1. Introduction

Lernor Education (“Lernor”, “we”, “our”, or “us”) is a global academic institution providing assessment-led educational support across multiple curricula, including the IB Diploma Programme, IB MYP, IGCSE, and A-Level. In the course of delivering academic services, operating institutional systems, and maintaining educational quality, Lernor processes personal and academic information relating to students, parents or guardians, schools, educators, applicants, and website users.

This Privacy Policy explains how information is collected, used, processed, stored, and disclosed when individuals interact with Lernor through our websites, platforms, communications, academic services, recruitment processes, or related institutional activities. It also outlines the principles governing such processing and the rights available under applicable data protection laws.

Lernor acts as the data controller for the purposes described in this policy, except where information is processed on behalf of a school or institutional partner under a separate agreement. This policy applies globally and is intended to reflect Lernor’s academic, operational, and legal responsibilities in a clear and institutionally appropriate manner.

2. Scope of This Policy

This Privacy Policy applies to the processing of information in connection with all Lernor activities, including but not limited to:

• Visitors to Lernor websites and digital platforms
• Students receiving academic or assessment-related support
• Parents or guardians engaging with Lernor on behalf of students
• Schools and institutional partners
• Educators, examiners, consultants, and applicants
• Individuals communicating with Lernor through any channel

The policy covers information collected or generated through academic services, digital platforms, learning portals, communications, recruitment processes, events, assessments, and related institutional operations. It applies regardless of whether information is provided directly, generated through use of Lernor systems, or obtained in the course of delivering services.

Where Lernor processes information on behalf of a school or institutional partner under a separate agreement, such processing is governed by the terms of that agreement and applicable law. In all other cases, this Privacy Policy governs the processing of information by Lernor as an independent data controller.

3. Categories of Information We Collect

In the course of operating as an academic institution and delivering assessment-led services, Lernor collects and processes a broad range of information. The categories below are indicative and not exhaustive.

a. Identity and Contact Information

Information such as names, email addresses, telephone numbers, institutional affiliations, and similar identifiers provided directly or generated through engagement with Lernor.

b. Academic and Assessment Information

Information relating to academic programmes, coursework, assessments, submissions, drafts, feedback, evaluations, recordings of academic sessions, and related educational materials shared or generated in connection with Lernor’s services.

c. Communications

Records of correspondence and interactions, including emails, messages, calls, internal notes, and other communications conducted through Lernor systems or channels.

d. Usage and Technical Information

Information generated through interaction with Lernor websites, platforms, or systems, including IP addresses, device information, browser type, access logs, timestamps, metadata, navigation patterns, and other technical or usage data.

e. Transactional and Administrative Information

Information related to enrolment, payments, invoicing, contractual arrangements, and administrative coordination.

f. Recruitment and Professional Information

Information provided or generated in connection with educator engagement, recruitment, or professional collaboration, including qualifications, experience, assessments, and related documentation.

g. Derived, Inferred, and Generated Information

Information derived or inferred from other data, including engagement indicators, performance patterns, preferences, usage trends, or analytical outputs generated through institutional review, academic analysis, or system optimisation. Information may be collected directly from individuals, generated through use of Lernor services or systems, or obtained in the course of legitimate academic, operational, or institutional activities.

4. Purposes and Legal Basis of Processing

Lernor processes personal and academic information to the extent reasonably necessary for the establishment, administration, operation, and development of its educational services and institutional functions, and in a manner consistent with applicable data protection and privacy laws.

Information may be processed for academic, operational, analytical, security, institutional, legal, and governance-related purposes, including those necessary to deliver educational services; maintain academic standards and assessment integrity; ensure appropriate oversight, safeguarding, and quality assurance; operate and secure institutional systems and infrastructure; analyse, evaluate, and improve services and methodologies; support organisational planning and institutional development; and manage compliance, risk, and legal obligations.

Processing is undertaken on one or more lawful bases recognised under applicable law, including where processing is necessary for the performance of contractual arrangements, compliance with legal obligations, the protection of vital interests, consent where required, and Lernor’s legitimate interests in operating, protecting, and developing its educational institution.

Nothing in this Privacy Policy shall be interpreted as limiting Lernor’s ability to process information in any manner that is lawful, proportionate, and consistent with the purposes described herein.

5. Academic Data and Confidential Handling

In the course of providing educational and assessment-led services, Lernor processes academic information that may include coursework, assessments, drafts, submissions, feedback, evaluations, recordings, and related educational materials. Such information is processed as part of Lernor’s academic functions and institutional operations.

Access to academic information is limited to individuals acting within the scope of their academic, professional, or institutional responsibilities, and is subject to internal controls and procedures designed to support confidentiality, integrity, and appropriate use. Academic information may be reviewed, analysed, and processed for educational delivery, quality assurance, institutional oversight, safeguarding, and related lawful purposes.

Nothing in this section shall be construed as creating an obligation of absolute confidentiality, ownership, or exclusivity beyond what is required under applicable law. Academic information may be retained, processed, or disclosed to the extent necessary to fulfil the purposes set out in this Privacy Policy, to comply with legal or regulatory requirements, or to support legitimate institutional interests.

6. De-Identified and Aggregated Information

Lernor may anonymise, aggregate, or otherwise de-identify information so that it no longer identifies an individual. De-identified or aggregated information may be used by Lernor for academic, analytical, research, quality assurance, institutional review, service development, and system improvement purposes.

Such information may be analysed internally and, where appropriate, shared with professional advisors, research partners, or service providers, provided that reasonable measures are applied to prevent re-identification and to ensure use consistent with institutional and legal standards.

Once information has been de-identified, it is no longer subject to the protections applicable to personal data under data protection laws and may be retained and used by Lernor for lawful purposes without limitation.

7. Data Sharing and Disclosure

Lernor may share or disclose information, including personal and academic information, where such sharing is necessary and appropriate for the operation of its educational services and institutional functions, and where permitted by applicable law. Information may be shared with internal teams, educators, examiners, consultants, and other individuals acting on behalf of Lernor for academic, operational, or institutional purposes. Lernor may also disclose information to service providers, professional advisors, or infrastructure partners who support Lernor’s systems, operations, or compliance obligations, subject to appropriate contractual and organisational safeguards.

Information may further be disclosed where required to comply with legal or regulatory obligations, to respond to lawful requests from public authorities, to protect the rights, property, or safety of Lernor or others, or in connection with corporate transactions, restructuring, or the transfer of institutional activities, provided that such disclosure is consistent with applicable law.

Lernor does not sell personal information as a standalone commercial activity. Any sharing or disclosure is conducted in a manner consistent with the purposes set out in this Privacy Policy and Lernor’s institutional responsibilities.

8. International Data Processing and Transfers

Lernor operates as a global academic institution. In the course of delivering educational services and maintaining institutional operations, information may be processed, stored, or accessed in jurisdictions outside the country in which an individual is located.

Where information is transferred or processed across borders, Lernor takes reasonable steps to ensure that such processing is carried out in accordance with applicable data protection laws and appropriate safeguards, including contractual, organisational, or technical measures, as required.

By engaging with Lernor’s services, individuals acknowledge and accept that information may be processed in multiple jurisdictions where Lernor, its service providers, or institutional partners operate.

9. Data Retention

Lernor retains information for as long as is reasonably necessary to fulfil the purposes for which it is processed, as set out in this Privacy Policy, including academic, institutional, operational, legal, and compliance-related purposes.

Retention periods may vary depending on the nature of the information, the context in which it was collected or generated, and applicable legal or regulatory requirements. Information may be retained beyond the conclusion of an academic engagement where necessary for institutional records, quality assurance, safeguarding, dispute resolution, system integrity, or compliance with legal obligations.

Lernor may also retain information in backup systems, archives, logs, or similar records for operational continuity and security purposes. Where information is no longer required, it is handled in accordance with Lernor’s internal retention and deletion practices and applicable law.

10. Individual Rights and Requests

Subject to applicable data protection laws, individuals may have certain rights in relation to information processed by Lernor. These rights may include the right to request access to, correction of, or restriction on the processing of personal information, and, in certain circumstances, the right to request erasure or object to processing.

Requests to exercise such rights must be made in writing and may be subject to identity verification and other requirements permitted by law. Lernor will assess and respond to requests within the timeframes prescribed by applicable legislation and may decline or limit requests where permitted, including where processing is necessary for academic, institutional, legal, or operational purposes.

Where Lernor processes information on behalf of a school or institutional partner, requests relating to such information may need to be directed to the relevant institution in accordance with applicable agreements and legal obligations.

11. Updates to This Privacy Policy

Lernor may revise or update this Privacy Policy from time to time to reflect changes in legal requirements, institutional practices, academic services, or operational processes. Any updates will become effective upon publication on Lernor’s websites or platforms, unless otherwise required by applicable law.

Where changes are material, Lernor may provide additional notice in a manner consistent with legal obligations. Continued engagement with Lernor’s services following the publication of an updated Privacy Policy constitutes acknowledgment of the revised terms, to the extent permitted by law.

12. Contact Information

Questions, requests, or communications relating to this Privacy Policy or Lernor’s processing of information may be directed to Lernor using the contact details made available on our official website or through designated institutional communication channels.

Lernor will address communications in accordance with applicable law and internal procedures.