Modular Learning Ltd | Company number: 17257897
Registered office: Irish Square, Upper Denbigh Road, St Asaph, Denbighshire, United Kingdom, LL17 0RN
Version 1.0 - June 2026
Modular Learning Ltd ("MLL", "we", "us", "our") operates the Modular Learning Platform (the "Platform"), available at app.modular-learning.co.uk and associated portals.
MLL is the data controller for personal data collected through the Platform. In certain circumstances we also act as a data processor on behalf of employer organisations - see section 6.
We are not required to appoint a Data Protection Officer.
When you register and use the Platform as a learner, we collect:
When you register or use an Employer Account, we collect:
Payment card data is collected and processed directly by Stripe. MLL does not store card numbers or payment authentication data.
Where an employer organisation registers staff on the Platform, MLL receives personal data about those individuals (name, email address, and role) from the employer rather than directly from the individual. The employer is responsible for ensuring it has a lawful basis to provide that data to MLL.
Standard server logs and analytics tools may record IP addresses, browser types, pages visited, and referral sources when you access the Platform. This data is used for operational and analytical purposes.
| Purpose | Legal basis |
|---|---|
| Delivering the Platform service | Performance of a contract |
| Processing payments | Performance of a contract |
| Issuing certificates of completion | Performance of a contract |
| Maintaining training and compliance records | Legitimate interests |
| Making training records visible to linked employer accounts | Performance of a contract / Legitimate interests |
| Sending service communications (renewal reminders, completion notifications, account updates) | Performance of a contract / Legitimate interests |
| Improving Platform content and functionality | Legitimate interests |
| Internal analytics, benchmarking, and product development | Legitimate interests |
| Commercial data use, including aggregated analytics and business development | Legitimate interests |
| Complying with legal obligations | Legal obligation |
Our legitimate interests include: operating and developing the Platform as a commercial product; maintaining records that learners and employers may rely on for regulatory inspection purposes; and using data to improve and grow the business.
We use the data we collect for the purposes described in section 3 and may also:
Anonymised or aggregated data - from which individual persons cannot reasonably be identified - is not personal data and may be used and shared without restriction.
Service providers acting on our instruction:
Employer Accounts:
If you are a learner linked to an Employer Account, that employer can see your training activity as described in the Learner Terms and Conditions. Employers may see modules you purchased personally as well as modules purchased on your behalf. You can sever your link with an employer at any time via your account settings.
Professional advisers:
We may share personal data with our lawyers, accountants, auditors, and other professional advisers where necessary in the ordinary course of business.
Regulators and law enforcement:
We may disclose personal data where required by law, court order, or a regulatory authority.
Acquirers and successors:
If MLL is sold, merged, or restructured, personal data held on the Platform may be transferred to the acquirer or successor entity as part of that transaction.
MLL is the data controller for account registration data, authentication credentials, Platform analytics, and billing records.
Where MLL processes personal data about an organisation's employees on that organisation's instruction - for example, maintaining completion records for learners linked to an Employer Account - MLL acts as a data processor for that processing. The employer organisation is a separate data controller for its decision to register staff on the Platform and its access to their records.
A Data Processing Agreement (DPA) setting out MLL's obligations as a processor is available on request.
Some of our service providers operate outside the UK. Where personal data is transferred outside the UK, we rely on appropriate transfer mechanisms, which may include UK adequacy regulations, the UK International Data Transfer Agreement (IDTA), or equivalent standard contractual clauses, depending on the destination country and provider.
Service providers that may process data outside the UK include Stripe (United States) and our hosting and infrastructure providers. Details of the safeguards in place are available on request.
Training records, completion data, and certificates are retained indefinitely. The sectors we serve are subject to regulatory inspection requirements and training history may need to be evidenced years or decades after completion.
Account and contact data is retained for as long as your account is active and for up to six years after account closure, reflecting standard legal limitation periods, or longer where required by applicable law.
Billing records are retained for the period required by law.
Where you request erasure of your data (see section 9), we will assess the request individually. We will not delete data where we have an overriding legitimate interest or legal obligation to retain it, including where deletion would remove records relevant to a current or foreseeable regulatory inspection.
Under UK data protection law you have the following rights in relation to your personal data:
To exercise any of these rights, contact customer support. We will respond within one month.
If you object to receiving marketing communications, you may opt out at any time by contacting us or using any unsubscribe link in our emails.
Module pass/fail outcomes are determined automatically by the Platform based on quiz scores. This is a feature of the training product and does not constitute automated decision-making that has a legal or similarly significant effect on you.
The Platform uses cookies to operate. These include:
Further information about specific cookies used is available on request.
We may update this Privacy Notice at any time. The current version will always be available at app.modular-learning.co.uk/privacy. We will notify registered users of material changes by email or Platform notification where practicable.
If you have concerns about how we handle your personal data, contact customer support in the first instance.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk