# uPull.ai Academy — Privacy Notice

**Last updated:** 7 September 2026

uPull.ai Ltd, London, UK, is responsible for Academy personal information. Contact **help-desk@upull.ai** for privacy questions, access, correction, deletion or objection requests.

## Information we use

We use account details; saved, active and completed learning; pathways and badges; evidence and attachment links; manager invitations; supplier submissions; community posts/comments; Academy-update preferences; and Academy Assistant questions.

## Why we use it

We use this information to operate Academy accounts and learning records, provide role-appropriate manager/supplier/admin functions, run the Learner Community safely, provide support and improve the service. Our usual basis is legitimate interests in operating a secure professional learning service. Optional Academy updates use consent. Required account, password-reset, invitation and badge emails are service messages, not marketing.

## Important safety rule

Do not put patient-identifiable information, confidential clinical information, HR-sensitive information or other special-category personal data into evidence, attachments, community posts or Academy Assistant questions. The Assistant is for learning support, not clinical advice.

## Visibility and sharing

Managers can see learner information only after the learner accepts the manager invitation. Evidence is private unless the learner chooses to share that individual entry with their manager. Community content is visible only after the author chooses to publish it; authors can remove their own content and administrators can moderate it.

## Retention

- Account, learning and evidence records: active account plus normally 12 months after closure or last activity.
- Manager invitation/assignment records: 12 months after final status.
- Community posts/comments: until removed or account closure, then normally 12 months.
- Supplier submission/review audit: 24 months after final decision.
- Security/application logs: normally 90 days, unless required for an investigation.

## Hosting and rights

The Academy is hosted in Google Cloud's London region (`europe-west2`). External course providers apply their own privacy terms after you leave the Academy. We do not sell Academy personal information.

Contact **help-desk@upull.ai** to exercise your rights. You may also complain to the UK Information Commissioner's Office.