1. Introduction

Learner Key Ltd (Company Reg. SC 339387, registered at 23 Scotland Street, Glasgow G5 8NB, www.learnerkey.com) is deeply committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you interact with us, including when you visit our website, enquire about our courses, or become a learner. We adhere strictly to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Who We Are (Data Controller)

Learner Key Ltd acts as the Data Controller responsible for your personal data. For any privacy-related questions or concerns, please contact our Data Protection team at support@learnerkey.com.

3. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:

• Identity Data: Full name, date of birth, nationality.
• Contact Data: Email address, phone number, postal address, country of residence.
• Academic & Professional Data: Highest qualification achieved, relevant work experience, English and Mathematics proficiency.
• Course & Application Data: Course(s) of interest, intended start date, visa assistance requirements, accommodation assistance requirements, how you heard about us.
• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Information about how you use our website, products, and services.
• Marketing & Communications Data: Your preferences in receiving marketing from us and your communication preferences.

4. How We Collect Your Data

We use different methods to collect data from and about you, including:

• Direct Interactions: You may provide your Identity, Contact, Academic & Professional, and Course & Application Data by filling in forms on our website (e.g., “Apply Now” form), corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  • Apply for our courses.
  • Enquire about our courses or services.
  • Request marketing or information to be sent to you.
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for more details.

5. How We Use Your Data (Purposes and Lawful Basis)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Purpose for which we use your data	Type of Data Involved	Lawful Basis for Processing
To process your application and manage enrolment	Identity, Contact, Academic & Professional, Course & Application	Performance of a contract with you, Legitimate Interests (to run our business)
To provide educational services and support	All data types relevant to your course	Performance of a contract with you, Legitimate Interests (to deliver education)
To manage our relationship with you	Identity, Contact, Profile, Marketing & Communications	Performance of a contract with you, Legitimate Interests (to keep records updated)
To comply with legal/regulatory obligations	Identity, Contact, Course & Application	Legal Obligation
To improve our website, products, and services	Technical, Usage	Legitimate Interests (to understand how our services are used)
To send relevant marketing communications (with consent)	Contact, Marketing & Communications	Consent

6. Data Sharing

We may share your personal data with the following parties for the purposes set out in Section 5:

• Awarding Bodies: Such as Highfield Qualifications and Qualifi, for registration, certification, and quality assurance purposes.
• Partner Centres: If a course is delivered in partnership, for the purposes of course delivery and administration.
• Third-Party Service Providers: Who provide services like IT support, website hosting, payment processing, or marketing assistance, acting as processors under our instruction.
• Universities: For progression purposes, as detailed in our course-specific information.
• Professional Advisers: Including lawyers, bankers, auditors, and insurers, who provide professional services.
• Regulatory & Legal Authorities: When we are legally required to do so.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent at any time where we are relying on consent to process your personal data.

To exercise any of these rights, please contact us at support@learnerkey.com. You will not have to pay a fee to exercise any of your rights.

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

11. Changes to this Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on 17^th June 2025