Clauses that recur across this industry, and what each one actually permits.
“to provide and improve our services”
The catch-all purpose. Analytics, profiling, personalisation, and increasingly AI training can all ride under it. When they want to do something new with your data, this sentence usually already covers it.
THE MOVE An objection draws the line: use your data to run the service, not to improve, target, or train on it.
“we do not sell your personal information”
Often technically true, and still misleading. It usually means no cash changes hands. Data can still flow to ad networks, analytics firms, and partners: on their definition, sharing is not selling.
THE MOVE Flip the do-not-sell switch where one exists. The written objection on top of it goes on your record.
“service providers, partners, and affiliates”
How data leaves the building with no name attached. Recipients are listed by what they do, never who they are. You cannot send a request to a company you cannot name, which is the point.
THE MOVE An access request can ask for the recipients by name, not just the categories. UK and EU law put that choice with you. The reply, or the silence, goes on your record.
“aggregated or de-identified information”
Stripping the name does not strip the pattern, and the pattern often still points at you. Policies grant themselves free, indefinite use of this data because in their telling it is no longer about you.
THE MOVE If a deletion comes back as 'anonymised', keep the reply. It is their claim, not a fact you can check.
“retained as long as necessary, or as required by law”
They can keep it for: legal duties, tax rules, fraud prevention, possible lawsuits, their own business reasons. None of them carries a firm end date. Deletion becomes a negotiation, not an event.
THE MOVE Which reasons apply to you, and how long each runs, is a request of its own. Their reply goes on your record.
“you grant us a licence to use your content”
A contract term, not a data setting, so a privacy request cannot undo it. The careful version ends with your account. The broad version can be passed on, never expires, and survives deletion.
THE MOVE Whether the licence ends with the account is written in their terms, not yours. Closing the account goes on your record.
“content providers and other business partners, so they may share information about their products and services that may be of interest to you”
The companies whose courses you took receive your details and market to you directly. It is worded as an interest match rather than a handover, and it runs under the ordinary commercial terms of an account you opened yourself.
THE MOVE An objection draws the line and asks which partners already have your details. Their reply goes on your record.
“deleted upon successful completion of verification and in any event no later than two years after collection”
A real limit, and a narrow one. It covers the face data and documents from a certificate check, not the course record around them, and two years is the outside date rather than a promise about the usual one.
THE MOVE A request asks what the check produced and whether it is still held. Their reply goes on your record.