Privacy Policy

Effective Date: 1 November 2025
Company Name: JCA Creative Ltd t/a CllimberTM
Registered Address: Dukes Court, Bognor Road, Chichester, England, PO19 8FX, UK
Company Number: 03982394
For Data Protection Enquiries: Contact us using the online form at Cllimber.com.

1. Introduction

JCA Creative Ltd (“we”, “us”, “our”) is committed to protecting the privacy of all users (“you”, “your”) who access our online learning platform and services. This Privacy Policy explains how we collect, use, store, share, and protect your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using our website, platform, or services (collectively, the "Platform"), you acknowledge that you have read and understood this Privacy Policy

2. Who We Are

JCA Creative Ltd is the data controller of your personal data for the purposes of the UK GDPR. Our principal business activity is the provision of online educational content via a Software-as-a-Service (SaaS) model.

3. The Data We Collect

We may collect and process the following categories of personal data:

3.1 Personal Identifiers

Full name
Email address
Username and password
Contact details (e.g., phone number, address – if applicable)

3.2 Technical Data

IP address
Browser type and version
Device information
Operating system
Time zone setting and location
Platform usage data and logs

3.3 Learning and Usage Data

Courses enrolled and completed
Progress tracking
Test/quiz scores or results
Certification status

3.4 Payment and Transaction Data

Billing address
Last 4 digits of card (we do not store full card data – this is handled by our secure payment processor)
Payment status, refunds, and receipts

3.5 Marketing Preferences

Newsletter opt-ins
Communication preferences

4. How We Collect Your Data

We collect data in the following ways:

Directly from you when you:
- Create an account
- Enrol in a course
- Contact us for support
- Submit forms or surveys
- Opt-in to marketing communications
Automatically, when you:
- Use our Platform (via cookies, usage analytics, session tracking)
From third parties, such as:
- Payment providers
- Analytics tools (e.g., Google Analytics)
- Email delivery platforms (e.g., Mailchimp)

5. How We Use Your Data

We use your personal data for the following purposes:

Purpose

Legal Basis (UK GDPR)

To provide access to courses and learning features

Performance of a contract

To manage user accounts and provide support

Performance of a contract

To personalise your learning experience

Legitimate interests

To process payments and issue invoices

Performance of a contract

To improve our Platform (analytics and performance)

Legitimate interests

To send service emails (e.g. password resets)

Legitimate interests

To send marketing emails (with your consent)

Consent

To comply with legal obligations (e.g., accounting, tax)

Legal obligation

6. Marketing and Communications

We will only send marketing communications (such as newsletters or course updates) if you have opted in. You can unsubscribe at any time by contacting us using the online form.

7. Cookies and Analytics

We use cookies and similar technologies to improve your experience, analyse usage patterns, and remember preferences.

For detailed information, see our separate Cookie Policy.

8. Sharing Your Data

We may share your data with trusted third-party service providers who help us deliver our services, including:

Payment processors (e.g., Stripe, PayPal)
Cloud hosting services (e.g., AWS, Google Cloud)
Learning analytics platforms
Customer support tools (e.g., Intercom, Zendesk)
Email marketing platforms
Platforms associated with JCA Creative Ltd

All third parties are required to adhere to data protection obligations under UK GDPR and are not permitted to use your data for their own purposes.

9. International Data Transfers

Some of our service providers may store or process your data outside the UK (e.g., in the EEA or USA). In such cases, we ensure appropriate safeguards are in place, including:

Adequacy decisions by the UK Government
Standard Contractual Clauses (SCCs)

10. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements.

Data Type

Retention Period

User account data

6 years after account closure

Course progress and certifications

6 years

Payment and transaction records

7 years (legal obligation)

Marketing consents

Until withdrawal or 2 years after last interaction

11. Your Rights

Under UK data protection laws, you have the following rights:

Right to access – request a copy of your personal data
Right to rectification – request correction of inaccurate data
Right to erasure – request deletion of your data (in certain cases)
Right to restrict processing – request limits on how we process your data
Right to data portability – request transfer of your data
Right to object – object to processing based on legitimate interest or direct marketing
Right to withdraw consent – withdraw marketing or analytics consent at any time

To exercise your rights, contact us using the online form.

12. Security Measures

We use industry-standard encryption, secure servers, and access controls to protect your data. However, no system is 100% secure, and you are responsible for maintaining the confidentiality of your account credentials.

13. Children’s Privacy

Our services are not directed at children under 18. If you believe we have collected personal data from a child without appropriate consent, please contact us immediately.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised “Effective Date.” Where required by law, we will notify you of significant changes and, if necessary, seek your consent.

15. Complaints

If you are unhappy with how we handle your data, please contact us first. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

📍 Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK
📞 +44 (0)303 123 1113
🌐 www.ico.org.uk

16. Contact Us

For all privacy-related enquiries, please contact us:
Online: Contact Form

Post: Data Protection Officer, JCA Creative Ltd, Dukes Court, Bognor Road, Chichester, England, PO19 8FX, UK

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1. Introduction

By using our website, platform, or services (collectively, the "Platform"), you acknowledge that you have read and understood this Privacy Policy

2. Who We Are

3. The Data We Collect

We may collect and process the following categories of personal data:

3.1 Personal Identifiers

Full name
Email address
Username and password
Contact details (e.g., phone number, address – if applicable)

3.2 Technical Data

IP address
Browser type and version
Device information
Operating system
Time zone setting and location
Platform usage data and logs

3.3 Learning and Usage Data

Courses enrolled and completed
Progress tracking
Test/quiz scores or results
Certification status

3.4 Payment and Transaction Data

Billing address
Last 4 digits of card (we do not store full card data – this is handled by our secure payment processor)
Payment status, refunds, and receipts

3.5 Marketing Preferences

Newsletter opt-ins
Communication preferences

4. How We Collect Your Data

We collect data in the following ways:

Directly from you when you:
- Create an account
- Enrol in a course
- Contact us for support
- Submit forms or surveys
- Opt-in to marketing communications
Automatically, when you:
- Use our Platform (via cookies, usage analytics, session tracking)
From third parties, such as:
- Payment providers
- Analytics tools (e.g., Google Analytics)
- Email delivery platforms (e.g., Mailchimp)

5. How We Use Your Data

We use your personal data for the following purposes:

Purpose

Legal Basis (UK GDPR)

To provide access to courses and learning features

Performance of a contract

To manage user accounts and provide support

Performance of a contract

To personalise your learning experience

Legitimate interests

To process payments and issue invoices

Performance of a contract

To improve our Platform (analytics and performance)

Legitimate interests

To send service emails (e.g. password resets)

Legitimate interests

To send marketing emails (with your consent)

Consent

To comply with legal obligations (e.g., accounting, tax)

Legal obligation

6. Marketing and Communications

We will only send marketing communications (such as newsletters or course updates) if you have opted in. You can unsubscribe at any time by contacting us using the online form.

7. Cookies and Analytics

We use cookies and similar technologies to improve your experience, analyse usage patterns, and remember preferences.

For detailed information, see our separate Cookie Policy.

8. Sharing Your Data

We may share your data with trusted third-party service providers who help us deliver our services, including:

Payment processors (e.g., Stripe, PayPal)
Cloud hosting services (e.g., AWS, Google Cloud)
Learning analytics platforms
Customer support tools (e.g., Intercom, Zendesk)
Email marketing platforms
Platforms associated with JCA Creative Ltd

All third parties are required to adhere to data protection obligations under UK GDPR and are not permitted to use your data for their own purposes.

9. International Data Transfers

Some of our service providers may store or process your data outside the UK (e.g., in the EEA or USA). In such cases, we ensure appropriate safeguards are in place, including:

Adequacy decisions by the UK Government
Standard Contractual Clauses (SCCs)

10. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements.

Data Type

Retention Period

User account data

6 years after account closure

Course progress and certifications

6 years

Payment and transaction records

7 years (legal obligation)

Marketing consents

Until withdrawal or 2 years after last interaction

11. Your Rights

Under UK data protection laws, you have the following rights:

Right to access – request a copy of your personal data
Right to rectification – request correction of inaccurate data
Right to erasure – request deletion of your data (in certain cases)
Right to restrict processing – request limits on how we process your data
Right to data portability – request transfer of your data
Right to object – object to processing based on legitimate interest or direct marketing
Right to withdraw consent – withdraw marketing or analytics consent at any time

To exercise your rights, contact us using the online form.

12. Security Measures

13. Children’s Privacy

Our services are not directed at children under 18. If you believe we have collected personal data from a child without appropriate consent, please contact us immediately.

14. Changes to This Policy

15. Complaints

If you are unhappy with how we handle your data, please contact us first. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

📍 Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK
📞 +44 (0)303 123 1113
🌐 www.ico.org.uk

16. Contact Us

For all privacy-related enquiries, please contact us:
Online: Contact Form

Post: Data Protection Officer, JCA Creative Ltd, Dukes Court, Bognor Road, Chichester, England, PO19 8FX, UK

Cllimber Privacy Policy