Privacy policy

LearningKav Limited ("LearningKav", "we", "us", or "our") provides the LearningKav service — a software application and AI-powered study companion ("Josh") that helps you plan, run, and track your learning across the tools and resources you already use (the "Service"). This Privacy Policy explains how we collect, use, and protect personal data when you use the Service or visit www.learningkav.com (the "Site").

We are a company registered in England and Wales.

• Company: LearningKav Limited
• Company number: 16456384
• Registered office: 5 Friars Place Lane, London, England, W3 7AN
• Contact for privacy matters: joshua@learningkav.com

For most personal data we handle, LearningKav is the controller. Where you use the Service through an organisation (for example, an employer that provides you with a seat), the position is different — see Section 4 (Organisational / team accounts).

We process personal data in accordance with UK data protection law, namely the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR), each as amended (including by the Data (Use and Access) Act 2025).

We collect and process the following categories of personal data:

• Account and identity data: your name, email address, password (stored in hashed form), and any profile details you add.
• Billing data: your billing name and contact details, and subscription/transaction records. Card and payment details are collected and processed directly by our payment provider (Stripe) — we do not receive or store your full card number.
• Your learning content: study goals and plans you create, resources you add to the Service, notes, thoughts, insights, and other content you generate ("Learning Content"), and your activity within Circles (study groups).
• Communications: messages you send us (for example, support requests) and your responses to surveys or feedback requests.

• Usage and activity data: study sessions, progress, completion, streaks, feature usage, and how you interact with the Service.
• Technical data: IP address, device and browser type, operating system, language settings, and similar technical identifiers.
• Cookies and similar technologies: see our separate Cookie Policy.

• Where you connect a third-party tool or content source to the Service, we may receive limited data from that source as needed to provide the feature (for example, calendar availability to schedule study blocks). We only receive what is necessary for the feature you have enabled.

Special category data. No feature of the Service is designed to collect or handle special category data (such as data about your health, race or ethnicity, religion, political opinions, or sexual orientation). Because Learning Content and Circle messages are free-form, please do not enter special category or other sensitive personal information into these fields. Any such information you choose to include is processed only as part of your Learning Content and is not used for any separate purpose.

Where an organisation (for example, your employer or an L&D team) purchases and administers seats on the Service:

• The organisation is the controller of its members' personal data processed through the team account, and LearningKav acts as a processor on the organisation's behalf in respect of that data, under a separate data processing agreement.
• Administrators within the organisation may be able to view certain information about members of their team, including learning activity, progress, completion, engagement signals (including early indications that a member may be falling behind), and evidence of continuing professional development (CPD). This visibility is a core feature of team accounts.
• Your organisation is responsible for informing you about, and having a lawful basis for, its use of the Service and its access to your data. If you have questions about how your organisation uses your data, please contact your organisation directly.
• Separately, LearningKav remains a controller for its own limited purposes, such as account security, billing with the organisation, and improving and securing the Service.

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights. You can ask us for more information about that assessment.

Where we rely on consent (for example, certain marketing or non-essential cookies), you can withdraw it at any time without affecting the lawfulness of processing before withdrawal.

The Service uses automated processing to deliver its core features. In particular, Josh automatically generates and adjusts your study goals, plans, reminders, and revision material based on your activity, progress, and feedback, and, in team accounts, generates engagement signals for administrators.

These features assist you and your administrators; they are not intended to make decisions that produce legal effects concerning you, or similarly significant effects, without human involvement. In an organisational context, administrators remain responsible for exercising their own judgment and should not treat automated signals as decisions in themselves.

AI processing of your content. To provide Josh, Learning Content and related inputs are processed by large-language-model providers acting as our sub-processors — currently OpenAI and Anthropic (Claude) (see Section 8). We use these providers on a data-residency basis under which the relevant data is processed and held in the United Kingdom (London). Under our agreements with these providers, your content is not used to train their models.

If you believe a decision has been made about you based solely on automated processing and you wish to contest it, contact us at joshua@learningkav.com.

We keep personal data only for as long as necessary for the purposes set out above.

• Account and Learning Content: for as long as your account is active, and then deleted or anonymised within 90 days of account closure, unless we need to retain some limited data longer for legal reasons.
• Billing and payment data: we do not store your payment or card data ourselves. Billing is handled by our payment provider, Stripe, which retains transaction records under its own policies and applicable law.
• Support communications: retained for 24 months after your query is resolved.
• Analytics data: retained for 24 months.

For team accounts, retention may also be governed by our agreement with your organisation.

We do not sell your personal data. We share it only as follows:

• Service providers (sub-processors) who process data on our behalf under contract, including for hosting, payments, AI features, email, and analytics.
• Your organisation, where you use a team account (see Section 4).
• Professional advisers, and authorities, where required by law, to comply with legal obligations, or to protect our rights, users, or the Service.
• A buyer or successor, in the event of a merger, acquisition, or sale of assets, subject to appropriate protections.

Our current sub-processors include:

Our application hosting and AI processing take place in the United Kingdom. Some of our other providers are located in the EU (our analytics and email providers), which benefits from UK "adequacy". Our payment provider (Stripe) may process some data in the United States.

Where we transfer personal data outside the UK, we ensure an appropriate safeguard is in place — such as transfer to a country with UK "adequacy" status, or the use of the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with any additional measures required.

You can ask us for more detail about the safeguards we use by contacting joshua@learningkav.com.

We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and hashed password storage. No method of transmission or storage is completely secure, but we work to protect your data and to detect and respond to incidents.

Under UK data protection law you have the right to:

• be informed about how we use your data (this Policy);
• access a copy of your personal data;
• request rectification of inaccurate or incomplete data;
• request erasure of your data in certain circumstances;
• restrict processing in certain circumstances;
• data portability — receive certain data in a portable format;
• object to processing based on legitimate interests, and to direct marketing at any time;
• withdraw consent where we rely on it; and
• not be subject to solely automated decisions producing legal or similarly significant effects (see Section 6).

To exercise any of these rights, contact joshua@learningkav.com. We will respond without undue delay and normally within one month. There is usually no charge, though we may charge a reasonable fee or decline requests that are manifestly unfounded or excessive.

If you use a team account, some requests may need to be directed to, or handled together with, your organisation as controller.

Complaints.If you have a concern, please contact us first so we can try to resolve it. You also have the right to complain to the UK data protection regulator, the Information Commission (formerly the Information Commissioner's Office / ICO): ico.org.uk — helpline 0303 123 1113. Under current UK law you may also raise your complaint directly with us before contacting the regulator.

The Service is intended for users aged 18 and over and is not directed at children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take appropriate steps to delete it.

We may update this Policy from time to time. If we make material changes, we will notify you by email or through the Service before they take effect. The "Last updated" date at the top shows when it was last revised.

Questions about this Policy or your personal data:

LearningKav Limited
5 Friars Place Lane, London, England, W3 7AN
joshua@learningkav.com