Privacy Notice for Learner Journey

Website: https://www.learnerjourney.com

Email: info@learnerjourney.com

Company: Ventures Anywhere Limited

Registered Office: 10–12 East Parade, Leeds, LS1 2BH, United Kingdom

Company Registration Number: 10384821

1. Who We Are

Learner Journey is operated by Ventures Anywhere Limited, a company based in the UK. We are committed to protecting your privacy and handling your personal data responsibly.

2. What Personal Data We Collect

We may collect and process the following data:

• Name, email address, and contact details
• School, organisation, or workplace information
• Learning activity, progress data, and assessment outcomes
• Payment and billing information (where applicable)
• Technical data such as IP address, browser type, and device information

3. Why We Collect Your Data

We use your information to:

• Provide and manage access to the platform
• Track learning progress and personalise content
• Communicate with you
• Maintain security and improve platform performance
• Fulfil legal obligations

We do not sell your personal data to third parties.

4. Legal Basis for Processing

We process your data under the following lawful bases:

• Your consent
• The performance of a contract
• Compliance with legal obligations
• Our legitimate interests (e.g. improving services)

5. Sharing Your Data

We may share data with third-party service providers (such as cloud hosting, analytics, and payment gateways) under strict confidentiality and data processing agreements. We will also share data if legally required to do so.

5a. Artificial Intelligence

Some features are powered by AI models. When you use them, the text, documents or images you provide, and relevant context such as your learning progress, are sent to the model provider to generate a response. Our default provider is Google Cloud (Vertex AI, Gemini models); if a workspace enables it, image generation may also use OpenAI. These providers process the data to provide the service and do not use it to train their models under our agreements with them.

We keep a record of each AI request (which feature, when, who, how long the input and output were, whether it was refused, and the cost) for 90 days for safety, abuse prevention and billing. The content of your requests is not kept in that record, except that the text of a CV analysed for a job application is kept for 30 days so that a decision can be checked if a candidate disputes it. Conversations with the AI tutor, coaches and live chat are stored with the workspace they belong to and are visible to that workspace’s administrators. The AI tutor may keep a learner model (what you have found easy or hard, your study preferences); you can view, edit, delete or opt out of this from the tutor.

We do not make solely automated decisions with legal or similarly significant effects about you. AI summaries of job applications are reviewed by a person before any decision is made.

6. Data Retention

We retain personal data only as long as necessary for the purposes it was collected, or as required by law.

7. International Data Transfers

If your data is transferred outside the UK, we will ensure adequate protection, such as approved standard contractual clauses or adequacy decisions.

8. Your Rights

Under UK GDPR, you have the right to:

• Access your data
• Request correction or deletion
• Object to or restrict processing
• Withdraw your consent at any time
• Lodge a complaint with the Information Commissioner’s Office (ICO)

To make a data rights request, email info@learnerjourney.com.

9. Cookies and Tracking

We use cookies to improve the site experience and collect anonymous usage statistics. You can manage your cookie preferences through your browser or our cookie settings panel.

10. Contact Us

For any data protection or privacy-related queries:

Email: info@learnerjourney.com

Address: Ventures Anywhere Limited, 10–12 East Parade, Leeds, LS1 2BH

For formal complaints, contact the Information Commissioner’s Office at https://ico.org.uk