Effective date: 14 August 2026

Privacy Policy

Last updated: 14 August 2026

This Privacy Policy explains how HORNE MEDIA LTD collects, uses, stores and protects personal information in connection with the SpendGrade website and Learning Programme.

Data Controller

The data controller is:

Email:
contact@spendgrade.com

Telephone:
+44 (0)263 544 024

SpendGrade is a trading name used by HORNE MEDIA LTD for its online educational programme.

Who This Policy Applies To

This Privacy Policy applies to:

• visitors to the SpendGrade website;
• people who contact HORNE MEDIA LTD by email;
• people who request information about the Learning Programme;
• people who receive an invoice;
• participants who purchase access;
• registered users of the educational platform;
• people who submit refund requests, complaints or data protection requests.

The SpendGrade Learning Programme is currently intended for adults aged 18 or over who reside in the United Kingdom.

Information Collected Through the Website

SpendGrade does not currently provide a contact or access request form on the website.

When you select an email link, your device may open its default email application. You decide whether to send the email and what information to include.

The website does not automatically receive your name, email address or message merely because you select an email link.

Technical information may still be processed when you visit the website, including:

• IP address;
• browser type and version;
• device type;
• operating system;
• requested pages;
• date and time of access;
• referral information;
• website security and error logs.

This information may be processed by the website hosting and security providers.

Information Collected by Email

If you contact HORNE MEDIA LTD by email, we may receive:

• your name;
• your email address;
• the contents of your message;
• the access period you are interested in;
• information required to respond to your enquiry;
• attachments that you voluntarily provide;
• the date and time of correspondence.

Please do not send passwords, payment card information, complete bank account details or unnecessary sensitive personal information by email.

Access Request and Contract Information

If you request or purchase access to the Learning Programme, we may process:

• your name;
• your email address;
• billing information;
• selected access period;
• invoice number;
• invoice date;
• payment amount;
• payment date;
• bank transfer reference;
• confirmation that payment has been received;
• contract and correspondence records;
• start and end dates of access.

HORNE MEDIA LTD does not collect payment card details through the SpendGrade website.

Payments are made by bank transfer using the information stated on the invoice.

Our bank and accounting records may contain information required to identify and reconcile your payment.

Learning Platform Account Information

After payment has been received and confirmed, HORNE MEDIA LTD creates an account using the participant’s email address.

We may process:

• account name;
• email address;
• internal user identifier;
• account creation date;
• access start date;
• access expiry date;
• login and security records;
• module access or completion information;
• technical support correspondence;
• account status.

Account information is used to provide and administer access to the Learning Programme.

Purposes and Lawful Bases

We process personal information for the following purposes.

Responding to enquiries

Purpose:

• responding to questions;
• providing programme information;
• explaining available access periods.

Lawful basis:

• taking steps at your request before entering into a contract;
• our legitimate interest in responding to enquiries concerning our services.

Issuing invoices and confirming payments

Purpose:

• preparing and sending invoices;
• identifying bank transfers;
• maintaining payment records.

Lawful basis:

• taking steps before entering into a contract;
• performing a contract;
• complying with legal, tax and accounting obligations.

Creating and administering accounts

Purpose:

• creating an account;
• providing platform access;
• confirming access dates;
• maintaining account security;
• providing technical support;
• ending access when the purchased period expires.

Lawful basis:

• performing a contract;
• our legitimate interest in protecting and administering the educational platform.

Processing refund requests and complaints

Purpose:

• reviewing refund requests;
• issuing refunds where applicable;
• responding to complaints;
• maintaining relevant records.

Lawful basis:

• performing a contract;
• complying with legal obligations;
• our legitimate interest in resolving complaints and protecting legal rights.

Website security and technical operation

Purpose:

• operating the website;
• preventing misuse;
• detecting security incidents;
• diagnosing technical problems;
• maintaining server and security logs.

Lawful basis:

• our legitimate interest in maintaining a secure and functional website.

Legal and regulatory compliance

Purpose:

• maintaining accounting and tax records;
• responding to lawful requests;
• establishing, exercising or defending legal claims.

Lawful basis:

• compliance with a legal obligation;
• our legitimate interest in protecting legal rights.

Marketing Communications

HORNE MEDIA LTD may respond to an enquiry and send information directly connected with the service you requested.

We will not add you to an unrelated electronic marketing list solely because you requested information or purchased access.

Where consent is required for electronic marketing, we will request it separately.

You may withdraw marketing consent at any time by emailing:

contact@spendgrade.com

Service communications concerning invoices, payments, account access, security, expiry dates, refunds or changes affecting an active service are not marketing communications.

Cookies and Advertising Technologies

The website may use strictly necessary technologies required for security and basic website operation.

At the effective date of this Privacy Policy, Microsoft Advertising Universal Event Tracking is not active on the SpendGrade website.

If HORNE MEDIA LTD introduces Microsoft Advertising UET or another non-essential advertising or analytics technology:

• this Privacy Policy and the Cookie Policy will be updated before activation;
• information about the relevant provider and processing will be provided;
• non-essential technologies will not be activated before the user has made the required consent choice;
• users will be provided with a method of withdrawing or changing consent.

Further information is available in the Cookie Policy.

Information Sharing

HORNE MEDIA LTD may share personal information with service providers where reasonably necessary to operate SpendGrade.

These may include:

• website hosting and security providers;
• business email providers;
• learning platform providers;
• accounting and bookkeeping providers;
• banking and payment service providers;
• IT and technical support providers;
• professional advisers;
• public authorities where disclosure is required by law.

Service providers may process information only for the relevant service and under appropriate contractual or legal obligations.

We do not sell personal information.

International Data Transfers

Some service providers may process personal information outside the United Kingdom.

Where UK data protection law requires safeguards for an international transfer, HORNE MEDIA LTD will use an appropriate transfer mechanism.

This may include:

• a country covered by UK adequacy regulations;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved standard contractual clauses;
• another lawful transfer mechanism.

Further information about applicable safeguards may be requested by emailing:

contact@spendgrade.com

Data Retention

Personal information is retained only for as long as reasonably necessary for the relevant purpose and applicable legal obligations.

Unless a longer period is required, the following general periods apply:

• initial enquiries that do not result in a purchase: up to 12 months after the final correspondence;
• invoices, payment and accounting records: generally 6 years after the end of the relevant financial year;
• contract records: generally 6 years after the end of the contractual relationship;
• active account information: for the duration of access;
• expired account information: up to 12 months after access expires, unless a longer period is required for legal or security purposes;
• refund and complaint records: generally up to 6 years after the matter is closed;
• routine website security logs: normally up to 30 days, unless longer retention is required to investigate a security incident.

Information may be deleted earlier when it is no longer required and no legal reason for retention remains.

Information Security

HORNE MEDIA LTD uses reasonable organisational and technical measures intended to protect personal information against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure;
• destruction.

No internet transmission or electronic storage system can be guaranteed to be completely secure.

Users are responsible for protecting their account information and should not share passwords or login details with another person.

Your Data Protection Rights

Depending on the circumstances, UK data protection law may give you the right to:

• request access to your personal information;
• request correction of inaccurate information;
• request deletion of information;
• request restriction of processing;
• object to processing based on legitimate interests;
• request data portability;
• withdraw consent where processing is based on consent;
• complain to the Information Commissioner’s Office.

Some rights are subject to legal conditions and exceptions.

To exercise a right, email:

contact@spendgrade.com

Use the subject:

Data Protection Request

We may request reasonable information to confirm your identity before responding.

Automated Decision-Making

HORNE MEDIA LTD does not use personal information collected through SpendGrade to make solely automated decisions that produce legal or similarly significant effects.

Children

SpendGrade and the Learning Programme are not intended for people under the age of 18.

We do not knowingly provide Learning Programme access to children.

If you believe that a child has provided personal information, contact:

contact@spendgrade.com

Third-Party Websites

The SpendGrade website may contain links to third-party websites, including public information and support organisations.

HORNE MEDIA LTD does not control the privacy practices of those websites.

Users should review the privacy information provided by the relevant third party.

Complaints to the ICO

If you have concerns about how HORNE MEDIA LTD processes personal information, please contact us first:

contact@spendgrade.com

You also have the right to complain to the Information Commissioner’s Office.

Telephone: 0303 123 1113

Website:
https://ico.org.uk/make-a-complaint/

Changes to This Privacy Policy

HORNE MEDIA LTD may update this Privacy Policy when processing activities, service providers or legal requirements change.

The updated version will be displayed on the SpendGrade website with a revised effective date.

Material changes affecting active participants may also be communicated by email where appropriate.

Contact

For privacy questions or data protection requests:

Email:
contact@spendgrade.com

Telephone:
+44 (0)263 544 024