Privacy Policy & Terms of Service

Your rights and how Sphere protects and uses your information

This page explains how Sphere collects, uses, and protects your personal information. You will also find information on your rights and responsibilities as a user. We are committed to protecting your privacy and complying with data protection legislation such as the Protection Act 2018 and UK and EU GDPR.

Last Updated: October 2025

Sphere collects information to provide our educational platform services. This includes:

Account Information

  • Name and display name
  • Email address
  • Profile picture
  • Organisation affiliation

Platform Usage Data

  • Assessment results
  • Toolkit creations, completions, activity and comments
  • Forum posts and comments
  • User Generated Content Reactions
  • Resource uploads and downloads
  • Bookmarks and preferences
  • Learner & practitioner affiliation
  • Login statistics

Technical Information

  • IP address (anonymised)
  • Browser type and version
  • Device information

Sphere may use cookies and similar technologies to improve your experience and understand how our platform is used.

Essential Cookies

These are necessary for the platform to function, including authentication and session management.

Translation Cookies

Sphere uses Google translate cookies to determine the preferred language to display content to you.

You can manage cookie preferences at any time through your browser settings.

We use your information to:

  • Provide and maintain Sphere services
  • Authenticate your account and ensure security
  • Enable collaboration between learners and practitioners
  • Generate assessment reports and learning insights
  • Facilitate community features (forums, toolkits, resources)
  • Improve platform functionality and user experience
  • Send important service updates and notifications
  • Comply with legal obligations

Sharing with Practitioners

If you're a learner, you can choose to share your assessment results and progress with practitioners. You control this through your profile settings and can revoke access at any time.

We do not sell your personal data. We may share information only in the following circumstances:

With Your Consent

When you explicitly agree to share data (e.g., granting practitioner access to your assessments) or opting not to privatise account information.

Funding and Evaluation

Anonymised, aggregated data may be shared with funders and partners operated by Adult Learning Wales for:

  • Securing and maintaining funding
  • Monitoring participation and outcomes
  • Evaluating site effectiveness

Legal Requirements

When required by law or to protect the rights and safety of our users and platform.

Note: All data sharing complies with UK GDPR and is conducted transparently with respect for your rights.

We retain personal data only as long as necessary for service delivery.

The following are retained until an account deletion is requested :

  • Toolkit creations, activity and comments.
  • Assessment results
  • Forum posts, replies and reactions
  • Resources

Specific retention periods are based on:

  • Legal and regulatory requirements
  • Funding body obligations
  • Legitimate business interests

Account deletion can be requested at any point through the account page, permanently deleting personal information. Though some information may be retained in anonymised form for analytics and reporting.

Under UK GDPR, you have the following rights:

Access

Request a copy of the personal data we hold about you

Rectification

Correct inaccurate or incomplete data

Erasure

Request deletion of your personal data (subject to legal obligations)

Restriction

Limit how we process your data in certain circumstances

Portability

Receive your data in a structured, commonly used format

Object

Object to processing based on legitimate interests

Withdraw Consent

Withdraw consent at any time (where processing is based on consent)

We implement appropriate technical and organisational measures to protect your data:

  • Encrypted data transmission (HTTPS/SSL)
  • Secure authentication and access controls
  • Regular security updates and monitoring
  • Staff training on data protection
  • Incident response procedures

We may update this privacy policy periodically to reflect changes in our practices or legal requirements. When we make significant changes, we will:

  • The 'Last Updated' date at the top of this page will be updated as policy changes
  • Request renewed consent where required by law

Continued use of Sphere after policy updates constitutes acceptance of the changes.

Contact & Complaints

For questions about this policy or to exercise your data rights, contact our Data Protection Officer:

Data Protection Officer

Adult Learning Wales

7 Coopers Yard, Curran Road

Cardiff, CF10 5NB

Email: dpo@adultlearning.wales

Right to Complain

If you believe your data is being processed unlawfully, you can lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office

Wycliffe House, Water Lane

Wilmslow, Cheshire, SK9 5AF

Visit ICO Website