Vanguard Data Services Privacy Policy

2. INFORMATION WE COLLECT

We collect personal information that you voluntarily provide to us as well as data automatically generated when you interact with the Platform.

• Account Credentials & Identity Data: Full name, email address, password credentials, and unique account identifiers.
• Profile Metadata: Phone number, academic institution or university, city, professional links (e.g., LinkedIn profile), and personal biography provided in your account settings.
• Learning & Telemetry Data: Module completion history, instructional progress, course enrollments, assessment results, and active platform watch time.
• Payment & Transaction Data: Information necessary to process course purchases. All payment transactions are securely handled directly by our PCI-DSS compliant third-party payment processor (Stripe). We do not store or process raw payment card details on our servers.
• Technical & Usage Data: IP address, browser type, device specifications, operating system, and session data collected via necessary cookies.

3. LEGAL BASIS FOR PROCESSING YOUR DATA

We process your personal data under the following legal grounds provided by UK GDPR:

• Contractual Necessity: To register your account, grant access to course materials, track educational progress, and issue CPD-accredited certification.
• Legitimate Interests: To maintain the security, functionality, and performance of our Platform, prevent fraud, and improve our curriculum.
• Legal Obligation: To comply with financial accounting, auditing, and corporate reporting requirements.
• Consent: Where you have explicitly opted in to receive promotional communication or non-essential cookies (which you may withdraw at any time).

4. DATA RETENTION AND SECURITY

• Security Controls: We implement appropriate technical and organizational measures to safeguard your personal data against unauthorized access, loss, alteration, or disclosure. Access control mechanisms and encrypted sessions safeguard user sessions.
• Data Retention: We retain your personal data for as long as your account remains active or as required to fulfill our contractual and legal obligations. Upon account closure, data is either securely deleted or anonymized, unless retention is mandated by applicable tax or financial laws.

5. SHARING AND THIRD-PARTY DISCLOSURES

We do not sell, rent, or trade your personal data to third-party advertisers. We only share information with authorized service providers who process data on our behalf to operate the Platform, including:

• Secure cloud hosting and infrastructure providers.
• Payment processing platforms (Stripe).
• Educational verification registries (such as The CPD Register) to authenticate awarded credentials.
• Law enforcement or regulatory authorities when required by applicable law or court order.

6. INTERNATIONAL DATA TRANSFERS

As a global platform operating between the United Kingdom and international locations, your data may be transferred to and stored in locations outside the UK or European Economic Area (EEA). Where international transfers occur, we ensure adequate protections are in place, such as Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO).

7. YOUR DATA PROTECTION RIGHTS

Under the UK GDPR and applicable privacy legislation, you possess the following rights regarding your personal information:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure (“Right to be Forgotten”): Request deletion of your personal account and associated data, subject to legal retention obligations.
• Right to Restrict Processing: Request restriction of processing under certain circumstances.
• Right to Data Portability: Request a copy of your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or direct marketing.

To exercise any of these rights, please submit a formal request to our Data Protection Officer at privacy@axncorp.com.

8. COOKIES AND TRACKING TECHNOLOGIES

We use essential cookies and similar tracking technologies to maintain secure user login sessions, remember user preferences, and analyze platform performance. You can control cookie preferences through your web browser settings; however, disabling essential cookies may impact platform functionality.

9. UPDATES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy periodically to reflect operational, legal, or regulatory changes. Any updates will be posted on this page with a revised “Effective Date.”