Privacy Policy

1. Who we are

AXE is an online learning platform operated by AIENAI (“AIENAI”, “we”, “us” or “our”). AIENAI is the data controller responsible for your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

• Legal entity: AIENAI Limited, registered in England and Wales under company number [company number].
• Registered office: Ashmic Suite 220 17 Holywell Hill, St. Albans, Hertfordshire, AL1 1DT.
• ICO registration: ZC191315.

We operate in the UK with a subsidiary team in Nigeria. Questions about this policy or your data can be sent to academy@aienai.co.

2. Who this policy covers

This policy applies to everyone who uses AXE, including learners, tutors and facilitators, and staff of organisations that run their courses on the platform. Where an organisation (for example a school or employer) enrols you on a course, that organisation may also be a controller of your data for its own purposes; this policy covers only AIENAI’s handling of your data.

3. Information we collect

Information you give us

• Account details: your name, email address and password, and your role (learner, tutor or organisation staff).
• Profile information: optional details such as a display name, avatar, bio, interests and learning goals.
• Learning content you create: quiz answers, submitted assignments, project work, notebook entries, forum posts and support issues, including any images or video you upload.
• Support and communications: messages you send us or your facilitators, and the contents of support issues you log.

Information we collect automatically

• Usage data: lessons opened, progress, scores, XP and activity timestamps used to run the learning experience.
• Device and technical data: IP address, browser type and similar information collected through cookies and comparable technologies.

Information from third parties

• Sign-in providers: if you sign in with Google, we receive basic profile information from that provider.
• Payments: when you buy a course, our payment processor confirms the transaction to us. We do not store your full card details.

4. How and why we use your data

We use personal data to:

• create and manage your account and deliver the courses you are enrolled on;
• track progress, award XP and issue certificates;
• enable forums, teams, live classes and the support-issue channel;
• process payments and prevent fraud;
• respond to your enquiries and provide support;
• keep the platform secure and improve how it works;
• send service messages, and, where permitted, occasional updates you can opt out of.

5. Our lawful bases

Under the UK GDPR we rely on the following lawful bases:

• Contract: to provide the platform and the courses you sign up for.
• Legitimate interests: to secure, maintain and improve the service, where this is not overridden by your rights.
• Consent: for optional cookies and any marketing communications, which you can withdraw at any time.
• Legal obligation: to meet our accounting, tax and regulatory duties.

6. Sharing your data

We do not sell your personal data. We share it only with service providers who process it on our behalf under contract, and only as needed to run AXE. These currently include providers for cloud hosting and databases, application hosting, payment processing and authentication. Where a course is run by an organisation, relevant learning data (such as progress, submissions and support issues) is visible to that organisation’s tutors and admins. We may also disclose data where required by law.

7. International transfers

Some of our providers and our Nigeria-based team may process data outside the UK. Where we transfer personal data internationally, we put appropriate safeguards in place, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or rely on a valid adequacy decision.

8. How long we keep it

We keep personal data for as long as your account is active and for as long as needed to provide the service, then for any period required to meet legal, accounting or dispute obligations. Learning records such as certificates may be retained longer so that achievements can be verified. When data is no longer needed we delete or anonymise it.

9. Children and young people

Some AXE programmes, such as Teen UX, are designed for learners aged 13 to 17. Where a learner is under 18 we take extra care in line with the ICO’s Age Appropriate Design Code, collect only what is needed, and, where required, seek verifiable consent from a parent or guardian. AXE is not intended for children under 13. See our children’s privacy notice for more detail. If you believe a child has given us data without the right consent, contact academy@aienai.co and we will remove it.

10. Security

We use technical and organisational measures to protect your data, including encryption in transit, access controls and tenant-level isolation of each organisation’s data. No system is completely secure, but we work to protect your information and will notify you and the relevant authority of a breach where the law requires.

11. Cookies

We use cookies and similar technologies to keep you signed in, remember your preferences and understand how the platform is used. You can control non-essential cookies through your browser settings and any cookie controls we provide.

12. Your rights

Under UK data protection law you have the right to:

• access the personal data we hold about you;
• ask us to correct inaccurate or incomplete data;
• ask us to erase your data in certain circumstances;
• restrict or object to how we use your data;
• request a copy of your data in a portable format;
• withdraw consent where we rely on it.

To exercise any of these, email academy@aienai.co. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk, though we would welcome the chance to resolve your concern first.

13. Changes to this policy

We may update this policy from time to time. When we make significant changes we will update the date above and, where appropriate, tell you through the platform.

14. Contact us

For any privacy question or request, contact us at academy@aienai.co.