Swift Learn | Privacy Policy

In plain English:We collect only what we need to run our learning platform and services. We don't sell your data. You can ask us to delete it at any time. This policy explains exactly what we collect, why, and who sees it.

1. Introduction

Welcome to Swift Learn's privacy policy. Swift Learn is a brand of Brainy Cheeks Ltd, a company providing online learning solutions for organisations. We respect your privacy and are committed to protecting your personal information.

For UK GDPR purposes, Swift Learn (referred to as “Swift Learn”, “we”, “our”, or “us”) is the controller of the personal data you provide to us.

2. Contact Information

Legal entity	Brainy Cheeks Ltd
Data protection contact	Data Protection Contact
Email	support@swiftlearn.co.uk

If you have any questions about this policy or wish to exercise your data protection rights, please contact us using the details above.

3. Data We Collect

3.1 Information You Provide to Us

Name and contact information (email, phone number)
Company name, job title, and role
Account credentials (username, encrypted password)
Communication preferences
Payment and billing information
Course enrolment and learning data
Support enquiries and correspondence

3.2 Information We Collect Automatically

Device type, operating system, and browser information
IP address and approximate location
Pages visited, time spent, and interaction patterns on our platform
Referral source (how you found us)
Course progress and completion data

3.3 Information from Third Parties

We may receive information about you from third parties, including:

Payment confirmation from our payment processor (Stripe)
Analytics data from Google Analytics
Publicly available business contact information where we have a legitimate reason to contact you about our services

4. Lawful Basis for Processing

Under Article 6(1) of the UK GDPR, we process your personal data on the following bases:

Purpose	Lawful Basis	Detail
Providing our services and managing your account	Contractual necessity (Art 6(1)(b))	Processing is necessary to perform our contract with you
Processing payments	Contractual necessity (Art 6(1)(b))	Required to fulfil our obligations under your service agreement
Sending service communications	Contractual necessity (Art 6(1)(b))	Necessary to keep you informed about services you use
Website analytics and platform improvement	Legitimate interest (Art 6(1)(f))	We anonymise data where possible and you can opt out via cookie preferences
Marketing communications	Consent (Art 6(1)(a))	We only send marketing emails where you have given clear consent. You can withdraw consent at any time
Fraud prevention and platform security	Legitimate interest (Art 6(1)(f))	We have a legitimate interest in protecting our platform and users
Compliance with legal obligations	Legal obligation (Art 6(1)(c))	Required by law
Course progress tracking and certification	Contractual necessity (Art 6(1)(b))	Necessary to deliver the learning services you or your employer have engaged us to provide

5. Third-Party Service Providers

We share your personal data with the following categories of third-party processors, who process data on our behalf and under our instructions:

Category	Provider(s)	Purpose	Data Shared
Payment processing	Stripe	Processing card payments securely	Name, email, payment card details (we do not store full card numbers)
Analytics	Google Analytics	Understanding platform usage and improving our services	Anonymised usage data, IP address (anonymised), device/browser info
Cloud hosting	Infrastructure provider	Hosting our platform and storing data securely	All platform data (encrypted at rest and in transit)
Email services	Email service provider	Sending transactional and marketing emails	Name, email address
Learning management	Moodle (self-hosted)	Delivering courses via swift1.co.uk	Account details, course progress, learning data

We do not sell your personal data to any third party.

All third-party processors are bound by data processing agreements that require them to process your data only on our instructions and to maintain appropriate security measures.

6. International Data Transfers

We store your data in secure data centres located within the United Kingdom and the European Economic Area (EEA).

Where we transfer data outside the UK or EEA, we ensure appropriate safeguards are in place, including:

UK International Data Transfer Agreements (UK IDTAs) or EU Standard Contractual Clauses (SCCs) with UK Addendum
Verifying that recipients are in countries recognised by the UK Government as providing adequate data protection
Implementing appropriate technical and organisational security measures

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

Data Type	Retention Period	Reason
Account and profile data	Duration of your account plus 2 years	To allow account reactivation and handle post-contract queries
Course completion and certification records	6 years after completion	Professional certification requirements and contractual obligations
Payment and billing records	6 years after transaction	HMRC tax record-keeping requirements (legal obligation)
Marketing consent records	Duration of consent plus 2 years	To demonstrate consent was obtained (accountability)
Support correspondence	3 years after resolution	To identify recurring issues and improve service
Website analytics data	26 months (anonymised)	Platform improvement

After the applicable retention period, data is securely deleted or irreversibly anonymised.

8. Cookies

Our website uses cookies and similar technologies. For full details of the cookies we use, why we use them, and how to manage your preferences, please see our Cookie Policy.

We do not set non-essential cookies (analytics or personalisation) until you have given your consent via our cookie preference tool.

9. Your Rights

Under UK data protection law, you have the following rights:

Right	What It Means
Access	Obtain a copy of the personal data we hold about you
Rectification	Ask us to correct inaccurate or incomplete data
Erasure	Ask us to delete your personal data (subject to legal retention requirements)
Restriction	Ask us to limit how we process your data
Data portability	Receive your data in a structured, commonly used, machine-readable format
Object	Object to processing based on legitimate interest or for direct marketing
Withdraw consent	Where processing is based on consent, withdraw it at any time

To exercise any of these rights, please email our Data Protection Contact at support@swiftlearn.co.uk. We will respond within one calendar month of receiving your request, as required by law.

There is no fee for exercising your rights, unless your request is manifestly unfounded or excessive.

10. Children's Data

Our services are designed for organisations and professionals. We do not knowingly collect personal data from children under 13. If you believe we have inadvertently collected such data, please contact us immediately and we will delete it.

11. Changes to This Policy

We may update this policy from time to time. Where changes are material, we will notify you by email or by placing a prominent notice on our website. We encourage you to review this policy periodically.

12. Complaints

If you are unhappy with how we have handled your personal data, please contact us first so we can try to resolve the issue.

If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: https://ico.org.uk/make-a-complaint
Telephone: 0303 123 1113