Privacy Policy

Scope of this Privacy Policy

This Privacy Policy explains how ExelAcademy Online collects, uses, stores, and protects personal data relating to learners and their parents or guardians (Parents) in the course of providing its educational programmes and services.

1. Introduction

ExelAcademy Online operates a digital learning environment designed to support learners through structured academic instruction, mentorship, and project-based learning.

In delivering educational services, ExelAcademy Online processes personal data relating to learners, parents or guardians, staff, and other individuals who interact with our programmes and systems.

This policy explains:

• what personal data we collect
• how and why we process it
• the legal basis for processing
• how data is protected
• the rights individuals have regarding their personal data

For the purposes of applicable data protection legislation, the data controller is: ExelAcademy Online. Exel Academy is a division of UConnect AI Limited (registered company number: 16742288).

If you have any questions about the content of this notice you can contact us at: dpo@exelacademy.ai

Contact address: PO Box 4385, 16742288, Cardiff, CF14 8LH, United Kingdom.

3. Types of Personal Data We Collect

ExelAcademy Online may collect and process the following categories of personal data.

Learner information

• Name
• date of birth
• ethnicity, gender
• health and medical conditions
• disabilities and special educational needs
• safeguarding information
• contact details and country of domicile
• parent contact and financial information
• educational history

Educational records

• assignments and submitted work
• academic progress and mastery data
• assessment outcomes
• learning activity records

Engagement data

• participation in learning activities
• platform usage related to educational activity
• mentor feedback and review notes

Communication records

• messages between staff, mentors, learners, and parents
• enquiries submitted through the website or email

Technical information

• login and account access data
• device or platform usage information necessary for system operation

4. Educational Data and Learning Platform Processing

Personal data generated through the learner enrolment process, participation in learning activities within ExelAcademy Online, including academic progress data, assignments, mentor feedback, learning analytics, and records of learner engagement, is processed solely for the purpose of delivering and supporting educational provision.

Personal data may also be received from statutory agencies and from the learner's previous places of education.

This information forms part of a learner's educational record and is used by authorised ExelAcademy Online staff and systems to support teaching, mentorship, safeguarding, academic assessment, and programme coordination.

Access to this data is restricted to authorised personnel and approved systems that are required to support the educational functions of ExelAcademy Online. Appropriate safeguards are applied to ensure that learner information is handled securely and in accordance with applicable data protection legislation.

Automated systems used within ExelAcademy Online to support learning activities operate under defined human oversight and do not make independent decisions regarding learner progression, safeguarding matters, or other significant educational outcomes.

5. How Personal Data Is Used

Personal data may be used by ExelAcademy Online for the following purposes:

• Confirming the identity of prospective learners and their parents
• delivering educational programmes
• monitoring academic progress
• coordinating mentorship and learner support
• safeguarding and welfare monitoring
• communicating with parents or guardians
• maintaining records of participation and achievement
• administering enrolment and programme access
• responding to enquiries and service requests

Where communication systems are used to send updates about programmes or services, this will be conducted in accordance with applicable communications regulations.

6. Legal Basis for Processing

ExelAcademy Online processes personal data on the following legal bases where applicable.

Educational provision and legitimate interests — Processing necessary to deliver educational services, maintain the operation of ExelAcademy Online learning programmes, to enable learners to take part in national or other external assessments, and to promote diversity and equality.

Contractual necessity — Processing necessary to fulfil enrolment agreements with learners or parents.

Legal obligations — Processing required to comply with legal responsibilities relating to safeguarding, record keeping, prevention, detection and investigation of crime as well as regulatory requirements such as compliance with anti-money laundering laws.

Consent — Where specific processing activities require consent, such consent will be requested and may be withdrawn at any time.

7. Data Sharing

Personal data may be shared only where necessary with:

• authorised staff and mentors
• approved technology providers supporting the learning platform
• safeguarding authorities where required
• external health professionals such as educational psychologists
• professional advisors (e.g. lawyers)
• regulatory or legal authorities where legally required

All third-party service providers used by ExelAcademy Online are required to process personal data in accordance with applicable data protection laws and contractual safeguards.

8. International Data Transfers

Because ExelAcademy Online operates digitally and serves internationally located learners, personal data may be processed or stored using technology providers operating in multiple jurisdictions.

Where personal data is transferred outside the United Kingdom or applicable data protection jurisdictions, ExelAcademy Online ensures that appropriate safeguards are applied. These may include:

• recognised adequacy decisions
• standard contractual clauses
• equivalent legal protection mechanisms

These safeguards are intended to ensure that personal data remains protected in accordance with applicable data protection standards.

9. Data Retention

To comply with legal and safeguarding obligations, personal data of learners and their parents will be kept for 7 years after they leave ExelAcademy Online or until their 25th birthday, whichever is later.

Academic data of learners is kept for longer periods of time for research, statistical and reporting purposes and data minimisation procedures are followed.

10. Data Security

ExelAcademy Online implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure.

These measures may include:

• secure authentication systems
• access control and user permissions
• encrypted communication where appropriate
• monitoring and review of platform access

Only authorised personnel and systems are permitted to access learner information where required for legitimate educational purposes.

11. Individual Rights

Individuals whose data is processed by ExelAcademy Online may have rights under applicable data protection legislation. These rights allow individuals to understand how their information is used and to request action where appropriate.

Your right to be informed — Individuals have the right to receive clear information about how ExelAcademy Online collects and uses personal data. This Privacy Policy forms part of that commitment and explains how learner and parent information is handled.

Your right of access — Individuals may request confirmation of whether ExelAcademy Online holds personal data about them and may request access to that information, together with an explanation of how it is being used.

Your right to rectification — If personal data held by ExelAcademy Online is inaccurate or incomplete, individuals may request that the information be corrected or updated.

Your right to erasure — In certain circumstances, individuals may request that personal data be deleted where there is no longer a lawful basis for its continued processing.

Your right to restriction of processing — Individuals may request that the processing of their personal data be limited in certain situations, for example while a concern about accuracy or lawful use is being reviewed.

Your right to object to processing — Individuals may object to the processing of their personal data where the processing is based on legitimate interests or where it relates to certain forms of communication.

Your right to data portability — Individuals may request a copy of their personal data in a structured and commonly used format.

Your rights around automated decision making and profiling — Individuals have the right not to be subject to decisions based solely on automated processing where those decisions produce significant effects for them. ExelAcademy Online does not rely on automated systems to make independent decisions about learner progression, safeguarding matters, or other significant educational outcomes. Where automated systems are used to support learning activity, they operate under defined human oversight.

Requests relating to personal data rights should be directed to the Data Protection Officer: dpo@exelacademy.ai

Individuals also have the right to lodge a complaint with the Information Commissioner's Office, UK: https://ico.org.uk/global/contact-us/

12. Policy Governance and Review

This policy is approved and maintained by ExelAcademy Online as part of its governance framework.

Policy Owner	Tirzah Elese, ExelAcademy Online
Next Review Date	04/08/2026

This policy will be reviewed periodically to ensure it remains aligned with applicable data protection legislation, educational practice, and the operational systems used by ExelAcademy Online.

Cookies Policy

Scope of this Cookie Policy

This Cookie Policy explains how ExelAcademy Online collects, uses, and stores cookies in relation to learners and their parents or guardians as part of delivering its educational programmes and services.

What are cookies?

A cookie is a small text file that is placed on a user's device or computer by a website. Cookies serve different purposes. Some are essential to the operation of a website, while others support functionality, performance, or user experience. Each cookie has a defined role in enabling the website to function effectively and securely.

The cookies we use

The cookies we use on the website are:

Moodle is the technology used to host the ExelAcademy learning platform and website. Moodle uses the following cookies:

When you first visit the website, you are given the option to accept or decline non-essential cookies. This preference can be updated at any time through the cookie settings available on the site. A cookie is used to record your cookie preferences. Where consent has been provided, this record is stored on your device so that your preferences can be recognised on future visits.

(i) An essential session cookie, typically referred to as "MoodleSession", is required for the platform to function correctly. This cookie enables continuity between pages and allows users to remain logged in while navigating the site. When you log out or close your browser, this cookie is automatically removed.

(ii) A further cookie, commonly referred to as "MOODLEID" or similar, is used for convenience. It stores the username within the browser so that it can be pre-filled on subsequent visits. This cookie is optional and can be declined. If it is not accepted, users will be required to enter their username each time they log in.

More information on Cookies

For more information about cookies and why websites use them, please visit https://www.aboutcookies.org.uk/cookies

Policy Governance and Review

This policy is approved and maintained by ExelAcademy Online as part of its governance framework.

Policy Owner	Tirzah Elese, ExelAcademy Online
Next Review Date	04/08/2026

This policy will be reviewed periodically to ensure it remains aligned with applicable data protection legislation, educational practice, and the operational systems used by ExelAcademy Online.