Privacy Policy


We are delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of Key to Learning Ltd. The use of the Internet page is possible without any provision of personal data; however, if you want to be a Subscriber to our services and updates, give your details in a Contact Form in order for us to get in touch with you, or want to become a Member using our online products, then processing of personal data will become necessary. For Subscribers we always obtain your consent to holding and processing of data and for Members our legal basis for holding and processing your data is contractual.

The processing of your personal data, such as the name, address, e-mail address, or telephone number shall always be in line with the General Data Protection Regulation (GDPR), with the terms and rules established by the US Federal Trade Commission (“FTC”), as may be amended and in accordance with the data protection regulations of the UK’s Information Commissioners Office.

As the data controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of the personal data of a data subject [this means you and your data] processed through our websites.


  1. Controller and Data Protection Officer

The Controller of your data is Key to Learning Ltd, 14 Mount Road, Wheathampstead, Hertfordshire, AL4 8BX, United Kingdom

Phone: +44 (0)1582 832320


Data Protection Officer: David Higgins (Director)

Any Subscriber or Member may, at any time, contact our Data Protection Officer directly with all questions concerning data protection.


  1. Cookies

Our Internet pages use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

With cookies, Key to Learning Ltd can provide the users of our website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website visitor that uses cookies, for example does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system.

You may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you deactivate the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.


  1. Collection of general data and information (non-personal data)

Our website collects a series of general data and information when a person uses the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Key to Learning Ltd does not draw any conclusions about you. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Key to Learning Ltd analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by you.


  1. The data we hold and process

What personal data is transmitted to us is determined by the respective input mask used for registration as a Subscriber and/or as a Member buying products and services. The personal data entered is collected and stored exclusively for our own purposes, for internal use and use by our Third-Party service providers. Service Providers are companies that help us run our business by processing personal data for us. Such providers include payment processing services, server services, data analysis services, fraud monitoring and prevention, email delivery, social media and marketing. We always ensure that our Third-Party service providers are themselves committing to GDPR compliance through examination of their own privacy policies.

For Members who buy products through our website, some of these are supplied by our partners. Your data is transferred to them solely for supply and shipping. Those suppliers are covered by the GDPR regulations and committed to them. Any payments are made through our secure payment providers.

We never sell data to other organisations. 

When using our secure payment service providers, we do not ourselves store any information on credit or debit cards or bank accounts.

We do not use automated decision-making or profiling.

By registering on our website, the IP address—assigned by the Internet service provider (ISP) and used by you —date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. Therefore, the storage of this data is necessary for our security. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

Your registration, with the voluntary supply of your personal data, is intended to enable us to offer Subscribers content or services that may only be offered to registered users and to provide Members with the products and services they have bought.

We will, at any time, provide information upon request to each registered person as to what personal data is stored about them. In addition, we will correct or erase personal data at the request or indication of the registered person, insofar as there are no statutory storage obligations. All our employees are available to you in this respect as contact persons.


  1. Subscribers

On the website of Key to Learning Ltd, users are given the opportunity to subscribe to our newsletter and promotions. The input mask used for this purpose determines what personal data are transmitted.

Key to Learning Ltd informs its Members and Subscribers regularly by means of a newsletter about its offers, articles and relevant information. The enterprise’s newsletter may only be received by you if (1) you have a valid e-mail address and (2) you register. On registration, a confirmation e-mail will be sent to the e-mail address given by you, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address is authorized to be registered.

During the registration process, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by you at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of your e-mail address at a later date, and it therefore serves the aim of the legal protection for us.

The personal data collected as part of a registration will only be used to send our newsletter, articles and promotions. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties, other than our service providers (see 4 above). The subscription to our newsletter may be terminated by you at any time. The consent to the storage of personal data, which you have given, may be revoked at any time. For revocation of consent, a corresponding link is found in each newsletter or email. It is also possible to unsubscribe from the newsletter at any time by communicating this to us in a different way.


  1. Contact via the website or email

The website of Key to Learning Ltd contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If you contact us by e-mail or via a contact form, the personal data transmitted by you are automatically stored. Such personal data transmitted on a voluntary basis by you to us are stored for processing or contacting you. There is no transfer of this personal data to third parties.


  1. Routine erasure and blocking of personal data

We will process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which we are subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.


  1. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data for Members (who have a contract with us) is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, if it is no longer necessary for the fulfilment of the contract or the initiation of a further contract.

For any Subscribers who have not responded to our communications for 6 years, we will routinely delete their personal data.


  1. Provision of personal data as a statutory or contractual requirement

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions. Sometimes it may be necessary to conclude a contract that you provide us with personal data, which must subsequently be processed by us. You are, for example, obliged to provide us with personal data when our company signs a contract with you. The non-provision of the personal data would have the consequence that the contract with you could not be concluded.


This Privacy Policy has been adapted from a standard generated by the Privacy Policy Generator of the German Association for Data Protection that was developed in cooperation with Privacy Lawyers from WILDE BEUGER SOLMECKE, Cologne.