1) Who we are

LearningWalks Ltd (Company No. 16569899) registered at 39 High St, Battle, TN33 0EE, United Kingdom is the data controller for account and service metadata, and a data processor when handling Customer Content entered by Organisations.

2) Data we collect

• Account details: name, email, role, password, organisation information, billing contacts.
• Customer Content: learning walk notes, staff feedback, pupil views (captured only through staff accounts), uploaded evidence including photos and documents, class data, room data.
• Telemetry & analytics: logs, device/browser data, and Microsoft Clarity session replays (kept up to 30 days).
• Support: enquiries, emails, and any information you choose to provide.

3) How we use your data

• To provide the Service: creating accounts, authenticating users, storing and displaying Customer Content.
• To support and improve: responding to enquiries, debugging, product development, training models on anonymised usage.
• To meet legal duties: accounting, tax, safeguarding, and compliance obligations.
• For communication: sending important notices about the Service. Marketing emails are only sent with consent and can be opted out of at any time.

Legal bases under UK GDPR: contract, legal obligation, legitimate interests, and consent (where applicable).

4) Sharing and sub‑processors

We do not sell or rent your personal data. We share it only with trusted providers that help us deliver the Service, such as hosting, email, analytics, and support tools. These providers act as sub‑processors and our current list is published at /subprocessors.

All data is stored within the UK and EU. No data is stored outside these regions.

5) Retention

• Customer Content: available during your subscription and retained for 90 days after termination before permanent deletion.
• Session replays/logs: retained for up to 30 days.
• Billing records: retained for 6 years as required by HMRC.

6) Your rights

Under UK GDPR you have the right to request access, rectification, erasure, restriction, portability, and to object to certain processing. You can also lodge a complaint with the Information Commissioner’s Office (ICO).

To make a Subject Access Request (SAR) or exercise other rights, email [email protected].

7) Children

The Service is for school staff. Pupils do not hold accounts. Pupil views may be entered by staff during a learning walk, but we do not knowingly collect data directly from children.

8) Security

We apply appropriate technical and organisational measures to protect personal data, including encryption, access controls, and monitoring. However, no online system is completely secure. Report suspected security issues to [email protected].

9) International transfers

We store data in the UK and EU. If in future we transfer data internationally, we will ensure suitable safeguards such as UK International Data Transfer Agreements (IDTA) or EU Standard Contractual Clauses (SCCs).

10) Changes

We may update this Privacy Policy. Material changes will be notified to Organisation admins through the admin portal, and the updated version posted here with a new “Last updated” date.

11) Contact

Questions or concerns about privacy? Email [email protected].