Data Protection

INTRODUCTION iscommitted to providing a superior learning experience for everyone we workwith. We know that our users are committed to their success and we are equallycommitted to ensuring that each interaction that someone has with our contentis optimized for maximum educational potential. To enable us to do this, needs to gather and use certain information about individuals.Individuals who wegather information about includes customers, affiliates, business contacts,employees, and other people the organization has a relationship with or mayneed to contact.This policy describeshow this personal data is collected, handled, and stored to meet the company’sdata protection standards — and to comply with the law.


This data protectionpolicy ensures

  • Complies with data protection law and followsindustry best practices
  • Protects the rights of staff, customers,affiliates, and partners
  • Is open about how it stores and processesindividuals’ data
  • Protects itself from the risks of a data breach


The GDPR(General Data Protection Regulation) protection law describes how organizationswho conduct business with individuals or entities located in EU (European Union)nations — including — must collect, handle, and store personalinformation.

These rules applyregardless of whether data is stored electronically, on paper, or in any othermanner.

Tocomply with the law, personal information must be collected and used fairly,stored safely, and not disclosed unlawfully.

The EU GDPR isunderpinned by eight core principles. These state that personal data must:

  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant, and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of datasubjects
  • Be protected in appropriate ways
  • Not be transferred outside the EuropeanEconomic Area (EEA), unless that country or territory also ensures an adequatelevel of protection
  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant, and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of datasubjects
  • Be protected in appropriate ways
  • Not be transferred outside the EuropeanEconomic Area (EEA), unless that country or territory also ensures an adequatelevel of protection
  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant, and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of datasubjects
  • Be protected in appropriate ways
  • Not be transferred outside the EuropeanEconomic Area (EEA), unless that country or territory also ensures an adequatelevel of protection
  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant, and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of datasubjects
  • Be protected in appropriate ways
  • Not be transferred outside the EuropeanEconomic Area (EEA), unless that country or territory also ensures an adequatelevel of protection


Every day our businesswill receive, use, and store personal information about our customers, affiliates,partners, and colleagues. It is important that this information is handledlawfully and appropriately, in line with the requirements of the DataProtection Act 2018 and the General Data Protection Regulation (collectivelyreferred to as the ‘Data Protection Requirements’).

We take our dataprotection duties seriously because we respect the trust that is being placedin us to use personal information appropriately and responsibly.


This policy and anyother documents referred to in it, sets out the basis on which we will processany personal data that we collect or process. This policy does not form part ofany employee’s contract of employment and may be amended at any time.

The company as a wholeis responsible for ensuring compliance with the Data Protection Requirementsand with this policy. Any questions about the operation of this policy or anyconcerns that the policy has not been followed should be referred in the firstinstance to the Data Protection Officer.


Personal data isdefined as data, (whether stored electronically or paper based) relating to aliving individual who can be identified directly or indirectly from that data,(or from that data and other information in our possession).

Processing is anyactivity that involves use of personal data. It includes obtaining, recording,or holding the data, organizing, amending, retrieving, using, disclosing,erasing, or destroying it. Processing also includes transferring personal datato third parties under privacy control conditions.

Sensitive personal dataincludes contact info, address, session activity on the platform, IP locationetc. Sensitive personal data can only be processed under strict conditions, andused for express purpose that it was collected for.


Anyoneprocessing personal data, must ensure that data is:

A. Processed fairly,lawfully and in a transparent manner.

  • Collected for specified, explicit, andlegitimate purposes and any further processing is completed for a compatiblepurpose.
  • Adequate, relevant and limited to what isnecessary for the intended purposes.
  • Accurate and where necessary, kept up to date.
  • Kept in a form which permits identification forno longer than necessary for the intended purposes.
  • Not be held for any longer than necessary
  • Processed in line with the individual’s rightsand in a manner that ensures appropriate security of the personal data,including protection against unauthorized or unlawful processing and againstaccidental loss, destruction, or damage, using appropriate technical ororganizational measures.
  • Not transferred to people or organizationssituated in countries without adequate protection and without firstly havingadvised the individual.


The DataProtection Requirements are not intended to prevent the processing of personaldata, but to ensure that it is done fairly and without adversely affecting therights of the individual.

In accordance with theGeneral Data Protection Regulation (GDPR), we will only process personal datawhere it is required for a lawful purpose. The lawful purposes include (amongstothers): whether the individual has given their consent, the processing is necessaryfor performing a contract with the individual, for compliance with a legalobligation, or for the legitimate interest of the business. When sensitivepersonal data is being processed, additional conditions must be met.

A. Collection of Information

We receive and storeinformation about you such as:

Information you provide us: We collectinformation you provide to us which includes: your name, email address, addressor postal code, payment method, and telephone number. We collect thisinformation in a number of ways, including manual entry while you are using ourservice, interact with our customer service, participate in surveys ormarketing promotions, provide reviews or ratings, taste preferences, setpreferences in Your Profile/Account, or otherwise provide information to usthrough our service or elsewhere.

Information wecollect automatically: We collect information regarding you and youruse of our service, your interactions with us and our advertising, as well asinformation regarding your computer or other device used to access our service.

This informationincludes:

  • Your activity on our platform such as courseprogress and search queries
  • Details regarding your interactions withcustomer service such as the date, time and reason for contacting us
  • Transcripts of any chat conversations that youinitiate on our platforms
  • In the event that you initiate phone support,your phone number
  • Device IDs or unique identifiers, device andsoftware characteristics (such as type and configuration)
  • Connection information, statistics on pageviews, referral URLs, IP address, and standard web log information
  • Information collected via the use of cookies,web beacons and other technologies, including ad data (such as information onimpressions delivered to a cookie, the site URL where the impression wasdelivered, as well as the date and time).

See our Privacy Policy for more details.

B. Use of Information

We use the informationwe collect to provide, analyze, administer, enhance, and personalize ourservices and marketing efforts, to process your registration, your orders, yourpayments, and your communication on these and other topics.

Our primary aim isalways to enhance the user experience. We do so in several ways using the datathat we collect, but a few examples are: determining your general platformusage, required action item completions, login details, etc. which then helpsus know what difficulties the you’re facing within the platform, with which canthen use to take action to minimize the effort on your end. We collect otherinformation, such as most visited links on our website, which then help usconclude what content was most watched, enabling us to create additionalcontent geared toward our users’ needs and personal preferences.


In the course of ourbusiness, we may collect and process personal data, which may include data thatwe receive directly from a data subject and data we receive from other sourcesincluding location data, business partners, and subcontractors who worktechnical, payment and delivery services, credit reference agencies, and othercapacities.

We will only processpersonal data for the specific purposes or for any other purposes specificallypermitted by the Data Protection Requirements. We will notify those purposes tothe data subject when we first collect the data or as soon as possiblethereafter.


If we collect personaldata directly from an individual, we will inform them about:

  • The purpose or purposes for which we intend toprocess that personal data, as well as the legal basis for the processing.
  • Where we rely upon the legitimate interests ofthe business to process personal data, the legitimate interests pursued.
  • The types of third parties, if any, with whichwe will share or disclose that personal data.
  • The fact that the business intends to transferpersonal data to a non-EEA country or international organization and theappropriate and suitable safeguards in place.
  • How individuals can limit our use anddisclosure of their personal data.
  • Information about the period that theirinformation will be stored or the criteria used to determine that period.
  • Their right to request from us as thecontroller access to and rectification or erasure of personal data orrestriction of processing.
  • Their right to object to processing and theirright to data portability.
  • Their right to withdraw their consent at anytime (if consent was given) without affecting the lawfulness of the processingbefore the consent was withdrawn.
  • The right to lodge a complaint with theInformation Commissioner's Office.
  • Other sources where personal data regarding theindividual originated from and whether it came from publicly accessiblesources.
  • Whether the provision of the personal data is astatutory or contractual requirement, or a requirement necessary to enter intoa contract, as well as whether the individual is obliged to provide thepersonal data and any consequences of failure to provide the data.
  • The existence of automated decision-making,including profiling and meaningful information about the logic involved, aswell as the significance and the envisaged consequences of such processing forthe individual.

If we receive personaldata about an individual from other sources, we will provide them with thisinformation as soon as possible (in addition to telling them about the categoriesof personal data concerned) but at the latest within One (1) month.

We will also informdata subjects whose personal data we process, that we are the data controllerwith regard to that data and our contact detail regarding data protection actis email protected, and who the Data Protection Compliance Manager/DataProtection Office is.


We will only collectpersonal data to the extent that it is required for the specific purposenotified to the data subject.


We will ensure thatpersonal data we hold is accurate and kept up to date. We will check theaccuracy of any personal data at the point of collection and at regularintervals afterwards. We will take all reasonable steps to destroy or amendinaccurate or out-of-date data.


We will not keeppersonal data longer than necessary for the purpose or purposes for which itwas collected. We will take all reasonable steps to destroy or erase from oursystems, all data which is no longer required.


We will process allpersonal data in line with data subjects’ rights, in particular their right to:

  • Confirmation as to whether or not personal dataconcerning the individual is being processed.
  • Request access to any data held about them by adata controller.
  • Request rectification, erasure or restrictionon processing of their personal data.
  • Lodge a complaint with a supervisory authority.
  • Data portability.
  • Object to processing including for directmarketing.
  • Not be subject to automated decision makingincluding profiling in certain circumstances.


We will takeappropriate security measures against unlawful or unauthorized processing ofpersonal data and against the accidental or unlawful destruction, damage, loss,alteration, or unauthorized disclosure of or access to personal datatransmitted, stored, or otherwise processed.

We will put in placeprocedures and technologies to maintain the security of all personal data fromthe point of the determination of the means for processing and point of datacollection to the point of destruction. Personal data will only be transferredto a data processor if he or she agrees to comply with those procedures andpolicies, or if he or she puts in place adequate measures himself/herself.

We will maintain datasecurity by protecting the confidentiality, integrity, and availability of thepersonal data, defined as follows:

  • Confidentiality: Only people who are authorizedto use the data can access it.
  • Integrity: Personal data should be accurate andsuitable for the purpose for which it is processed.
  • Availability: Authorized users should be ableto access the data if they need it for authorized purposes. Personal datashould therefore be stored on the central computer system& databases instead of individual PCs.


  • Entry controls: Any stranger seen inentry-controlled areas will be reported.
  • Securing lockable desks and cupboards all thetime. Desks and cupboards should be kept locked if they hold confidentialinformation of any kind. (Personal information is always consideredconfidential.)
  • Data minimization will be practiced.
  • Pseudonymisation and encryption of data will bethe primary state of storing the data.
  • Methods of disposal: Paper documents would beshredded. Digital storage devices would be physically destroyed when they areno longer required. Electronic data would be deleted once it’s intended purposeis fulfilled.
  • Equipment: Staff has to ensure that individualmonitors do not show confidential information to passers-by and that they logoff from their PC when it is left unattended.
  • Transferring Personal Data Outside of the EEA:We may transfer any personal data we hold to a country outside the EuropeanEconomic Area (‘EEA’) or to an international organization, provided that one ofthe following conditions applies:
    ○ The country to which the personal data istransferred ensures an adequate level of protection for the data subjects’rights and freedoms.
    ○ The data subject has given his consent.
    ○The transfer is necessary for one of thereasons set out in the Act, including the performance of a contract between usand the data subject, or to protect the vital interests of the data subject.
    ○ The transfer is legally required on importantpublic interest grounds or for the establishment, exercise or defense of legalclaims.
    ○ The transfer is authorized by the relevant dataprotection authority where we have adduced adequate safeguards with respect tothe protection of the data subjects’ privacy, their fundamental rights andfreedoms, and the exercise of their rights.

Subject to therequirements above, personal data we hold may also be processed by staffoperating outside the EEA who work for us or for one of our suppliers. Thosestaff may be engaged in, among other things, the fulfilment of contracts withthe data subject, the processing of payment details and the provision ofsupport services.


We may share personaldata we hold with any member of our group, which means our subsidiaries, ourultimate holding company and its subsidiaries.


To these ends, thecompany has a privacy statement setting out how data relating to individuals isused by the company.

Individuals must make aformal request for information we hold about them. Employees who receive arequest should forward it to the data department immediately.

When receivingtelephone inquiries, we will only disclose personal data we hold on our systemsif the following conditions are met:

  • We will check the caller’s identity to makesure that information is only given to a person who is entitled to it.
  • We will suggest that the caller put theirrequest in writing if we are not sure about the caller’s identity and wheretheir identity cannot be checked.
  • Where a request is made electronically, datawill be provided electronically when possible.

Our support team willrefer a request to the data processing department or the Data ProtectionCompliance Manager for assistance in difficult situations.


We may modify thisPrivacy Statement at any time, but we will provide prominent advance notice ofany material changes to this Statement, such as posting a notice through theServices, on our websites, or sending you an email, to provide you theopportunity to review the changes and choose whether to continue using theServices.