banner displayed when you first visit the Website. Most web browsers also allow you to refuse or delete cookies through their settings. Note that disabling cookies may affect the functionality of the Website.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this Policy periodically to stay informed about how we are protecting your personal data. Your continued use of the Website after any changes constitutes your acceptance of the updated Privacy Policy.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Company: FOUR PEARLS CAPITAL LTD
Company No.: 17152753
Address: 128 City Road, London, United Kingdom, EC1V 2NX
Website: nfpassive.com
Contact form: Contact page

You may also contact the Information Commissioner's Office (ICO) if you have a concern about our use of your personal data: ico.org.uk or call 0303 123 1113.