Privacy Policy
Last updated: [REPLACE WITH DATE OF YOUR LAST POLICY REVIEW]
1. Information We Collect
We collect information you provide directly: name, email address, company name, and role when you create an account. We also collect usage data such as pages visited, courses started, and feature interactions to improve the learning experience.
2. How We Use Your Data
Your data is used to provide and improve the Ascend service, personalise learning recommendations, generate analytics for L&D administrators, and communicate product updates. We never sell personal data to third parties.
3. Data Retention
We retain account data for as long as your organisation maintains an active subscription. Upon cancellation, data is retained for 90 days to allow for reactivation, then permanently deleted. Learner progress data can be exported at any time via CSV or API.
4. Data Security
All data is encrypted in transit (TLS 1.3) and at rest (AES-256). We maintain SOC 2 Type II compliance and undergo annual third-party penetration testing. Data is stored in EU (Frankfurt) or US (Virginia) data centres based on your preference.
5. Your Rights
Under GDPR, you have the right to access your personal data, the right to rectify inaccurate data, the right to delete your data, the right to restrict processing, the right to data portability, the right to object to processing, the right not to be subject to a decision based solely on automated processing — including profiling — that produces legal or similarly significant effects (GDPR Art. 22; you may request human review, contest the decision, and express your point of view), and the right to lodge a complaint with a supervisory authority. Contact privacy@ascend.io to exercise any of these rights. We respond to all requests within 30 days.
6. Your Rights — California & US State Privacy Laws
If you are a resident of California (CCPA/CPRA), Colorado, Connecticut, Texas, Virginia, Oregon, or another US state with a comprehensive consumer-privacy law, you have the following rights, subject to certain exceptions: Right to Know / Access — you may request the categories and specific pieces of personal information we have collected about you, the sources of that information, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it. Right to Delete — you may request deletion of the personal information we have collected from you, subject to our legal retention obligations. Right to Correct — you may request correction of inaccurate personal information we maintain about you. Right to Opt Out of Sale or Sharing — we do not sell your personal information for money. If we share personal information for cross-context behavioural advertising, you may opt out at any time via our "Do Not Sell or Share My Personal Information" page (linked in the footer where applicable). We also recognise the Global Privacy Control (GPC) signal as an opt-out, as described in our Do Not Track and Global Privacy Control section. Right to Limit Use of Sensitive Personal Information — where we process sensitive personal information, you may direct us to limit its use to that which is necessary to provide the Service. Right to Non-Discrimination — we will not discriminate or retaliate against you for exercising any of these rights. To exercise these rights, contact us at privacy@ascend.io or use the "Do Not Sell or Share My Personal Information" page. We may need to verify your identity before responding, and you may use an authorised agent. We respond to verifiable requests to know, delete, or correct within 45 days (extendable by a further 45 days where reasonably necessary). Requests to opt out of sale or sharing, or to limit the use of sensitive personal information, are honoured as soon as feasible and no later than 15 business days, consistent with our Do Not Sell or Share My Personal Information page.
7. Do Not Track and Global Privacy Control
We honour Global Privacy Control (GPC) where legally required. We do not currently respond to Do Not Track (DNT) browser signals because no common technical standard defines how websites should interpret them.
8. Cookies
We use essential cookies for authentication and preferences. Analytics cookies (opt-in) help us understand usage patterns. We do not use advertising cookies or share cookie data with third parties.
9. Contact
For privacy inquiries, contact our Data Protection Officer at privacy@ascend.io. The current registered address is shown in the footer (see SITE_CONFIG.legalEntity.registeredAddress — buyer must replace the placeholder with their real address before publishing).