Privacy Policy

Last updated: 26 October 2026

1. Who We Are

Projukti Team is a trading name of PROJUKTI TEAM LIMITED, registered in England and Wales under company number 15759825.

Our registered office is:

Unit 8, First Floor, 17–18 Vine Court, London, England, E1 1JH.

PROJUKTI TEAM LIMITED is the data controller for the personal information we collect and use for the purposes described in this Privacy Policy. This means we determine why and how that information is used.

For privacy enquiries, requests or complaints, contact:

Email: [email protected]

Telephone: +44 20 8191 2679

Post: Privacy Enquiries, PROJUKTI TEAM LIMITED, Unit 8, First Floor, 17–18 Vine Court, London, England, E1 1JH.

2. What This Policy Covers

This Privacy Policy explains how we handle personal information when you:

• Visit our websites or landing pages.
• Register for an account or use our mobile applications.
• Purchase or access courses, digital downloads, practice tests or other learning services.
• Contact us through email, telephone, WhatsApp, social media or other support channels.
• Participate in learning communities, surveys, promotions or referral programmes.
• Use AI-assisted learning or customer-support features, where available.

We handle personal information under applicable data protection law, including the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations, as amended, including by the Data (Use and Access) Act 2025.

Other data protection laws may apply where our activities fall within their scope.

This Policy explains our practices; it is not a request for blanket consent. Visiting our website, purchasing a course or accepting our Terms and Conditions does not automatically mean that you consent to optional tracking, marketing or unrelated uses of your information.

3. Personal Information We Collect

The information we collect depends on the services you use and your interactions with us.

Account and Contact Information

This may include your name, email address, telephone number, account identifier, login credentials in their secured form, language preference and account settings.

We may collect billing or postal address information where needed for a transaction or another stated purpose.

Purchase and Transaction Information

This may include purchased products, order references, transaction dates, amounts, currency, payment status, payment-provider references, subscription status and refund or payment-dispute records.

Payment providers and app stores also process information under their own applicable privacy notices. Please do not send full payment-card details, passwords or banking credentials through our support channels.

Learning and Course Information

This may include enrolments, lessons accessed, course progress, practice-test responses, scores, completion records, certificates and learning preferences.

If you submit an examination result for support, feedback or a guarantee claim, we may process the information needed to handle that request. Please remove unrelated information from supporting documents.

Communications and Contributions

This may include messages, enquiries, support tickets, survey responses, assignments, reviews, feedback and information you choose to share in a learning community.

Where recording or transcription is used, the additional arrangements in Section 8 apply.

Technical and Usage Information

This may include:

• IP address and approximate location derived from it.
• Browser, operating system, device type and app version.
• Account, device, session and advertising identifiers, where applicable.
• Pages or screens viewed, features used and interaction events.
• Referral sources, campaign identifiers and interactions with advertisements.
• Error reports, diagnostic information and security logs.
• Cookie, consent and communication-preference records.

IP addresses, device identifiers and similar technical information may be personal information. We do not treat information as anonymous simply because it does not include your name.

AI Interactions

Where you use an AI-assisted feature, we may process your question, submitted text or audio, relevant conversation history and information needed to provide a response.

The information required depends on the feature. Please avoid submitting unnecessary sensitive information or another person’s private information.

Affiliate and Referral Information

If you participate in a referral or affiliate programme, we may process referral identifiers, attributed transactions, commission records and information needed to administer payments and meet applicable legal obligations.

4. How We Obtain Information

We obtain personal information:

• Directly from you, when you register, purchase, complete forms, submit content or contact us.
• From your use of our services, including account activity and technical information, subject to applicable tracking choices.
• From payment providers and app stores, such as transaction confirmations and purchase-entitlement information.
• From communication and support platforms, when you contact us through those services.
• From referral and advertising partners, where permitted, such as referral attribution or campaign-interaction information.
• From someone acting on your behalf, such as an authorised parent, guardian or purchaser.

Where we obtain personal information from another source, we provide any additional information about that source and our use of the information that the law requires.

You may browse public pages without creating an account, but necessary technical information may still be processed to deliver and secure the website.

Where information is required to create an account, fulfil a purchase or provide support, we explain this at the relevant point. If you do not provide it, we may be unable to provide the associated service. Optional information will be identified as optional.

5. Why We Use Information and Our Lawful Bases

We identify an appropriate lawful basis for each purpose.

PurposeLawful basis

Creating and managing your account, processing purchases, providing course access and maintaining learning progress

Performance of our contract with you, or taking steps you request before entering into a contract

Providing support necessary to deliver your purchased services

Performance of our contract with you

Responding to general enquiries and administering ordinary customer relationships outside a contract

Our legitimate interests in communicating with users and operating our services

Protecting accounts, detecting fraud, investigating misuse and maintaining service security

Our legitimate interests in protecting users, systems and our business; legal obligation where a specific legal requirement applies

Keeping records required for tax, accounting or regulatory purposes

Compliance with legal obligations

Optional analytics, session replay, advertising measurement and personalised advertising

Consent, as explained in Section 6

Reviewing necessary operational records to resolve faults and improve service reliability

Our legitimate interests in maintaining reliable services; this does not bypass consent requirements for optional tracking

Sending promotional communications

Consent, or our legitimate interests where the electronic-marketing soft opt-in is lawfully available and all its conditions are met

Publishing identifiable testimonials or learner stories with your permission

Consent

Administering an affiliate agreement

Performance of that agreement; legal obligation for required financial records

Handling legal claims and necessary corporate due diligence

Our legitimate interests in protecting legal rights and managing our business, subject to appropriate safeguards

Where we rely on legitimate interests, we consider whether the use is necessary and proportionate and balance those interests against your rights and reasonable expectations.

If we need to use special-category information, such as health information supplied for an accessibility request, we must also identify an additional legal condition. We will explain the relevant processing and obtain explicit consent where that is the appropriate condition.

We will not use information for a new, incompatible purpose without first meeting the applicable legal requirements and providing appropriate information.

6. Cookies, App Technologies and Tracking

Our websites and applications may use cookies, local storage, pixels, software development kits, session identifiers and similar technologies.

These technologies can support different purposes:

• Essential functions: authentication, security, shopping baskets and other functions needed to provide a service you request.
• Preferences: language and other interface choices.
• Analytics: understanding how people navigate and use our services.
• Session replay: reviewing representations of website or app interactions to identify usability problems.
• Advertising and attribution: measuring campaigns, attributing enquiries or purchases, and showing relevant advertising.

We obtain consent before using optional analytics, session replay or advertising technologies. Technologies that qualify for a legal exception may operate without consent only within the conditions of that exception.

Before optional tracking starts, the relevant notice or consent interface will explain its purposes and identify the providers involved, the technologies used and relevant durations.

You can refuse optional tracking or withdraw your consent through the available website or app privacy controls. Refusing optional tracking does not prevent you from accessing the core course you purchased.

Changing a browser or device setting may affect some technologies, but does not necessarily control every app SDK or server-side process. Contact us if you need help managing a choice.

Session Replay

Where session replay is enabled, it may capture page or screen interactions, scrolling, clicks and relevant technical events. Its purpose is to help identify errors and improve usability.

Replay must be configured to exclude or mask passwords, payment information and other sensitive or private content. Access and retention must be limited to the stated purpose.

Advertising and Server-Side Measurement

Where you consent to relevant advertising measurement, information shared with advertising providers may include device or browser identifiers, campaign information and conversion events.

If customer matching is used, the relevant notice must explain which information is shared, with whom and for what purpose before the processing begins.

Hashing an email address or telephone number does not necessarily make it anonymous. Server-side tracking and conversion APIs remain subject to applicable privacy and consent requirements.

7. Marketing and Your Choices

We distinguish promotional communications from messages needed to provide your services.

Service messages may include purchase confirmations, security alerts, access instructions and important information about your course or account. We may send these where necessary even if you have opted out of marketing.

We send promotional email, SMS, WhatsApp or similar electronic messages only:

• With appropriate consent; or
• Where a lawful soft opt-in applies to our own similar products or services, including an opportunity to opt out when details are collected and in each subsequent message.

Contacting us, joining a support conversation or purchasing a course does not automatically authorise every form of marketing.

You have the right to object to direct marketing at any time, including profiling connected with that marketing. We will stop using your information for those purposes when you object.

You can use the unsubscribe or opt-out mechanism in a message, update available preferences, or contact [email protected]. We do not charge for opting out.

We may retain a limited suppression record to ensure that your choice continues to be respected.

8. Recordings, Communities and Testimonials

If a live class, telephone call or support interaction is recorded or transcribed, we will tell participants beforehand why this is happening and explain the relevant handling arrangements.

For optional recordings used for learning, quality review or training, we seek consent. Where another lawful basis applies to a particular recording, we explain it before recording begins.

Consent to participate in a class or support conversation is not blanket permission to use your image, voice or messages in advertising.

We obtain separate permission before publishing identifiable testimonials, learner stories or examination results for promotional purposes. You can withdraw consent for future consent-based use by contacting us.

If you join an optional community hosted by a third-party platform, information such as your display name, messages, profile details or telephone number may be visible to other members, depending on that platform’s settings. We explain material visibility implications before you join.

Please respect other members’ privacy and avoid sharing their private messages or personal information without authorisation.

9. AI-Assisted Features and Automated Processing

Where AI-assisted learning or support is available, information you submit and relevant service context may be processed to generate a response.

AI providers may process that information on our behalf. The relevant feature notice will explain material information about the provider’s role and handling of your submissions.

Using an AI feature does not, by itself, give blanket permission to use your private conversations or learning records to train general-purpose AI models. Any separate training use requires an appropriate lawful basis, clear information and consent where required.

Learning recommendations may use your course progress, practice results or selected preferences to suggest relevant materials. This type of personalisation does not itself determine an official examination result or qualification.

If a feature involves solely automated decisions with legal or similarly significant effects, we will provide a specific notice explaining the information used, the principal factors involved and the likely consequences. We will also provide the safeguards required by law, including an opportunity to make representations, obtain human intervention and challenge the decision.

You can contact us to request human review of an account-access issue, payment problem or material support decision.

10. Who We Share Information With

We share information only where there is an appropriate purpose and lawful basis.

Depending on the service, recipients may include:

• Website, application, cloud-hosting and content-delivery providers.
• Payment processors, banks, accounting providers and app-store operators.
• Customer-support, customer-relationship-management and communication providers.
• Email, SMS, telephone and messaging-service providers.
• Analytics, diagnostic, session-replay and advertising providers, subject to applicable choices.
• AI, transcription and learning-technology providers, where relevant.
• Authorised instructors, support personnel and contractors who need access to deliver their work.
• Accountants, lawyers, auditors, insurers and other professional advisers.
• Regulators, law-enforcement bodies or courts where disclosure is required or otherwise lawfully justified.

Where a provider acts as our processor, it must process information under appropriate contractual instructions and protections.

Some organisations, including certain payment providers, app stores and advertising platforms, may act as independent controllers for particular activities. Their own privacy notices explain those activities. We do not describe every third party as processing only on our instructions.

We do not sell or rent learner contact lists for unrelated third-party marketing. Advertising-related disclosures and any corporate-transaction disclosures are addressed separately in this Policy.

11. Investors, Fundraising and Corporate Transactions

We use aggregated or genuinely anonymised information for routine investor reporting wherever possible, such as overall enrolment, revenue or course-usage figures.

Pseudonymised information remains personal information where an individual can still be identified.

If identifiable information is necessary for fundraising due diligence, a merger, acquisition, restructuring or business transfer, we assess the lawful basis and disclose only what is necessary.

Depending on the transaction, recipients may include prospective investors or purchasers and their professional advisers. Appropriate restrictions may include confidentiality obligations, limited data-room access and limits on further use.

An investor’s involvement does not itself authorise access to individual learner records or marketing to our users.

If a transaction changes the controller of your information or how it will be used, we will provide the information required by law. A confidentiality agreement does not replace the need for a lawful basis.

12. International Transfers

Our use of suppliers, communication platforms and authorised personnel may involve processing or access outside the United Kingdom.

Where this involves a restricted international transfer, we must ensure that an appropriate transfer mechanism applies. Depending on the destination and recipient, this may include:

• UK adequacy regulations.
• The UK International Data Transfer Agreement.
• The UK Addendum to the European Commission’s Standard Contractual Clauses.
• Another mechanism or limited exception permitted by applicable law.

Where required, we assess the protection available in the destination country and apply additional safeguards.

You can contact [email protected] for information about the destinations relevant to your information and to request a copy or explanation of applicable safeguards, subject to necessary redactions.

Where EU GDPR applies, its international-transfer requirements must also be met.

13. How Long We Keep Information

We retain personal information for the purposes described in this Policy and determine retention by the type of record and the obligations associated with it.

The criteria we apply include:

InformationRetention criteria

Account and course-entitlement information

The duration of your account and purchased access, including information needed to honour continuing access rights

Learning progress and assessment records

Their usefulness for your ongoing learning, support and agreed course features; account closure and deletion requests trigger a review

Orders, invoices and financial records

Applicable accounting, tax and legal recordkeeping periods

Support enquiries and complaints

The time needed to resolve the matter, address follow-up issues and meet applicable legal-claim or regulatory requirements

Security and diagnostic logs

The period needed to identify faults, investigate incidents and protect systems, taking account of the sensitivity and risk involved

Optional analytics and session replay

The stated measurement or investigation purpose and the retention arrangements disclosed for the relevant technology

Marketing and consent records

The duration of relevant marketing activity and the evidence needed to demonstrate and respect your choices

Suppression records

The period needed to avoid sending marketing you have refused

Recordings and transcripts

The specific purpose explained when recording begins, including any relevant course-access or complaint-handling period

We do not retain all information indefinitely merely because an account once existed.

When information is no longer required, it should be deleted or genuinely anonymised. Information subject to a legal hold or a necessary recordkeeping obligation may be retained for that purpose with restricted use.

Backup copies may remain until the applicable backup cycle replaces them. Information awaiting removal from backups must not be restored to ordinary use in a way that defeats a valid deletion request.

14. Security and Account Deletion

We apply technical and organisational measures appropriate to the nature of the information and the risks involved. These include restricting access to authorised people and requiring appropriate safeguards from providers processing information on our behalf.

No system can be guaranteed completely secure. If a personal-data breach occurs, we assess it and notify the relevant authority and affected individuals where the law requires.

Please keep your account credentials secure and tell us promptly if you suspect unauthorised access.

You can request account deletion through available account controls or by contacting [email protected].

Deleting an account does not necessarily require immediate deletion of every record. We may need to retain limited information for legal obligations, unresolved disputes, fraud prevention or other justified purposes. We will explain relevant exceptions when responding.

Deleting an account or uninstalling an app may not stop a subscription administered by an app store. Subscription arrangements are addressed separately in the relevant service terms.

15. Children and Young People

Our learner services are intended for people aged 16 or over, consistent with our Terms and Conditions.

Users aged 16 or 17 are still children for data protection purposes. Where our services are likely to be accessed by children, we apply the protections required by applicable law and take account of the Children’s Code.

This includes age-appropriate information, data minimisation, appropriate privacy defaults and careful assessment of profiling, tracking and other potentially harmful processing.

We do not use our minimum-age statement as a substitute for assessing who actually accesses our services.

If we become aware of an account belonging to someone below our permitted age, we will assess the situation, restrict inappropriate access and delete information that we have no lawful reason to retain.

A parent, guardian or young person can contact us with a privacy concern. We consider the young person’s rights and understanding when responding; parental involvement does not automatically give unrestricted access to their information.

16. Your Data Protection Rights

Depending on the circumstances and the lawful basis involved, you may have the right to:

• Obtain information about how your personal information is used.
• Request access to your personal information.
• Correct inaccurate or incomplete information.
• Request deletion.
• Restrict certain processing.
• Receive or transfer certain information in a portable format.
• Object to processing based on legitimate interests.
• Object to direct marketing, including related profiling.
• Withdraw consent where processing relies on consent.
• Exercise applicable safeguards relating to significant automated decisions.

You may object to direct marketing at any time. For processing based on legitimate interests, you may object for reasons relating to your circumstances.

These rights are subject to applicable legal conditions and exemptions. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise a right, contact [email protected]. You do not need to use a prescribed form or particular legal wording.

We may request proportionate information to verify identity or authority before disclosing or changing personal information.

We respond without undue delay and normally within one month. Where the law permits an extension, including for complex or multiple requests, we will explain the reason and applicable timeframe. An extension may be up to a further two months.

Requests are normally free. We will explain any lawful basis for charging a reasonable fee or refusing a request, together with your complaint rights.

17. Privacy Complaints

If you are concerned about how we handle personal information, contact:

Email: [email protected]

Telephone: +44 20 8191 2679

Post: Privacy Complaints, PROJUKTI TEAM LIMITED, Unit 8, First Floor, 17–18 Vine Court, London, England, E1 1JH.

We will acknowledge a data protection complaint within 30 days, investigate appropriately, keep you informed and communicate the outcome without undue delay.

You also have the right to complain to the UK supervisory authority:

Information Commissioner’s Office (ICO)

Complaints: ico.org.uk/make-a-complaint

Where another jurisdiction’s data protection law applies, you may also have the right to complain to the relevant local supervisory authority.

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our services, processing activities or legal requirements.

We will update the date at the top of this page and provide appropriate notice of material changes, including directly where required.

Where a new use requires consent, we will obtain that consent before beginning the relevant processing. Continued use of our website or application does not automatically provide consent to a new purpose.

Our Terms and Conditions govern use of our services, and our Refund Policy addresses cancellation and refund arrangements.