Privacy Policy

Table of Contents

1. About the Navigatr Platform

What is the Platform?

The Navigatr Platform is an internet-based platform for adults and young people aged 13 years and above that is hosted and stores data in the UK. The Platform is designed to enable individuals who subscribe to the Service to access digital badges and pathways that connect learning achievements with job opportunities or further learning. Navigatr enables individuals (“Earners”) to receive digital badges and display badges they have online on the Service or on third party sites such as LinkedIn.

What is the purpose of the Platform?

The Platform is designed to promote opportunities to individuals to engage in learning, career progression, skills or personal development, and to recognise their learning and civic participation using digital badges containing skills information. Engagement data in activities and opportunities can be used by Providers and Communities to understand participation in their local offer.

What is a Provider?

A Provider is an organisation, employer or business that provides the Platform content. Content includes; activities, opportunities, or digital badges on the Platform. A Provider could be a local authority, training, education or certification provider, membership organisation, non profit organisation or corporation.

What is a Community?

A “Community” is a collection of “Providers” - organisations that provide learning, training, certifications and employment opportunities for individuals in a city, region or across an institution. Communities can create pathways, badges and activities and opportunity content on the Platform on behalf of Providers.

The community you join may determine the kind of data you're asked to provide. Navigatr is the Data Controller for all processing of personal data that takes place within the Platform. Organisations using Navigatr act as users of the Platform (see Section 5 for details).

Who are we?

The Platform is managed by Navigatr Limited (“Navigatr”) (company no: 11761403) of Navigatr, Castleton Mill, Castleton Close, Leeds, West Yorkshire, LS12 2DS.

2. About the Navigatr privacy policy

Navigatr is committed to data security and the fair and transparent processing of personal data. This privacy policy “Policy” sets out how we will treat the personal data provided to us in compliance with applicable data protection law, in particular the UK General Data Protection Regulation (UK GDPR) and, as applicable, the General Data Protection Regulation (EU) 2016/679 (EU GDPR).

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share your personal data, your rights in relation to your personal data, how to contact us and the supervisory authorities you can report a concern to about the way we process your data.

This Privacy Policy explains how Navigatr processes your personal data and the lawful bases we rely on. Where consent is required, we will ask for it explicitly at the appropriate point.

This Privacy Policy applies to Navigatr's processing of personal data. Organisations using the Platform will provide their own privacy information for any activities or processing they carry out outside the Platform where required.

Children’s privacy

The Platform is not provided to any individual under the age of 13 years and we do not collect personal information from anyone under the age of 13 years. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us using the details provided below under ‘our contact details’.

Terms and definitions we use

Within this Policy, we use the following terms as defined in the data protection legislation which includes but is not limited to GDPR (UK) the Data Protection Act 2018, Privacy and Electronic Communications Regulation (PECR), and any other relevant legislation in place at the time of reading this Privacy Policy:

Changes to our Policy

Any changes we may make to how your data is processed will be included in an updated Privacy Policy made available through the Platform. You will be notified of any changes via email. Please check back frequently to see any updates or changes to our Policy.

3. Surveys on the Platform

Navigatr includes a survey feature that helps measure participation, outcomes, and the impact of learning programmes. You may be asked to complete surveys when you join pathways or programmes. Surveys help organisations understand how well their programmes are working and improve the support they offer.

Your individual survey answers are not shown to organisations at an individual level. Organisations only see anonymised and aggregated statistics (for example, percentages) to help them understand overall outcomes and improve their services.

Separately, organisations may see your name and email as part of normal programme administration (for example, badge delivery). This is unrelated to survey responses.

You can complete surveys directly on the Platform. If you need to change or delete your survey responses, you can contact support at support@navigatr.app.

4. Why Navigatr is collecting data

The Platform is designed to recognise learning and civic participation using digital badges that contain skills information. The Platform highlights what additional or related badges you can engage with on a pathway in order to work towards a destination in employment or further education or training.

In order for us to create and manage your account, provide a personalised experience, display content based on your interests and location and to provide you with the best possible service; we need to collect and use personal information about you.

5. Who are the Data Controllers and Data Processors

Navigatr Limited is the Data Controller for all processing of personal data that takes place within the Navigatr Platform. This includes how data is collected and structured, how surveys and equality monitoring work, how special-category data is segregated and protected, how anonymisation and aggregation are applied, and all access controls, retention rules, and security measures within the Platform.

Organisations using Navigatr act as users of the Platform. Where organisations use the Platform to process personal data as part of delivering their programme (for example, administering badges and pathways), their use of the Platform is governed by our Terms and any applicable data processing agreement.

6. What data is collected

Data you provide to us

When you create an account on the Platform, Navigatr will collect and process the following personal data:

Personal data we collect

To create a user profile on the Platform:

  • First name
  • Last name
  • Email address

To personalise your experience on the Platform:

  • Home address (full address including city and postcode)
  • Date of birth
  • Profile picture

Special category (sensitive) data

We will ask for your explicit consent to collect, store and use special category data (for example, ethnicity, gender and disability or learning difficulties) and other equality monitoring information (for example, age). This data is collected for equality monitoring and reporting purposes to identify barriers to employment and ensure equal access to opportunities.

Providing special category data is completely optional and will not affect your access to the Platform or any pathways. You can choose "prefer not to say" for any question, or choose not to provide this information at all.

You can withdraw your consent and delete your special category data at any time through your account settings. If you have provided special category data as part of survey responses, you can request deletion by contacting support at support@navigatr.app. You can also request deletion of specific survey responses via support while keeping your account and other data intact.

Special category data is:

  • Stored securely and separately from your general profile data
  • Subject to restricted access controls (only authorised Navigatr staff with specific roles can access for support purposes)
  • Never shared in identifiable form with providers, communities, or other organisations
  • Used only to generate anonymised and aggregated insights (aggregated statistics and percentages with no personal data) for reporting purposes
  • Not used for automated decision-making or recommendations

Interest and preference data

We ask you for the following types of information to enable you to have a more personalised experience of the Platform, and to ensure that any activities or opportunities recommended by the Platform will meet your needs or interests:

  • What type of activities/learning style would you like to participate in
  • What type of personal goals you like to achieve
  • What type of career aspirations you have
  • What self-development goals do you want to achieve

Data we collect automatically

If you visit the Platform, Navigatr may automatically collect the following information:

  • Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit to our website such as the credential products you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Data we derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer preferences based on your activity history.

7. Where does the Platform get my data from?

Data you supply

All of the personal and special category data is provided to us directly by you for one of the following reasons and if you:

  • Sign up for a new account on the Platform
  • Join a Community that asks for Special Category data
  • Correspond with us by phone, e-mail, or in writing
  • Report a problem
  • Make a request related to your Data Protection Rights
  • Fill out a form on our website
  • Give consent to receive communications such as e-newsletters from your Community.

Data imported from external sources

In some cases, Navigatr may import data that was originally collected outside the Platform. When this occurs:

  • You will be provided with clear information about the import where reasonably practicable before any data is transferred
  • Data is processed under the same security, access control, and pseudonymisation safeguards as data collected directly on the Platform
  • Pseudonymisation is applied as part of the import process where applicable
  • Imported data is subject to the same data subject rights as data collected on the Platform
  • Imported data follows the same retention policy as data collected on the Platform
  • The raw file used to transfer data to Navigatr is permanently deleted after successful import and processing
  • The purpose of the import will be explained when you are informed about it

8. Who we will share your information with

Personal data

Content Providers and Communities

Navigatr will share your personal data (name and email address) with the Provider - the organisation who has listed the content you have engaged with - where relevant, as part of programme delivery. This includes activities, digital badges or pathways to work or learning opportunities and their associated Community when you actively engage with them. "Actively engaging" means:

  • Joining pathways
  • Receiving badges
  • Participating in activities

This is part of normal programme delivery so organisations can provide their services to you.

Survey responses and special category data

Your individual survey answers are not shared with organisations at an individual level. Only anonymised and aggregated outputs (aggregated statistics and percentages with no personal data) may be shared for reporting and evaluation purposes. Reports contain percentages and statistics only - no personal data or special category data is included.

Separately, organisations may see your name and email as part of normal programme administration (for example, badge delivery), which is unrelated to survey responses.

Special category data is never shared in identifiable form with providers, communities, or other organisations. It is only used to generate anonymised and aggregated insights (aggregated statistics and percentages with no personal data) for reporting purposes.

Technical Partners

Navigatr works with technical partners as needed to deliver services. All technical partners are bound by data processing agreements that ensure GDPR compliance.

Other organisations

Navigatr may also share your information with:

  • Legal and other professional advisers, consultants, and professional experts
  • Service providers contracted to us in connection with provision of the products and services such as providers of IT services, hosting, development, management and consultancy, and customer relationship management services
  • Analytics and search engine providers, such as Google Analytics, that assist us in the improvement and optimisation of our product. This includes anonymised data on the number of users, session statistics, approximate geolocation, browser and device information.
  • Law enforcement or other authorities if required by applicable law.

Where the third party is our data processor, we will ensure there is a contract in place which includes obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them. Navigatr will ensure that these GDPR requirements are replicated for any third party contracts.

9. How we use your information

Navigatr will use the personal data we collect to provide, maintain, and improve Our Services, which includes publishing and distributing user-generated content and personalising the content you see. We will use your information in the following ways:

  • Create and maintain your Platform account
  • Respond to your questions and comments and provide customer service
  • Monitor and analyse trends, usage, and activities in connection with our Services;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Navigatr and others
  • Debug to identify and repair errors in our services
  • Communicate with you in relation to the provision of the contracted products and services
  • Comply with our legal and financial obligations
  • Carry out any other purpose described to you at the time the information was collected.
  • Send you technical notices, security alerts, support and administrative messages

Send you content recommendations

Automated decision-making is the process of making a decision by automated means without any human involvement. These decisions can be based on factual data, as well as on digitally created profiles or inferred data. The Platform will automatically suggest content to you through notifications.

Survey responses and special category data are not used to personalise content or generate recommendations.

These notifications are based both on the interests provided during onboarding and the skills data present in your earned badges (badge assertions). For example, if you have selected in your preferences that you are interested in ‘coding’ and/or have earned a digital badge with the skill tag ‘coding’; you will be notified of upcoming activities near your location that include the tag ‘coding’.

Display content that is most relevant to you based on your interests and preferences

Profiling analyses aspects of an individual’s personality, behaviour, interests and habits to make predictions or decisions about them. The Platform displays content based on your location, interests and preference data, provided by you during the onboarding process, and digital badges contained in your profile. These preferences can be changed at any time from your account settings page.

This doesn't hide or limit access to any content within the library and is purely to help an individual see the information most relevant to you, based on your preferences.

Cookies

Navigatr uses Cookies in line with our Cookie Policy. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications preferences

You may opt out of receiving certain communications from us or Community Providers, such as newsletters, and notifications, by following the instructions in those communications or through your account’s Settings page.

If you opt out, Navigatr may still send you administrative emails, such as those about your account or our ongoing business relations.

10. How long we will keep your information

Navigatr will retain your personal data as long as we provide the Navigatr services in order to maintain the integrity of your digital credentials. We store personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

This includes the hosting of metadata on the Platform provided by Navigatr that ensures links from your digital credentials still function when shared (by you) with third party websites, like your social media accounts.

User-initiated deletion

You have several options for deleting your data:

Partial deletion:

  • You can delete your special category data via your account settings page (keeps your account and other data)
  • You can request deletion of specific survey responses via support at support@navigatr.app (keeps your account and other data)

Full account deletion:

  • You can delete your entire account via your account settings page
  • This deletes all associated personal data, survey responses, and special category data

All deletions are completed within 30 days of your request, including removal from backups.

Organisation-initiated deletion

If an organisation requests deletion of data associated with its programmes, the following will be permanently deleted:

  • All organisation data
  • Badge issuance records and programme-related data associated with that organisation (to the extent they are held on behalf of that organisation)
  • Pathway participation history and progress
  • Survey responses (permanently deleted, not anonymised)
  • All related special category data

Your Navigatr account and profile will remain active because:

  • It belongs to you (not the organisation)
  • It is a learning record that may include badges, pathways, and data from multiple organisations
  • You retain access to badges and pathways from other organisations

Data retention

Navigatr will retain your personal data for as long as needed for the purposes for which it was collected or as long as your account remains active. This includes the hosting of metadata on the Platform provided by Navigatr that ensures links from your digital credentials still function when shared (by you) with third party websites, like your social media accounts.

Anonymised and aggregated data (statistics and percentages with no personal data) may be retained for reporting and evaluation purposes after account deletion. This is acceptable under GDPR as anonymised data is no longer considered personal data.

11. Lawful bases for processing

Navigatr processes your personal data based on the following lawful bases:

  • Consent (Article 6(1)(a)): For survey participation and where we ask you to provide optional information
  • Contract (Article 6(1)(b)): To provide the services you have signed up for, including platform operation, security, and data processing
  • Legitimate Interest (Article 6(1)(f)): For Platform operation, security, anonymisation, aggregation, and service improvement

For special category data, we rely on:

  • Explicit Consent (Article 9(2)(a)): For equality monitoring data, which is completely optional

Survey participation is voluntary and requires your consent. Consent is collected each time you start a new survey and applies only to that specific survey instance - it is survey-specific, not account-wide. You remain free to decline participation each time by choosing not to proceed when consent is requested at the start of the survey.

If you withdraw your consent or request deletion of survey responses, this affects only past responses. It does not prevent you from being invited to future surveys, which will always require fresh, active consent if you choose to participate.

12. Your rights

Under the UK General Data Protection Regulation (UK GDPR), you have the following rights:

Right to access

You have the right to request a copy of the personal data that we hold about you by contacting Navigatr at the email or postal address given below. Please provide proof of identity. Navigatr will respond within 30 days of request.

If you have signed up for a Navigatr account, you may at any time request an export of your personal information from the Settings page, or by going to Settings and then selecting Account on the Platform.

Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive. For more information, you may refer to the Information Commissioner’s Office (ICO)’s webpage Information Commissioner's Office (ICO) webpage on manifestly unfounded and excessive requests.

Right to rectification

Navigatr aims to keep your personal data accurate and complete. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

You may also correct information associated with your account from the Settings page, or by going to Settings and then selecting Account on the Platform, and the Your Interests section to update your interests.

Right to erasure

You have the right to request the deletion of your personal data. This right applies where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where you object to the processing and there are no overriding legitimate grounds for the processing, or where your personal data has been unlawfully processed.

You may withdraw consent by deleting your account at any time through the Settings page.

Please note that there are exceptions to this right. For example, we may be unable to delete your data if it is necessary for compliance with a legal obligation, for the establishment, exercise, or defence of legal claims, or for archiving purposes in the public interest. If we are unable to comply with your request due to an exception, we will explain this to you in our response.

Right to object to processing

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. You may object at any time to the use of your personal data by contacting gdpr@navigatr.app

Right to restrict processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted.

Right to data portability

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means.

Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

You are not required to pay any charge for exercising your rights. If you make a request, Navigatr has 30 days to respond to you. Please contact us using the details provided below.

Raising a complaint

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint with the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.

13. Contact us

To exercise any of your data protection rights, or if you have a query about this Policy, please email Navigatr at gdpr@navigatr.app or write to Data Protection, Navigatr, Castleton Mill, Castleton Close, Leeds, West Yorkshire, LS12 2DS