LIVE STUDY PLAY LTD
Version 1.0
Last updated: 16 July 2025
Effective date: 17 July 2025
This Privacy Policy describes how LIVE STUDY PLAY LTD (trading as CodexNova) collects, uses, stores and safeguards your personal data when you visit https://codexnova.uk (the “Site”) or use any of our services (collectively, the “Services”).
1. Who We Are
Data Controller: LIVE STUDY PLAY LTD (Company No. 15280324)
Registered office: Dept 4558a, 126 East Ferry Road, Canary Wharf, London E14 9FP, United Kingdom
Email: info@codexnova.uk
We are subject to the UK General Data Protection Regulation (“UK GDPR”) and, for customers in the European Economic Area, the EU GDPR.
2. The Data We Collect
| Category | Examples | Source |
| Account Data | Name, email address, username, password hash | You |
| Billing Data | Billing address, VAT ID, country, currency | You |
| Payment Tokens | Card BIN/last-4 & tokenised PAN via PSP, SEPA mandate ID, crypto wallet address (USDC/ETH) | Payment gateway |
| KYC Data | Government ID, selfie, proof-of-address, sanctions / PEP screening results | You / KYC provider |
| Usage Data | IP address, device type, browser agent, pages viewed, download history | Matomo Analytics (self-hosted) |
| Marketing Data | Newsletter opt-in status, email engagement metrics (open/click), social-media campaign identifiers | You / ESP |
| Support Data | Emails, contact-form submissions, error logs, screenshots | You |
We do not knowingly collect data from children under 18.
3. Why We Process Your Data & Lawful Bases
| Purpose | Lawful Basis (UK/EU GDPR Art. 6) |
| Create & manage your Account; deliver Digital Assets | Contract (Art. 6 (1)(b)) |
| Process payments & issue invoices | Contract; Legal obligation (tax) |
| Conduct KYC/AML & fraud screening | Legal obligation; Legitimate interests (risk management) |
| Provide customer support | Contract; Legitimate interests |
| Send transactional emails (order confirmations, updates) | Contract |
| Marketing newsletters & personalised offers | Consent (can withdraw anytime) |
| On-site analytics & performance optimisation | Legitimate interests (service improvement), deployed after cookie consent |
| Compliance with legal requests, court orders | Legal obligation |
We do not perform behavioural advertising unless you have given opt-in consent through the cookie banner.
4. Cookies & Similar Technologies
The Site uses strictly necessary cookies (session, CSRF token) and optional analytics/marketing cookies. Please refer to our separate [Cookie Policy] for details.
5. How We Share Your Data
We share data only with:
- Payment processors & banks (Visa/Mastercard PSP, SEPA bank, crypto gateway) – payment execution;
- KYC/AML service providers – identity verification & sanctions screening ;
- Cloud hosting & email infrastructure (UK / EEA data centres) – platform operations;
- Analytics & marketing – self-hosted Matomo server, Meta pixels (loaded after opt-in) ;
- Professional advisers & auditors – legal, tax, security (ISO 27001 audits) ;
- Public authorities – HMRC, ICO, law-enforcement agencies, if legally required.
We never sell your personal data.
6. International Data Transfers
- UK ↔ EEA: Data moves under the EU–UK adequacy decision.
- Other third countries (e.g., US sub-processors for email delivery): protected by Standard Contractual Clauses and supplementary measures.
- Crypto gateway nodes: transaction hashes are public on the Ethereum blockchain and may be processed outside the UK/EEA.
7. Security Measures
CodexNova employs ISO 27001-aligned controls, quarterly penetration testing, encryption at rest & in transit, and role-based access with MFA for admin users .
8. Data Retention
| Data Type | Retention Period |
| Account & Billing Data | 6 years from last transaction (tax & accounting) |
| KYC Data | 5 years after Account closure (AML regulations) |
| Payment Tokens | Immediately upon authorisation except anonymised tokens stored by PSP for charge-backs (up to 540 days) |
| Marketing Data | Until you unsubscribe or 24 months of inactivity |
| Support Tickets | 3 years from closure |
| Analytics Logs | 14 months (aggregated thereafter) |
9. Automated Decision-Making
We use automated tools to:
- Screen transactions against sanctions & PEP lists;
- Score payments for fraud risk using PSP rules sets.
You may request a human review of any decision that affects you significantly.
10. Your Rights
Subject to conditions, you have rights to:
- Access – obtain a copy of your data;
- Rectification – correct inaccurate or incomplete data;
- Erasure – request deletion (“right to be forgotten”);
- Restriction – limit processing;
- Data Portability – receive data in a structured format;
- Object – to processing based on legitimate interests or direct marketing;
- Withdraw consent – at any time where processing is based on consent.
Exercising your rights
Email info@codexnova.uk with subject “Data Rights Request”. We will respond within one month.
Supervisory Authority
You may lodge a complaint with the UK Information Commissioner’s Office (ICO) or your local EU data-protection authority.
11. Changes to This Policy
We may update this Privacy Policy to reflect legal or operational changes. We will post the updated version with a new “Last updated” date. Material changes will take effect 30 days after posting.
12. Contact Us
If you have questions about privacy or data protection, contact our Data Protection Officer at info@codexnova.uk.
© 2025 LIVE STUDY PLAY LTD. All rights reserved.