Privacy Notice
This is the privacy notice of Blueberry Microlearning Ltd, company number 14963546 ('we', 'our', or 'us').
Our registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
1. Introduction
This notice describes how we collect, store, transfer and use personal data in connection with our online video learning courses on Sustainability and Climate Risk. It tells you about your privacy rights and how the law protects you.
In the context of the law and this notice, 'personal data' is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as 'processing'.
This notice applies to personal data collected through our website www.ClimateRisk.training and any associated learning platforms, mobile applications, and social media channels.
Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website.
2. Data Protection Officer
We have appointed a data protection officer ('DPO') who is responsible for ensuring that our privacy policy is followed.
If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO at dpo@climaterisk.training.
3. Personal Data We Process
3.1 How we obtain personal data
The information we process about you includes information:
- you have directly provided to us
- that we gather from third party databases and service providers
- as a result of monitoring how you use our website, learning platform or our services
3.2 Types of personal data we collect directly
When you use our website, register for courses, or purchase our services, we ask you to provide personal data. This can be categorised into the following groups:
- Personal identifiers: your first and last names, your title, and your date of birth
- Contact information: your email address, your telephone number and your postal addresses for billing and communication
- Account information: your username and password
- Payment information: debit or credit card details (processed through our secure payment provider)
- Educational information: your current professional qualifications, employer details (if relevant), and learning objectives
- Course activity data: your progress through courses, quiz scores, mock test results, completion rates, and time spent on materials
- Communication records: messages sent through our platform, support tickets, forum posts, and email correspondence
- Marketing preferences: what types of marketing you would like to receive
3.3 Types of personal data we collect from your use of our services
By using our website and learning platform, we process:
- Authentication data: username, password and other information used to access our services
- Learning analytics: course progress, video viewing patterns, quiz attempts and scores, mock exam results, completion certificates earned
- User-generated content: forum posts, comments, questions asked during courses, feedback and reviews
- Technical information: Internet Protocol (IP) address, browser type and version, device operating system, screen resolution
- Usage information: frequency of platform use, pages visited, features used, learning patterns
- Transaction information: details of courses purchased, payment history, refund requests
3.4 Special personal data
We do not routinely collect special personal data about you. However, if you voluntarily provide information about disabilities or learning difficulties when requesting course accommodations, we will process this data solely for the purpose of providing appropriate support.
3.5 If you do not provide personal data we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing access to our courses. If so, we will notify you of this at the time.
4. The Bases on Which We Process Information About You
The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.
4.1 Information we process because we have a contractual obligation with you
When you create an account on our website and purchase a course from us, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. We use it to:
- Verify your identity for security purposes
- Provide access to purchased courses
- Track your learning progress
- Issue completion certificates
- Provide instructor support and Q&A sessions
- Process payments and refunds
- Communicate important course updates
- Administer our Exam Success Guarantee
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
4.2 Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or sign up for our newsletter, you provide your consent to us to process information that may be personal data.
We continue to process your information on this basis until you withdraw your consent. You may withdraw your consent at any time by emailing support@climaterisk.training.
4.3 Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
For example, we may process your data on this basis for the purposes of:
- Improving our courses and learning platform
- Preventing fraudulent use of our services
- Ensuring network and information security
- Analysing learning patterns to enhance educational outcomes
- Protecting our intellectual property rights
- Responding to support requests
4.4 Information we process because we have a legal obligation
We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal data.
5. How and When We Process Your Personal Data
5.1 Your personal data is not sold
We do not sell or rent your personal data to third parties for marketing purposes.
5.2 Sharing with service providers
We may share your personal data with trusted third parties who assist us in operating our website and learning platform, including:
- Payment processors (to handle transactions securely)
- Cloud hosting providers (to store course content and user data)
- Email service providers (for course communications)
- Analytics providers (to improve our services)
- Professional examination bodies (only with your explicit consent)
All third-party service providers are required to maintain the confidentiality and security of your personal data.
5.3 User-Generated Content
When you post in forums, submit questions during courses, or leave reviews, this information may be visible to other learners. Please be mindful of the personal information you share in these public areas.
5.4 Payment information
Payment information is processed by our secure payment service provider. We do not store complete credit or debit card details on our servers. We retain only limited transaction information necessary for accounting, refunds, and our Exam Success Guarantee.
5.5 Learning Analytics
We use learning analytics to:
- Monitor individual progress and provide personalized support
- Identify areas where learners commonly struggle
- Improve course content and structure
- Verify eligibility for our Exam Success Guarantee
- Generate anonymized reports on course effectiveness
6. Use of Information We Collect Through Automated Systems
6.1 Cookies
Our website uses cookies to enhance your learning experience. These include:
- Essential cookies: Required for platform functionality and secure access
- Analytics cookies: Help us understand how learners use our platform
- Preference cookies: Remember your settings and learning preferences
- Performance cookies: Ensure videos stream smoothly and content loads quickly
You can manage cookie preferences through your browser settings, though some platform features may not function properly without essential cookies.
6.2 Video Analytics
Our video platform collects data about your viewing patterns to:
- Resume videos where you left off
- Track completion for certification purposes
- Identify content that may need clarification
- Optimize video delivery based on your connection speed
7. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Encryption of data in transit and at rest
- Regular security assessments and updates
- Access controls limiting data access to authorized personnel
- Secure backup procedures
- Regular staff training on data protection
8. Data Retention
We retain your personal data for different periods depending on its purpose:
- Account information: For the duration of your account plus 6 years
- Course progress data: Until course access expires plus 3 years
- Payment records: 7 years for accounting and tax purposes
- Exam results (for guarantee claims): 2 years from exam date
- Marketing communications: Until you unsubscribe
- Support communications: 3 years from last interaction
9. Your Rights
Under the Data Protection Act 2018, you have the following rights:
- Right to access: Request a copy of your personal data
- Right to rectification: Correct inaccurate personal data
- Right to erasure: Request deletion of your personal data (subject to legal obligations)
- Right to restrict processing: Limit how we use your data
- Right to data portability: Receive your data in a structured format
- Right to object: Object to certain types of processing
- Rights related to automated decision-making: We do not use automated decision-making
To exercise any of these rights, please contact our DPO at dpo@climaterisk.training.
10. International Data Transfers
Some of our service providers may process data outside the UK. Where this occurs, we ensure appropriate safeguards are in place, including:
- Standard contractual clauses
- Ensuring recipients are in countries with adequate data protection laws
- Implementing additional security measures where necessary
11. Children's Privacy
Our courses are designed for professional development and are not intended for children under 18. We do not knowingly collect personal data from children. If you are under 18, you may only use our services with parental consent.
12. Changes to This Privacy Policy
We may update this privacy policy from time to time. We will notify you of any material changes via email or through prominent notice on our platform. The "Last Updated" date at the top indicates when this policy was last revised.
13. Complaints
If you have any concerns about how we handle your personal data:
- First, contact our DPO at dpo@climaterisk.training
- If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/
We would appreciate the opportunity to address your concerns before you approach the ICO.
14. Contact Information
For privacy-related queries:
- Data Protection Officer: dpo@climaterisk.training
For general queries:
- Email: support@climaterisk.training
- Website: www.ClimateRisk.training
For formal complaints:
- Email: complaints@climaterisk.training
Policy Effective Date: 1 June 2025 Next Policy Review Date: 1 June 2025 Policy Owner: Directors, BLUEBERRY MICROLEARNING LTD
This policy should be read in conjunction with our Terms and Conditions