Thrive Learning Privacy Policy

Last updated: 16/12/25

Thrive Learning Limited is committed to protecting your privacy and being transparent about how we handle personal data. This Privacy Policy explains how we collect, use and protect information across all Thrive Learning services and products. It is written in clear and simple language so you can understand exactly what we do and why.

Thrive Learning Limited is incorporated in England under company number 10988277. Our registered office address is 27 Market Place, Bingham, Nottingham, NG13 8JY. You can contact us at privacy@thrivelearning.com.

1. Who this policy applies to

This Privacy Policy applies to anyone who interacts with any Thrive Learning services or products, including:

  • People who use the Thrive Platform
  • People who use Thrive mobile applications
  • People who use the WomenIn instance of the platform
  • Individuals who take part in usability testing
  • Employees of our customers and suppliers
  • Employees of prospective customers

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Different sections of this policy apply to different groups. The sections are clearly marked so you can see which areas are relevant to you.

2. Our role and how we handle personal data

Thrive acts in two different roles depending on how our products and services are used.

When we act as a processor

For most use of the Thrive Platform, we process personal data on behalf of our customers. This includes:

  • Information uploaded by customers
  • Information about users that customers invite to the platform
  • Usage data generated through interaction with the platform

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In these situations, the customer is the controller. They decide what data is collected, how it is used and how long it is kept. Customers are responsible for giving notice to users and collecting any required consents. We only process this information according to our agreements with customers.

When we act as a controller

We act as a controller when we:

  • Provide the WomenIn instance of the platform, where data is processed with user consent
  • Carry out usability testing
  • Hold contact details for employees of customers, suppliers and prospective customers
  • Process information for our own business operations such as marketing, relationship management and communication

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In these situations, we decide how personal data is used and are responsible for giving you the explanations in this policy.

3. Information we collect

The type of information we collect depends on how you use our products and services. We may collect the following categories of personal data.

3.1 Thrive Platform users

This includes use of the Thrive Learning Platform, Thrive mobile apps and any connected services.

We may collect:

  • Name
  • Email address
  • Profile information
  • Job title and organisational details
  • User generated content
  • Skills, preferences and interests
  • Course progress, completions and interactions with content
  • Activity logs such as files viewed, access times, browser information, IP address and device details
  • Information about how you use the platform, including recommendations and analytics
  • Single sign on details, such as your name or email address shared by your identity provider
  • Additional customer fields may be included by your employer. 

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If you use the mobile app, we may also collect:

  • City level location information
  • Device model, OS version and a device identifier
  • App usage events

3.2 WomenIn instance

When you use the WomenIn instance, Thrive acts as a controller and processes data with your consent.

We may collect:

  • Your profile details
  • Your activity within the instance
  • Any content you create or share
  • Logging and device information similar to the main platform

3.3 Usability testing participants

If you sign up to take part in usability studies, we may collect:

  • Name
  • Email address
  • Occupation and industry
  • Year of birth
  • Information about your internet use
  • Notes taken during testing sessions
  • Recordings of your screen or conversation where you have agreed to this

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Any notes we retain are anonymised and no longer identify you.

3.4 Employees of customers, suppliers and prospective customers

We may process:

  • Your name
  • Your work contact information
  • Your role
  • Information needed to communicate with your organisation
  • Information used for marketing material where you have agreed to appear in it

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This information is used to support communication, relationship management and the delivery of products or services to your organisation.

4. How we use personal data

We use personal data for the following purposes.

4.1 To provide and improve the Thrive Platform

This includes:

  • Operating and maintaining the platform
  • Supporting your organisation, including resolving technical issues
  • Generating personalised recommendations using AI driven features
  • Sending system notifications
  • Enabling features such as learning pathways, mentoring, skills development and content creation
  • Improving how the platform works based on analytics and insights

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4.2 To support our customers

We may use data to:

  • Respond to support requests
  • Detect, prevent and resolve security issues
  • Maintain service quality
  • Help customers understand engagement and performance

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4.3 To manage the WomenIn instance

Data is processed for the operation of the instance and to deliver its features and user experience. Processing is based on your consent.

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4.4 To conduct usability testing

We use information from volunteer testers to:

  • Organise test sessions
  • Analyse how people use new or existing features
  • Improve the design and usability of Thrive products

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4.5 To communicate with customers, suppliers and prospective customers

We process business contact information to:

  • Manage relationships
  • Respond to enquiries
  • Share information about services
  • Maintain accurate records

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Where you appear in marketing material, this is based on our legitimate interest in promoting our services.

4.6 AI-driven recommendations and profiling

Thrive uses AI-driven features to provide personalised learning recommendations, insights and content suggestions. These features may involve automated analysis of user activity, learning behaviour, skills data and preferences, which may be considered profiling under data protection law.

This profiling is used solely to:

  • Recommend relevant learning content or pathways

  • Improve engagement and user experience

  • Support skills development and learning outcomes

Thrive does not use AI-driven profiling to make automated decisions that produce legal effects or similarly significant impacts on individuals.

All recommendations are intended to support learning and development and do not:

  • Affect employment decisions
  • Result in disciplinary action
  • Determine access to essential services or benefits
  • Replace human decision-making by customers

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Customers remain responsible for how learning insights are interpreted or used within their organisations.

5. Legal bases for processing

We rely on the following lawful bases:

  • Contract: when processing is needed to deliver services to customers or to support platform functionality
  • Legitimate interests: for communicating with customer and supplier employees, promoting our services and improving our products
  • Consent: for the WomenIn instance and for usability testing participants
  • Legal obligation: where we need to retain information for accounting or reporting requirements

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6. Sharing information and international transfers

We may share information with selected service providers who help us operate the platform or deliver our services. These include hosting providers, communication services and security partners.

Some of these providers are located outside the UK or EEA. Where this happens, we ensure that appropriate safeguards are in place to protect your data. This may include standard contractual clauses or assessments of adequate protection.

We do not sell any personal data.

7. Security

We take reasonable technical and organisational steps to keep personal data secure. This includes secure hosting environments, access controls, encryption where appropriate and continuous monitoring for vulnerabilities. Please see our trust centre for further information. trust.thrivelearning.com

8. Data retention

Retention periods vary depending on the type of information.

  • Platform data is retained for as long as the customer remains an active subscriber. Data is deleted following termination or upon a customer’s written request.
  • WomenIn data is kept while you are an active user and deleted after 6 months of inactivity or upon request.
  • Usability testing data is kept for 12 months from the date you gave consent. Screen recordings are kept for no longer than 2 months.
  • Information about employees of customers and prospective customers is kept for up to 5 years. Information used in marketing material may be kept for up to 10 years.

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9. Cookies

We use cookies to operate the platform and to help us understand how it is used. These include:

  • Strictly necessary cookies to support core functions
  • Functional cookies that remember preferences or enhance your experience

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10. Your rights

You have the following rights in relation to your personal data:

  • The right to access your personal data
  • The right to request correction of inaccurate information
  • The right to request deletion in certain circumstances
  • The right to restrict or object to processing
  • The right to request your data in a structured, machine readable format
  • The right to withdraw consent when we rely on it

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If we act as a processor, you should contact your organisation to exercise your rights, as they control your data.

If you are a WomenIn user, a usability testing participant or an employee of a customer or supplier, you can exercise your rights by contacting privacy@thrivelearning.com.

You can also raise concerns with the Information Commissioner’s Office if you are unhappy with how we handle your information.

11. Contact us

If you have any questions or would like to exercise your rights, you can contact us at: privacy@thrivelearning.com

‍Thrive Learning Limited, 27 Market Place, Bingham, Nottingham, NG13 8JY