Duality Learning
Duality Learning

Privacy Policy

Duality Limited is committed to protecting your privacy. We have created the Privacy Policy to explain to you what information we collect, how we collect it and how that information is then used and can be accessed by you. 


This privacy policy should be read alongside and in addition to our Terms and Conditions, which are available upon request. This policy was last updated 2 April 2025. 


Purpose

This Privacy Policy outlines how Duality Limited ("we", "our", "us") collects, uses, discloses, and protects personal data of our customers, employees, and partners. It provides a comprehensive privacy and data protection compliance framework that is designed to comply with the Data Protection (Jersey) Law 2018 (DPJL), UK General Data Protection Regulation (UK GDPR), and the guidance provided by the Jersey Office of the Information Commissioner (JOIC). 


Duality Limited, as an AI-driven financial services education company, processes personal data in various ways, including user registration, learning progress tracking, AI-powered adaptive learning, and client engagement.


Scope

This policy applies to all personal data processed by Duality Learning in Jersey and any other regions where we operate. 


Definitions and Interpretation

“You” or “your” – means any customer, customer employers, consultants, suppliers or users of the Duality Learning website. This includes anyone who accesses our online courses, online events and eLearning offerings. 


“Data” – means all personal data that you provide to us and that we receive about you in providing our services. 


“Cookies” – means a small text file placed on your computer by this website when you visit certain parts of the website and/or when you use certain features of the website. 


“Data Protection Laws” – means any applicable law relating to the processing of personal Data, including but not limited to the Data Protection (Jersey) Law 2018 and subsequent legislation. 


“Website” – means www.dualitylearning.com, and any sub-domains of this site, unless expressly excluded by their own terms and conditions.  


In this privacy policy, unless the context requires a different interpretation: the singular includes the plural and vice versa. 


Why This Policy Exists

We gather and use certain information about individuals and their businesses to provide professional development products and services to both individuals and businesses. 

Collecting this information helps us to: 

  • understand how to help and support our customers; 
  • know what learnings and themes individuals and businesses are interested in hearing more about; and 
  • administer online courses, e-learning and other educational or professional development activities. 


Data Collection

Duality Limited collects and processes the following categorises of personal data: 

  • user information (name, email, job title, employer, professional background);
  • educational data (course enrolments, learning progress, CPD hours completed);
  • AI-generated insights (adaptive learning profiles, AI-assisted performance analytics);
  • technical data (IP address, browser details, device information); and
  • billing and payment details (payment records (where applicable). 


Under the Data Protection (Jersey) Law 2018, the lawful bases we rely on for processing this information are: 

  1. Your consent (obtaining explicit consent for marketing communications). You are able to remove your consent at any time. You can do this by contacting: data@dualitylearning.com; 
  2. We have a contractual obligation (providing access to educational services under user agreements); and, 
  3. We have a legitimate interest (improving AI-driven learning experiences and platform enhancements).


Data that you give us will be used to: 

  • arrange your attendance at online courses, provide you with eLearning or other professional development opportunities; 
  • to improve the products and services that we provide;
  • to send you information that you have asked for or which we think will be relevant to you; and
  • to customise or update our website. 


We use certain secure tolls and applications to provide our services. This includes a CRM system, booking system and e-learning platform. At times your information will be shared with these external systems and platforms to enable us to provide our services to you. 

We do not lease, distribute or sell your information to other third parties unless we have your permission, or the law requires us to do so. 


In the event of the sale and/or transfer of control of all or part of Duality Limited, Data may be transferred to or shared with any new owner or prospective purchaser. However, in such circumstances, we would take appropriate steps to ensure your privacy, where possible. 


We collect and hold Data in several different ways and the following sections describe how we do this: 


Via Our Website: Cookies and Analytics

When you visit our Website, we automatically collect some information about your visit. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content. This is done via Cookies. 

You always have the options to consent or disable the placing of the Cookies, However, if you choose to disable the placing of Cookies then some functionality of the Website may be impaired and reduce your experience as a user. For more information generally on Cookies, including how to disable them, please refer to aboutcookies.org. We also monitor the use of the Website with Google Analytics. 


The Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them. 


On Social Media

We have several social media platforms where we interact with individuals who follow our sites or respond to our postings. We will engage with and respond to individuals who also have a presence on these platforms. We use the analytics provided by these platforms to understand how our posts are engaging users. 


Our Customers And People Who Email or Telephone Us

We receive email and telephone enquiries from individuals and businesses about our services. In these cases, we enter telephone or email correspondence with individuals to provide the information they need. During this process, individuals may share commercially sensitive information with us about their business. 


We handle all commercial sensitive information as confidential information and will not share with third parties unless we have your permission or the law requires us to do so. 

The content of our email traffic and the documents that we receive are stored on an online Microsoft 365 platform. The Data stored on this platform is encrypted but you should be aware that if we are corresponding with you via a platform that you use which is not encrypted then these emails and their attachments may not be protected in transit. 


Data Storage and Retention

Your information is securely stored using the following third-party systems: 

  • Google Workspace 
  • AirTable
  • TalentLMS
  • HubSpot 


We retain Data in line with retention schedules. Data about our customers is retained for 5 years from the last interactions. Our data retention schedule is available upon request. 

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes. 


Data Security

We implement appropriate technical and organisational measures to protect Data against unauthorised access, disclosure, alterations and destruction. In the event of a Data breach, we have procedures in place to notify the Jersey Office of the Information Commissioner and affected individuals within 72 hours where required by law. 


Your Rights: Amending or Access Data

Under data protection law, you have rights including: 


Your right of access - You have the right to ask us for copies of your personal information. Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. 

Your right to object to processing - You have the the right to object to the processing of your personal data in certain circumstances. 

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. 

You are not required to pay any charge for exercising your rights. If you make a request, we have four weeks to respond to you.


If you have any questions about this policy or if you wish to make a request please contact our Data Protection Officer (DPO), details below: 


John Pipon

data@dualitylearning.com 


If you make a complaint about our use of your Data and are not happy with our handling of that complaint, you may be able to refer your complaint to the Jersey Office of the Information Commissioner (JOIC): 


JOIC’s address:

2nd Floor

5 Castle Street

St. Helier 

Jersey 

JE2 3BT

enquiries@jerseyoic.org 

+44 (0) 1534 716530 

Copyright © 2025 Duality Learning - All Rights Reserved.

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