DC-LEARN · LEGACY BUSINESS ENGINEERS LTD

Plain English Summary

We collect as little data as possible. Free modules need no account. If you choose to use the AI tutor, or to create a free certificate, we process what you type, as set out below. Paid access requires an email and payment (processed by Stripe, not stored by us). We don't sell your data to anyone. We use cookies only for essential functionality and to record how the course is used, as set out below.

1. Who We Are

Legacy Business Engineers Ltd (CRO: 720301), 15 Palmers Crescent, The Manor, Dublin 20, D20 DP71, Ireland is the data controller for DC-LEARN. Contact: lmurphy@legacybe.ie.

2. What Data We Collect

Free tier users: Free modules can be used without registration. If you use the AI tutor or create a free certificate, we process what you type, as set out below.

Paid tier users: We collect your name, email address, and purchase record. Payment card details are processed and stored by Stripe — we never see or store your full card number.

All users: We record how the course is used (pages and tabs visited, time spent, assessment attempts, whether you are on a phone, tablet or computer, your answers to the optional rating questions, and on the field challenges whether you wrote a call before the fix and how you marked it against the fix — never the sentence itself, which stays on your device). These records are first kept on your own device. If you are signed in, they are uploaded and stored with your account number so we can show your progress. If you are not signed in, they stay on your device and are not sent to us. If you later sign in on the same device, the records kept on it since your last visit, including any made before you signed in, are uploaded with your account at that moment. Clearing your browser storage before you sign in removes them. We do not use tracking pixels, retargeting, or behavioural advertising.

Free certificate: If you create a free certificate, we store the name you enter to issue and verify it. The form also asks for a work email address; it is checked on your device for a valid format and is not sent to us or stored.

AI tutor: Your questions to the tutor are sent to Anthropic, our AI provider, to write the answer. The first part of each question is kept, without your name or account, to improve the course. Please do not type personal details.

Limits that stop misuse: To stop the free tutor and the certificates being misused, each request records a scrambled code made from your internet address, never the address itself. The code is made with a secret that changes every day, so it cannot be turned back into your address or used to follow you from one day to the next. We use it only to count requests, and we delete it after 7 days. If you are signed in, the tutor counts your requests against a scrambled form of your account number instead.

Certificate test: When you ask for a Completion or Achievement certificate, your test answers are sent to our server so it can mark them itself. We keep the score and the three part-scores on your certificate record. We do not keep the answers.

3. Why We Process Your Data

We process personal data on the following legal bases under GDPR:

4. Who We Share Data With

We share data only with processors required to deliver the service:

Voice typing. Some exercises offer an optional Speak button. It uses your own browser's speech service to turn your voice into text: in Chrome and Edge the browser sends the sound to Google or Microsoft to do that, under their own terms. We do not receive or keep the audio. If you would rather not, type instead.

We do not sell, rent, or share your personal data with any third party for marketing purposes.

5. Data Retention

Account data is retained for the duration of your licence plus 6 years (Irish tax requirement). Anonymous analytics data is retained for 26 months. You may request deletion of your personal data at any time by contacting us.

6. Your Rights

Under GDPR, you have the right to access, rectify, erase, restrict processing, port your data, and object to processing. To exercise any of these rights, email lmurphy@legacybe.ie. We will respond within 30 days.

You may also lodge a complaint with the Data Protection Commission (Ireland).

7. International Transfers

Some processors (Stripe, Supabase, Anthropic) may process data outside the EEA. Where this occurs, it is subject to Standard Contractual Clauses or equivalent safeguards under GDPR.

8. Changes

We may update this policy from time to time. The "Last updated" date at the top of this page will change. Material changes will be communicated to registered users by email.