PRIVACY POLICY

Welcome to workearly.com (the “Website”).

WORKEARLY LTD, a company registered in England and Wales with registered office at 156a Burnt Oak Broadway, Edgware, England, HA8 0AX and company registration number 11762980 (“WORKEARLY”, “we”, “us” or “our”), is the controller of your personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and other applicable UK data protection legislation.

This Privacy Policy explains what personal data we collect and use, the purposes and lawful bases for processing, who we may share your personal data with, how long we retain it, and the rights available to you.

1. What personal data do we process?

Depending on how you use the Website and WORKEARLY’s services, we may process the following categories of personal data:

1.1 When you browse the Website

When you visit the Website, we may collect technical information such as your IP address, the date and time of your visit, browser and operating system type, device model or type, and other information collected through cookies and similar technologies relating to your use of and interaction with the Website.

For more information about our use of cookies and similar technologies, please see our Cookie Policy.

1.2 When you create and use an Account

When you create or use an Account on the WORKEARLY Educational Platform, we may collect identification and contact details, such as your name and email address, as well as information relating to the creation, operation and use of your Account.

We may also process technical and activity data relating to your use of the Educational Platform where necessary for the operation, security and support of your Account and the related services.

1.3 When you submit a Free Profile Assessment request

When you submit a Free Profile Assessment request, we collect your name, email address, telephone number and information relating to your professional profile, career goals and preferences that you provide as part of the relevant service.

1.4 When you contact WORKEARLY

When you contact us through a contact form or another official communication channel, we may collect your name, email address and/or telephone number, together with any information you include in your request or communication.

1.5 When you purchase a Course or other service

When you purchase a Course or another WORKEARLY service, we collect the information necessary to manage your purchase and provide the relevant service, such as your name, email address and information relating to your purchase and transaction.

WORKEARLY does not collect or store full payment card details. Card payments are processed through the secure environment of the relevant payment provider, such as Stripe. In connection with a transaction, we may receive limited payment information, such as the last four (4) digits of your card, transaction status and payment confirmation. Where another available payment method is used, we may receive corresponding information relating to the completion and status of the transaction.

1.6 When you participate in Courses

When you participate in a Course, we may process your name and email address, information relating to your enrolment and participation, progress and completion data, quiz, assessment and examination results, and information relating to certificates, badges, credentials or other completion and performance records associated with the Course.

Where eligibility for a particular benefit, discount or other special offer depends on a specific status or qualification, we may request appropriate supporting documentation.

1.7 When you use WORKEARLY Plus

If you subscribe to WORKEARLY Plus, we may process information relating to your selected Plan, the start and duration of your Subscription, Subscription status, renewal or cancellation, payments and refunds where applicable, as well as information relating to the Credits available to and used by you, the Courses you unlock and the Benefits you use under your Plan.

1.8 Professional Profile, Verified Skills and Credentials

Where your Plan includes a Professional Profile, we may process information displayed on or associated with your professional profile, such as your name, certificates, badges or other credentials obtained through WORKEARLY, Verified Skills, and other information relating to your professional development and use of the relevant services.

Depending on the functionality of the relevant service, you may choose to make your Professional Profile publicly accessible through a unique URL and share it with employers, professional contacts or other third parties.

1.9 Registration and participation in the WORKEARLY Talent Pool

If you register for the WORKEARLY Talent Pool, we may collect and process information relating to your professional profile and search for career opportunities, including identification and contact details, your CV, professional experience, education, qualifications, skills, job preferences and interests, and any other information you choose to include in your profile or CV.

As part of the operation of the Talent Pool, some of this information may be shared with Hiring Partners or other prospective employers in accordance with the functionality of the relevant service and the choices available to you.

1.10 Applying or submitting your CV to a Hiring Partner

Where you choose to apply for a specific career opportunity or request that your CV or professional profile be shared with a specific Hiring Partner, we process the information necessary to manage and transmit your application or expression of interest.

Once your personal data has been provided to the Hiring Partner, that Hiring Partner may process your personal data for its own recruitment purposes in accordance with its own privacy policy and applicable data protection obligations.

1.11 Applying for a position at WORKEARLY

If you apply for a position at WORKEARLY, we process your CV, contact details and other information you provide as part of your application for the purpose of assessing your candidacy.

Further information regarding the processing of candidate personal data may be provided in a separate Candidate Privacy Notice.

1.12 Corporate Training

If you participate in a Course or another WORKEARLY training service through your employer or another corporate customer, we process the personal data necessary to enrol you in and provide the relevant training, including information relating to your participation, progress, completion, assessments and examinations.

The employer or other corporate customer that purchased the relevant training may request from WORKEARLY:

  • information relating to your progress and completion of the Course purchased for you; and

  • results of assessments or examinations relating to that Course.

This information relates exclusively to Courses purchased for you by that employer or corporate customer. Information relating to Courses that you purchase or undertake independently as an individual customer is not shared with your employer as part of the Corporate Training arrangement.

1.13 Mentors

If you participate in the WORKEARLY Network as a Mentor, we may process information relating to your professional identity and status, including your name, photograph, short professional biography, professional experience, qualifications and other information you provide for the creation and display of your Mentor profile.

Certain information, such as your photograph, name and professional biography, may be published on the Website in accordance with the applicable WORKEARLY Network Terms.

1.14 Purchasing or gifting a Gift Card

When you purchase or gift a Gift Card, we may collect the purchaser’s name and email address, together with the recipient information necessary to send or provide the Gift Card.

1.15 Vouchers, discount codes, discounts and other benefits

When you redeem a voucher, discount code, discount or other promotional benefit, we may process your name, email address and, where necessary to verify your eligibility for the relevant benefit, appropriate supporting information or documentation.

1.16 Benefits and Partner Gift Cards

Where you use a Benefit provided through WORKEARLY Plus or another WORKEARLY service, we may process information relating to the Benefit provided to or used by you.

Where the provision of a particular Benefit requires personal data to be shared with a third-party partner, we will provide you with the relevant information, where required, before such sharing takes place.

1.17 Competitions, Giveaways and promotional activities

When you participate in a WORKEARLY competition, Giveaway or other promotional activity, we may process identification and contact details, information you submit through the relevant participation form, information relating to your participation, and data necessary to select, contact and verify winners and provide the relevant prize or benefit.

Where the relevant activity involves the creation of an Account, free access to a Course or another WORKEARLY service, we may also process the personal data necessary to provide that service.

Additional information concerning the processing of personal data in connection with a particular competition or Giveaway may be included in the applicable Special Terms and/or a specific privacy notice for that activity.

1.18 Newsletter and other marketing communications

When you subscribe to our Newsletter, we collect your email address and, where provided, your name.

You may withdraw your consent and stop receiving the relevant communications at any time by using the “unsubscribe” option included in our communications or by contacting WORKEARLY using the contact details provided in this Privacy Policy.

2. Why do we process your personal data?

WORKEARLY processes your personal data only where there is a lawful basis for doing so and for the purposes for which the data was collected. Depending on the service you use and the specific processing activity, we may rely on the following lawful bases:

2.1 Legitimate Interests

WORKEARLY may process certain personal data where this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, provided that your interests, fundamental rights and freedoms do not override those interests.

In particular, we may rely on legitimate interests for:

  • ensuring the proper, reliable and secure operation of the Website, Educational Platform, Accounts and our services;

  • preventing and addressing security incidents, fraud, misuse or unauthorised use of our services;

  • maintaining backups and ensuring business continuity;

  • managing communications with you and responding effectively to requests, enquiries or complaints;

  • supporting, managing and improving the operation of our services, where the relevant processing does not require your consent;

  • protecting the rights, property and legitimate interests of WORKEARLY, our users and third parties, and establishing, exercising or defending legal claims; and

  • providing and managing Corporate Training for Participants on behalf of corporate customers, including managing enrolment, participation, progress and completion of the relevant training.

Where we rely on legitimate interests, we consider whether the processing is necessary and balance the relevant interests against your rights and freedoms.

2.2 Consent

Where processing is based on your consent, we use your personal data only for the specific purpose or purposes for which you have given your consent.

In particular, we may ask for your consent:

  • to subscribe you to our Newsletter and send marketing or promotional communications, where consent is required;

  • to use non-essential cookies and similar technologies for analytics, personalisation and/or advertising purposes; and

  • for other specific processing activities where consent is required under applicable law.

Where you subscribe to our Newsletter, we process your email address and, where provided, your name in order to send you WORKEARLY news, updates and other relevant communications.

You may withdraw your consent at any time, without affecting the lawfulness of processing carried out on the basis of your consent before its withdrawal. For email communications, you may also use the “unsubscribe” option included in the relevant communication.

For cookies and similar technologies, you may change your preferences and withdraw your consent at any time through the available cookie settings. Further information is available in our Cookie Policy.

2.3 Performance of a contract or steps before entering into a contract

WORKEARLY may process personal data where the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request before entering into a contract.

Depending on the circumstances, we may rely on this lawful basis for processing necessary to:

  • create and manage your Account;

  • purchase, provide and manage Courses and other WORKEARLY services;

  • enable your participation in Courses, including managing your progress and completion, conducting assessments or examinations, and issuing certificates or other credentials;

  • purchase, activate, manage and renew your WORKEARLY Plus Subscription;

  • manage your Plan, Credits, Unlocked Courses and Benefits included in your Subscription;

  • provide and operate your Professional Profile where this forms part of your Plan;

  • purchase, send or redeem Gift Cards, vouchers, discount codes, discounts or other benefits;

  • manage your participation in WORKEARLY services or features that you have chosen to use, to the extent that the processing is necessary to provide those services or features;

  • register you for and enable your participation in the WORKEARLY Talent Pool and provide the related professional networking and career opportunity services; and

  • manage an application or expression of interest that you choose to submit for a specific career opportunity, including sharing your CV or professional profile with the relevant Hiring Partner or prospective employer where this is necessary to provide the service you have requested.

Where you apply for a position at WORKEARLY, we may also process the personal data you provide in order to take steps at your request before potentially entering into an employment or other professional relationship with you. Further information regarding the processing of candidate personal data may be provided in a separate Candidate Privacy Notice.

2.4 Legal Obligation

WORKEARLY may process personal data where this is necessary to comply with a legal obligation to which we are subject.

This may include processing personal data:

  • to comply with applicable tax, accounting and other statutory obligations relating to transactions and the provision of our services;

  • to manage and respond to requests you make in connection with the exercise of your data protection rights;

  • to comply with lawful requests, decisions or orders from courts, regulatory authorities, law-enforcement agencies or other competent authorities; and

  • to comply with any other legal obligation applicable to WORKEARLY.

3. Who do we share your personal data with?

WORKEARLY does not share your personal data with third parties except where this is necessary to provide our services, fulfil the purposes described in this Privacy Policy, or comply with our legal obligations.

Depending on the services you use, we may share your personal data with the following categories of recipients:

  • technology and support service providers, including hosting, cloud infrastructure, Educational Platform, technical support, security, storage and backup providers;

  • payment and related service providers, where necessary to process and manage transactions, payments, refunds or other related activities;

  • communication, email and marketing service providers, where necessary to send service-related communications or, where permitted, marketing communications;

  • education, certification and credential service providers, where participation in a Course or the issue of a certificate, badge or other credential requires the use of a third-party service;

  • Hiring Partners and other prospective employers, where you choose to apply for an opportunity or share your CV or professional profile with a particular organisation, or as part of your participation in the WORKEARLY Talent Pool, in accordance with the terms and functionality of the relevant service;

  • corporate customers or employers, where you participate in Corporate Training and the relevant corporate customer is entitled to receive specified information relating to your progress, completion, assessments or examinations exclusively in connection with the Course purchased for you;

  • partners providing Benefits or other services, where sharing certain personal data is necessary to provide a Benefit that you have chosen to use;

  • professional advisers, including legal, tax, accounting or other advisers, where access to personal data is necessary for the provision of their services; and

  • courts, regulators, law-enforcement agencies and other competent authorities where disclosure is required or permitted by applicable law.

Where third-party service providers process personal data on behalf of WORKEARLY, they are required to process the data in accordance with our instructions and are subject to appropriate contractual obligations concerning the protection, confidentiality and security of personal data.

In certain circumstances, third-party recipients may process your personal data as independent controllers for their own purposes and in accordance with their own obligations under applicable data protection law. This may apply, for example, to Hiring Partners or other prospective employers that receive your personal data as part of a recruitment process.

WORKEARLY does not sell your personal data to third parties.

4. Do we transfer your personal data outside the UK?

In connection with the provision of our services, some of your personal data may be transferred to, or accessed by, recipients located outside the United Kingdom, for example where we use technology, cloud, payment, communication or other service providers that operate internationally.

Where we make a restricted transfer of personal data outside the UK, we take appropriate steps to ensure that your personal data remains protected in accordance with applicable UK data protection law.

Depending on the circumstances, we may rely on:

  • UK adequacy regulations applicable to the relevant country, territory, sector or international organisation;

  • appropriate safeguards recognised under the UK GDPR, including the UK International Data Transfer Agreement (IDTA) or the UK International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses, where applicable; or

  • another lawful transfer mechanism or exception available under applicable UK data protection law.

Where required, we also carry out the relevant transfer risk assessment or data protection test and implement any additional measures necessary to ensure an appropriate level of protection for the transferred personal data.

For further information about international transfers of your personal data and the safeguards we use, you may contact WORKEARLY using the contact details provided in this Privacy Policy.

5. How do we protect your personal data?

WORKEARLY implements appropriate technical and organisational measures to protect your personal data, taking into account, among other things, the nature and context of the processing, the risks involved and the requirements of applicable data protection law.

These measures are designed to ensure an appropriate level of security and to protect personal data against unauthorised or unlawful access, use, disclosure, alteration, loss or destruction.

Access to personal data is limited to individuals who need such access for the performance of their duties. WORKEARLY personnel and third-party service providers that process personal data on our behalf are, where appropriate, subject to confidentiality obligations and are required to process personal data in accordance with WORKEARLY’s instructions and applicable data protection law.

6. How long do we keep your personal data?

WORKEARLY retains personal data for no longer than is reasonably necessary for the purposes for which it was collected and processed.

The applicable retention period may vary depending on the nature of the personal data, the service concerned, the duration of our relationship with you, and our legal, regulatory, accounting, tax, operational and legitimate business requirements.

Where you maintain an active Account with WORKEARLY, we may retain personal data associated with your Account and your use of WORKEARLY services, including Courses, Subscriptions, Professional Profiles, Talent Pool participation, Corporate Training and other services or features linked to your Account, for as long as your Account remains active.

In determining the appropriate retention period, we take into account, among other things:

  • the period during which you maintain an active Account or continue to use the relevant WORKEARLY service;

  • the duration and nature of our contractual or other relationship with you;

  • whether the data remains necessary to provide, administer or support the relevant service;

  • applicable legal, regulatory, tax and accounting requirements;

  • the need to maintain appropriate records of transactions, Courses, certifications, credentials, subscriptions and other services provided;

  • the establishment, exercise or defence of legal claims;

  • the prevention and investigation of fraud, misuse, security incidents or other unlawful activity; and

  • any applicable limitation periods or requirements of courts, regulators or other competent authorities.

Following the closure or deletion of your Account, we may retain certain personal data for an appropriate period where necessary to comply with legal, regulatory, accounting or tax obligations, maintain appropriate business records, resolve disputes, prevent fraud or misuse, or establish, exercise or defend legal claims.

Where you use a WORKEARLY service without maintaining an Account, we retain the relevant personal data for as long as reasonably necessary to provide and administer the relevant service and for an appropriate period thereafter, taking into account the purposes of the processing and any applicable legal, regulatory or legitimate business requirements.

Personal data relating to transactions, payments, purchases, subscriptions, Gift Cards, Benefits and other commercial activities may be retained for the period necessary to comply with applicable accounting, tax, legal and regulatory requirements.

Personal data relating to recruitment applications, competitions, Giveaways, promotional activities, enquiries and other occasional interactions will be retained for an appropriate period having regard to the purpose of the processing and any subsequent legal, regulatory or legitimate business requirements.

Where personal data is no longer required for the purposes for which it is retained, we will delete or anonymise it in accordance with our applicable retention practices.

7. What are your data protection rights?

Under applicable UK data protection law, and subject to the conditions and exceptions provided by law, you may have the following rights in relation to your personal data:

  • Right of access: you may request confirmation as to whether we process personal data relating to you and, where we do, request access to that personal data and relevant information about how it is processed.

  • Right to rectification: you may request that inaccurate personal data relating to you is corrected or that incomplete personal data is completed.

  • Right to erasure: you may request the deletion of your personal data in the circumstances provided by applicable law.

  • Right to restriction of processing: you may request that we restrict the processing of your personal data in certain circumstances.

  • Right to data portability: where applicable, you may request to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, have that data transmitted to another controller.

  • Right to object: where we process your personal data on the basis of legitimate interests, you may object to that processing on grounds relating to your particular situation. Where your personal data is processed for direct marketing purposes, you may object to such processing at any time.

  • Right to withdraw consent: where we rely on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of your consent before it was withdrawn.

  • Rights relating to automated decision-making: where applicable, you have rights and safeguards in relation to significant decisions made solely by automated processing, including the right to obtain human intervention, make representations and contest the decision, as provided by applicable UK data protection law. 

To exercise any of the above rights, you may contact WORKEARLY using the contact details provided in this Privacy Policy.

We will respond to your request without undue delay and, in any event, within one (1) month of receiving it. Where permitted by applicable law, this period may be extended by up to a further two (2) months, taking into account the complexity and number of requests. If an extension is required, we will inform you within one month of receiving your request.

You will not normally be required to pay a fee to exercise your rights. However, where a request is manifestly unfounded or excessive, in particular because of its repetitive character, WORKEARLY may, where permitted by law, charge a reasonable fee or refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making a request, we may request additional information necessary to confirm their identity.

Where a personal data breach is likely to result in a high risk to your rights and freedoms, WORKEARLY will notify you without undue delay where required by applicable data protection law.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you have concerns about how we process your personal data.

8. How can you contact us about your personal data?

If you have any questions, concerns or requests regarding the processing or protection of your personal data, or if you wish to exercise any of your data protection rights, you can contact WORKEARLY at:

WORKEARLY LTD
156a Burnt Oak Broadway
Edgware, England, HA8 0AX
United Kingdom

Email: personaldata@workearly.com

9. Right to lodge a complaint

If you have concerns about how WORKEARLY processes your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom

Telephone: 0303 123 1113

Further information about your data protection rights and how to make a complaint is available on the ICO website.

10. Changes to this Privacy Policy

WORKEARLY may update this Privacy Policy from time to time to reflect changes to our services, processing activities, legal or regulatory requirements, or other relevant developments.

Where we make material changes to this Privacy Policy, we will take appropriate steps to bring those changes to your attention where required by applicable law.

We encourage you to review this Privacy Policy periodically to stay informed about how we process and protect your personal data.

Last updated: September 2026