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Privacy Policy

Last Updated: March 12, 2026

1. Introduction & Controller Identity

This Privacy Policy explains how crowshard.ink ("we", "us", or "our") collects, uses, and protects personal data when you visit our website and register interest in our smartphone repair training. This policy applies to data processed through our website, forms, cookies, and related communications.

Data Controller: MOBILE ELEMENTS (ACCESSORIES) Ltd, 139 Front Street, Chester-le-Street, DH3 3AU, England. You can contact us about privacy questions at [email protected].

Effective Date: March 12, 2026. If we make material changes, we will update the "Last Updated" date and may post an on-site notice before changes take effect.

2. Personal Data We Collect

We collect only the data needed to operate the site, process registration requests, and improve the platform. Depending on how you use the site, we may collect the categories below.

  • Identity & contact data: full name and email address that you provide in our registration form.
  • Registration credentials: password you create during registration. Passwords should be unique and strong. We do not ask for payment card details or government IDs through our forms.
  • Form content: any messages or details you choose to include in form submissions or email communications.
  • Technical data: IP address, browser type, device/OS, language settings, and approximate location derived from IP for security and fraud prevention.
  • Usage data: pages viewed, time spent on pages, referrer information, and click paths to understand how the site is used.
  • Cookies & identifiers: cookie identifiers and similar technologies described in Section 4 and our Cookie Policy.
  • Conversion events: signals that a user completed a key action (for example, submitting a registration form), used for measurement and site improvement.

We do not intentionally collect special-category personal data (such as health information, religious beliefs, or political opinions). We also do not request financial account details. Please avoid including sensitive information in free-text fields or emails.

3. Why We Process Personal Data & Legal Basis (GDPR Art. 6)

We process personal data for clear, limited purposes. Where the GDPR or UK GDPR applies, our legal bases include:

  • Registration and contact requests: to receive and respond to your request, create a registration record, and provide next steps. Legal basis: Art. 6(1)(b) (performance of a contract or steps prior to entering a contract) and, where required, Art. 6(1)(a) (consent).
  • Site security and fraud prevention: to protect the site, prevent abuse, and maintain service reliability (for example, investigating suspicious traffic). Legal basis: Art. 6(1)(f) (legitimate interests).
  • Analytics: to understand aggregate site usage and improve content and performance. Legal basis: Art. 6(1)(a) (consent), where consent is required for analytics cookies.
  • Marketing/remarketing: to measure ad performance, attribute conversions, and show relevant offers where you opt in. Legal basis: Art. 6(1)(a) (consent).
  • Legal obligations: to comply with applicable laws and respond to lawful requests. Legal basis: Art. 6(1)(c) (legal obligation).

Automated Decision-Making (GDPR Art. 22): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.

4. Cookies & Tracking

We use cookies and similar technologies to operate the website and, where you consent, to understand usage and measure advertising performance. Cookies are small text files stored on your device. Some cookies are first-party (set by us) and others are third-party (set by service providers).

Cookie categories used on this site:

Essential (always active)

These cookies are required for the site to function. They include session continuity and storing your cookie preferences, and may include basic security or CSRF protections. Retention ranges from session duration to up to 12 months, depending on the cookie.

Analytics (consent)

If you enable analytics cookies, we may use Google Analytics 4 (GA4) to understand aggregate usage and improve the site. Where configured, IP addresses are anonymized. Typical analytics cookies include _ga and _ga_XXXXXXXXXX. Analytics retention is typically 14 months for reporting data.

Marketing (consent)

If you enable marketing cookies, we may use marketing identifiers to measure ad performance and build remarketing audiences. Typical cookies include _gcl_au (Google Ads), _fbp and _fbc (Meta). These are used for conversion attribution, remarketing, and audience measurement.

Beyond cookies, tracking can also include pixel tags (such as a Google tag or Meta Pixel) and server-side measurement (such as Meta Conversion API or server-side tag management). If we implement such tools, they will operate only in accordance with the consent choices you make through our cookie banner or preferences panel.

For more detail, see our Cookie Policy.

5. Consent (EEA/UK)

Users in the EEA and UK receive a consent notice under GDPR/UK GDPR. Analytics and marketing cookies activate only after explicit, informed, freely given consent (Art. 6(1)(a)). Your consent choice is recorded in the cookie_consent browser cookie, typically for 12 months.

You can withdraw consent at any time by selecting "Manage cookie preferences" in the footer or by clearing cookies in your browser. Withdrawal does not affect the lawfulness of processing that occurred before you withdrew consent.

6. Sharing With Advertising & Service Partners

We use service providers to run and improve the website. Depending on your cookie preferences and how you interact with the site, we may share certain data with the categories of partners below.

We do not sell personal data. Where we use advertising and analytics providers, we configure and limit processing to what is necessary for measurement, security, and providing relevant communications. These providers may process data on our behalf under contractual terms.

7. International Transfers

Some of our service providers may process data outside the UK/EEA, including in the United States. When we transfer personal data internationally, we use appropriate safeguards such as the EU-US Data Privacy Framework (and the UK Extension, where applicable), the Swiss-US Data Privacy Framework (where applicable), and Standard Contractual Clauses (EU 2021/914) as a fallback. For UK transfers, we may also rely on the UK International Data Transfer Agreement (IDTA) as a fallback mechanism.

8. Data Retention

We retain personal data only as long as needed for the purposes described in this policy, unless a longer retention period is required by law.

  • Registration and contact submissions: typically up to 2 years from the last interaction, so we can support follow-up and manage training requests.
  • Analytics reporting: typically 14 months (where enabled and configured).
  • Marketing cookies: retained according to the cookie lifespan (for example, 90 days for some marketing identifiers), unless you withdraw consent sooner.
  • Email correspondence: retained for the duration of our relationship plus up to 1 year for continuity and auditing.
  • Security logs: typically up to 90 days, unless needed longer to investigate abuse or maintain the integrity of the service.
  • Cookie consent record: up to 3 years for audit purposes, where required.
  • Legal compliance: retained as required by law (for example, records related to invoices where applicable can be 6 to 10 years depending on jurisdiction).

9. Your Rights (GDPR & UK GDPR)

If you are in the UK or EEA, you have rights under GDPR/UK GDPR, including: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21), and the right to withdraw consent at any time (Art. 7(3)).

To exercise your rights, email [email protected]. We aim to respond within 30 days. For complex requests, we may extend this by up to 60 additional days where permitted.

You also have the right to lodge a complaint with a supervisory authority. Helpful references:

10. Children

This site is not directed at individuals under 16. We do not knowingly collect personal data from children. If we learn we have collected personal data from a child under 16 without verifiable parental consent, we will delete it promptly.

11. Do Not Track

This website does not respond to Do Not Track (DNT) browser signals. Third-party providers may offer their own DNT-related settings or opt-out mechanisms.

12. Data Deletion Requests

To request deletion of your personal data, email us at [email protected] with the subject line "Data Deletion Request". We may ask for information to verify your identity before completing the request. Where we must retain limited data for legal compliance or security reasons, we will restrict processing to those required purposes only.

13. Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, personal data may be transferred to a successor entity. If the transfer materially changes how your personal data is used, we will provide notice through the website.

14. California (CCPA/CPRA)

This section applies to California residents to the extent the California Consumer Privacy Act (as amended by the CPRA) applies. In the past 12 months, we may have collected the following categories of personal information: identifiers (such as name, email, and online identifiers), internet or network activity information (such as browsing interactions), and inferences (such as preferences based on site usage).

We do not sell personal information as defined by the CCPA. We may share personal information for cross-context behavioral advertising depending on your cookie preferences; California residents may opt out via our cookie preferences panel (available through the footer link).

California residents have rights to know, delete, correct, opt out of sale/sharing, and not be discriminated against for exercising privacy rights. To submit a request, email [email protected] with the subject "California Privacy Request". We will take steps to verify your identity as required.

15. Virginia (VCDPA)

Where applicable, Virginia residents may have rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising. We do not sell personal data and we do not engage in profiling that produces legal or similarly significant effects.

To submit a request, email [email protected] with the subject "Virginia Privacy Request". If we deny a request, you may appeal by emailing with the subject "Appeal of Refusal — Privacy Request". We will respond to appeals within 60 days. If an appeal is denied, you may contact the Virginia Attorney General.

16. Nevada

Nevada residents may submit a verified opt-out request by emailing [email protected] with the subject "Nevada Do Not Sell Request". We do not currently sell personal information under Nevada Revised Statutes Chapter 603A.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, our services, or how we process data. Material changes will be announced via a site notice when appropriate, and we will update the "Last Updated" date at the top of this page.

18. Contact

If you have questions about this policy, your data, or your privacy rights, contact:

MOBILE ELEMENTS (ACCESSORIES) Ltd
139 Front Street
Chester-le-Street, DH3 3AU, England
Email: [email protected]