PRIVACY POLICY 

Last reviewed: August 2026 

RightTrack Learning Ltd understands that your privacy is important and that you care about how your Personal Data is used. We respect and value the privacy of everyone who visits or uses www.righttracklearning.com (“Our Site”), uses Our services, works for Us or provides goods or services to Us. 

We will only collect and use Personal Data in ways described in this Privacy Policy and in accordance with applicable data protection law. 

Please read this Privacy Policy carefully. It explains how We collect, use, store and protect your Personal Data and the rights available to you. 

 

1. Definitions and Interpretation

In this Policy: 

1.1 “Cookie” means a small text file placed on your computer or device when you visit certain parts of Our Site or use certain features. 

1.2 “Data Protection Regulation” means applicable data protection and privacy legislation in force in the United Kingdom from time to time, including the UK GDPR, Data Protection Act 2018, Privacy and Electronic Communications Regulations 2003, as amended, and the Data (Use and Access) Act 2025, together with any successor or replacement legislation. Where applicable to particular processing, this may also include the EU General Data Protection Regulation or other relevant data protection legislation. 

1.3 “Personal Data” means any information relating to an identified or identifiable individual. 

1.4 “We/Us/Our” means RightTrack Learning Ltd. 

 

2. Information About Us

2.1 Our Site is operated by RightTrack Learning Ltd, a limited company registered in England and Wales under number 02625253, whose registered office is at RIGHTTRACK LEARNING LIMITED Lifford Hall, Tunnel Lane, Kings Norton Birmingham, B30 3JN

2.2 Our VAT number is 687 7321 90.

 

3. What Does This Policy Cover?

3.1 This Privacy Policy applies to your use of Our Site, your purchase or use of Our services, your dealings with Us offline, and where you work for or provide goods or services to Us, either personally or as a representative of an organisation.

3.2 Our Site may contain links to other websites or applications, and We may refer you to third-party suppliers of goods or services. We have no control over how those independent organisations collect, store or use your Personal Data. We recommend that you review their privacy policies before providing Personal Data to them.

 

4. Your Rights

4.1 Depending on the circumstances, you may have the following rights under applicable data protection legislation:
4.1.1 The right to be informed about Our collection and use of Personal Data.
4.1.2 The right of access to the Personal Data We hold about you.
4.1.3 The right to have inaccurate or incomplete Personal Data corrected.
4.1.4 The right to request erasure of your Personal Data where applicable. 
4.1.5 The right to request restriction of the processing of your Personal Data. 
4.1.6 The right to data portability where applicable. 
4.1.7 The right to object to certain processing of your Personal Data, including the right to object at any time to its use for direct marketing. 
4.1.8 Rights relating to certain automated decision-making and profiling where applicable.
4.1.9 The right to withdraw consent where processing is based on consent. 

4.2 If you have a complaint about how We have handled your Personal Data, please contact Us using the details in Part 14. We will acknowledge a data protection complaint within 30 days, investigate it without undue delay, keep you appropriately informed and notify you of the outcome. 

4.3 You also have the right to raise a complaint with the Information Commissioner’s Office (ICO). 

 

5. What Personal Data Do We Collect?

5.1 Depending on your relationship with Us and your use of Our Site or services, We may collect some or all of the following Personal Data:
5.1.1 First name/last name.
5.1.2 Date of birth or age, where relevant. 
5.1.3 Address.
5.1.4 Personal or work email address. 
5.1.5 Contact telephone number.
5.1.6 Job title.
5.1.7 Organisation name. 
5.1.8 Bank details where necessary. 
5.1.9 Photographs or video. 
5.1.10 Next-of-kin contact details where relevant. 
5.1.11 IP address.
5.1.12 Location data.
5.1.13 Device type.
5.1.14 Web browser type and version. 
5.1.15 Operating system.
5.1.14 Programme registration or attendance information. 
5.1.15 Evaluation responses, feedback and opinions. 

5.2 Some of Our services may involve individuals voluntarily sharing information that constitutes special category Personal Data, for example information relating to health, disability, ethnicity, religion or sexual orientation. 

5.3 We seek to minimise the collection and retention of identifiable special category Personal Data. Where such information is collected through surveys, evaluation or similar activities, findings are normally reported in anonymised or aggregated form and only where there is sufficient data to prevent individuals being identifiable.

5.4 Where We deliberately collect or record identifiable special category Personal Data, We will ensure that an appropriate lawful basis and additional condition for processing applies. 

5.5 We do not normally collect credit or debit card details directly. Our payment providers may collect this information where necessary and their own privacy policies will apply.

5.6 We may collect financial information directly in limited circumstances, for example where necessary to process a refund or manage an employment or supplier relationship.

 

6. How Do We Use Your Personal Data?

6.1 We process Personal Data securely and retain it only for as long as reasonably necessary for the purpose for which it was collected, taking account of contractual, legal and regulatory requirements. 

6.2 Our collection and use of Personal Data will have an appropriate lawful basis under applicable data protection legislation. Depending on the purpose and circumstances, this may include: 
6.2.1 Processing necessary to perform a contract or take steps relating to a contract. 
6.2.2 Compliance with a legal obligation. 
6.2.3 Our legitimate interests, where those interests are not overridden by your rights and interests. 
6.2.4 Consent, where consent is the appropriate lawful basis. 

6.3 We may use Personal Data for purposes including:
6.3.1 Providing and managing access to Our Site and services. 
6.3.2 Managing your or your organisation’s relationship with Us. 
6.3.3 Managing purchases and contracts for Our services. 
6.3.4 Supplying and administering Our services. 
6.3.5 Communicating with clients, participants, suppliers and other contacts. 
6.3.6 Responding to emails, messages and other correspondence.
6.3.7 Providing programme communications, invitations, follow-up information and other information relevant to services you or your organisation are receiving.
6.3.8 Managing employment, associate and supplier relationships.
6.3.9 Carrying out research, evaluation and gathering feedback to improve Our services.
6.3.10 Managing and developing Our business and client relationships. 

6.4 Where permitted by law, We may use relevant contact information for direct marketing purposes, including contacting you about Our services, news or events. 

6.5 We will comply with applicable data protection and electronic marketing requirements. You may opt out of direct marketing at any time using the unsubscribe facility provided in Our emails or by contacting Us using the details in Part 14. 

6.6 If you object to the use of your Personal Data for direct marketing, We will stop using it for that purpose. We may retain limited information on a suppression list to ensure that your preference continues to be respected. 

6.7 Where We rely on your consent to process Personal Data, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn. You may also have a separate right to request erasure of your Personal Data where applicable.

6.8 Our general retention approach is: 

Information Standard retention approach 
Client and prospective client contact information Retained for as long as there is an ongoing or reasonably anticipated business relationship, or a legitimate business need to maintain the information for sales and marketing purposes. Records are reviewed periodically to ensure they remain relevant and accurate and are deleted or anonymised where they are no longer required, subject to any legal or contractual retention requirements. 
Participant information provided for programme delivery Routine participant information, including attendance registers and other administrative details, is retained until the end of the relevant project and any associated follow-up has been completed, after which it is securely deleted or anonymised unless there is a specific reason to retain it for longer. Where participant information forms part of a formal qualification, accreditation or certification record, relevant records may be retained for longer where necessary to evidence achievement, respond to future verification requests or meet the requirements of the relevant awarding or professional body. 
Evaluation, research and participant feedback data Identifiable data is normally retained until the end of the relevant project and any associated reporting or follow-up, after which it is securely deleted or anonymised unless there is a specific reason to retain it for longer. Participation in feedback activities is transparent and, where appropriate, optional. Anonymised or aggregated findings may be retained for longer to support continuous improvement, service development and analysis, where individuals can no longer reasonably be identified. 
Session recordings, photographs, testimonials and case-study material Retained for the agreed purpose and in accordance with the permissions and arrangements applying to the activity. 
Contracts, invoices and other financial or legal records Retained for the period required by applicable legal, taxation, accounting or contractual requirements. 

 

6.9 Where We act as a Data Processor on behalf of a client, We process Personal Data in accordance with the client’s documented instructions and applicable contractual arrangements. At the end of the relevant services, Personal Data will be securely deleted in accordance with the client’s instructions and contractual arrangements, unless applicable law requires continued retention. 

 

7. How and Where Do We Store and/or Transfer Your Personal Data?

7.1 The security of your Personal Data is important to Us. We take appropriate technical and organisational measures to protect it, including:
7.1.2 Limiting access to Personal Data to employees, associates, contractors and third parties who have a legitimate need to access it and are subject to appropriate confidentiality requirements.
7.1.3 Using appropriate security controls, including secure business systems, access controls, password protection and multi-factor authentication.
7.1.4 Maintaining procedures for identifying, reporting and responding to Personal Data breaches.
7.1.5 Taking appropriate steps to assess the security and data protection arrangements of service providers processing Personal Data on Our behalf. 

7.2 RightTrack Learning is Cyber Essentials certified. 

7.3 We use trusted third-party systems and service providers where necessary to operate Our business and deliver Our services. These may include CRM, cloud and productivity services, communications and virtual delivery, evaluation, hosting, payment and other business systems. 

7.4 Where third parties process Personal Data on Our behalf, We take appropriate steps to assess their data protection and security arrangements and put suitable contractual safeguards in place.

7.5 We maintain oversight of the systems and applications used to process Personal Data, with access to new tools and technologies subject to appropriate internal approval and security review. 

7.6 Some service providers may process or store Personal Data outside the United Kingdom. Where this occurs, We ensure that an appropriate lawful transfer mechanism and safeguards are in place in accordance with applicable data protection legislation.

7.7 Please contact Us using the details in Part 14 if you require further information about safeguards applying to international transfers. 

 

8. Do We Share Your Personal Data?

8.1 We may share Personal Data with trusted third-party service providers where this is necessary to operate Our business or provide Our services. 

8.2 Where third parties process Personal Data on Our behalf, We take appropriate steps to ensure that the information is handled safely, securely and in accordance with applicable data protection legislation. 

8.3 We may compile and use statistics about Our Site, services and business activities. Where information has been effectively anonymised so that individuals can no longer reasonably be identified, it is no longer treated as Personal Data for the purposes of this Policy. 

8.4 Where Personal Data is transferred internationally, the arrangements described in Part 7 will apply. 

8.5 We may disclose Personal Data where required by law, legal proceedings, a court order, regulatory requirements or a lawful request from a public authority. 

8.6 We do not sell Personal Data. 

 

9. What Happens If Our Business Changes Hands?

9.1 We may from time to time expand, reduce or restructure Our business, which could involve the sale or transfer of control of all or part of the business. 

9.2 Where Personal Data is relevant to a transferred part of Our business, it may be transferred to the new owner or controlling party in accordance with applicable data protection legislation and used for the purposes for which it was originally collected or otherwise lawfully processed. 

 

10. How Can You Control Your Personal Data?

10.1 In addition to the rights set out in Part 4, where you provide Personal Data to Us you may be given options to control how We use it. 

10.2 You can opt out of direct marketing at any time by using the unsubscribe link provided in Our marketing emails or by contacting Us using the details in Part 14. 

10.3 We may retain limited information on a suppression list where necessary to ensure that We continue to respect your request not to receive marketing. 

 

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Site without providing Personal Data.

11.2 However, some information may be required where necessary to provide particular services, respond to requests, enter into or administer a contract or meet legal requirements. 

11.3 You can control the use of non-essential Cookies. Further information is set out in Part 13. 

 

12. How Can You Access Your Personal Data?

12.1 You have the right to request access to Personal Data We hold about you.

12.2 In most circumstances, no fee is payable. Applicable data protection legislation may allow Us to charge a reasonable fee in limited circumstances, for example where a request is manifestly unfounded or excessive or where additional copies are requested. 

12.3 We may take reasonable steps to verify your identity before providing Personal Data. 

12.4 Please contact Us using the details in Part 14 if you wish to make a request. 

 

13. Our Use of Cookies

13.1 Our Site uses Cookies and similar technologies to support its operation and security and, where permitted, to understand how the Site is used and support advertising and marketing activity. 

13.2 Strictly necessary Cookies may be used without consent where they are required to provide the Site or functionality requested by you. 

13.3 Non-essential Cookies, including analytics and advertising Cookies, are subject to applicable consent requirements. Visitors can manage their preferences through the cookie controls available on Our Site. 

13.4 Our Site currently uses or may use Cookies associated with the following services and purposes: 

Cookie Provider / purpose 
PHPSESSID Website session management and functionality. 
_lscache_vary LiteSpeed website caching and functionality. 
__cf_bm Cloudflare and service-provider security and bot-management functionality. 
__hs_cookie_cat_pref HubSpot cookie-consent preferences. 
__hstc, __hssc, __hssrc, hubspotutk HubSpot website analytics and visitor/session functionality, where permitted by consent settings. 
_ga, _ga_BRRMVGM424 Google Analytics, used to understand website usage where analytics consent has been provided. 
_gcl_au Google advertising and conversion measurement where relevant consent has been provided. 
_fbp Meta/Facebook advertising and measurement where relevant consent has been provided. 
bcookie, li_gc, lidc LinkedIn functionality, advertising and consent management where relevant consent has been provided. 
test_cookie Google/DoubleClick functionality used in connection with advertising technologies where relevant consent has been provided. 

 

13.5 Other security, session or technical Cookies may be used by the Site or its service providers where necessary for security or functionality. 

13.6 Cookie technologies and providers can change as Our Site and services develop. We periodically review the Cookies used and update this Policy where appropriate. 

13.7 You can change your Cookie preferences through the controls provided on Our Site and through your browser settings. 

 

14. Contacting Us

14.1 If you have questions, requests or complaints relating to this Privacy Policy or the way We handle Personal Data, please contact: 

14.2 Data Protection Lead: Toni-Ann Martin
Email: enquiries@righttracklearning.com 

14.3 RIGHTTRACK LEARNING LIMITED Lifford Hall, Tunnel Lane, Kings Norton Birmingham, B30 3JN

14.4 Senior data protection oversight is provided by Claudia Cooney. 

 

15. Changes to Our Privacy Policy

15.1 We may update this Privacy Policy from time to time, including where there are changes to the law, Our services or the way We process Personal Data. 

15.2 Any updated version will be published on Our Site. We recommend that you review this page periodically to stay informed about how We use and protect Personal Data.