Who We Are
Zavmo is an AI-powered adaptive learning platform operated by Iridescent Technology Ltd, a company registered in England and Wales. We are the data controller responsible for your personal data.
For any privacy-related queries, you may contact our Data Protection Officer at hello@zavmo.ai. We aim to respond to all legitimate requests within 30 days.
Information We Collect
We collect and process personal data to provide, improve, and personalise your learning experience. The types of data we collect depend on how you interact with Zavmo.
Account & Identity Data
When you create an account or register through your organisation, we collect your name, email address, job title, organisation name, and login credentials. If you sign up as an individual learner, we collect the information you provide during registration.
Learning & Performance Data
As you use Zavmo, we collect data about your learning interactions to personalise your experience. This includes learning progress, assessment results, time spent on modules, preferred learning styles, interaction patterns with our Virtual Characters, and xAPI learning records.
Technical & Usage Data
We automatically collect certain technical information when you use our platform, including your IP address, browser type and version, device information, operating system, pages visited, time and date of visits, and referring URLs.
Communications Data
If you contact us via email, our website contact form, or other communication channels, we retain the content of those communications along with your contact details to respond to and manage your enquiry.
Special Category Data
Zavmo supports neurodiverse learners, including those with ADHD, dyslexia, and autism. If you voluntarily disclose information about neurodivergent conditions or learning differences to personalise your experience, we treat this as special category data under UK GDPR and process it only with your explicit consent.
How We Use Your Data
We use your personal data for specific, legitimate purposes directly related to our learning services.
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Delivering personalised learning pathways | Account, Learning & Performance data | Contract performance |
| Adapting content to your cognitive style | Learning preferences, interaction patterns | Consent / Legitimate interest |
| Generating progress reports for your organisation | Learning & Performance data | Contract performance |
| OFQUAL qualification tracking and certification | Assessment results, identity data | Legal obligation / Contract |
| Platform improvement and AI model enhancement | Anonymised usage data | Legitimate interest |
| Customer support and communications | Account, Communications data | Contract / Legitimate interest |
| Marketing (only with your permission) | Name, email address | Consent |
Our Legal Basis for Processing
Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, we rely on the following lawful bases to process your personal data:
Contractual Necessity
Processing is necessary to deliver the Zavmo learning platform and services you or your organisation have subscribed to. This includes account management, content delivery, assessment, and certification.
Legitimate Interest
We process certain data where it is in our legitimate business interests to do so, provided this does not override your fundamental rights and freedoms. This includes platform security, fraud prevention, service improvement through anonymised analytics, and internal research.
Consent
Where we rely on consent, you have the right to withdraw that consent at any time. This applies to marketing communications, processing of special category data related to neurodivergent learning preferences, and the use of non-essential cookies.
Legal Obligation
We may process your data where it is necessary to comply with legal or regulatory obligations, including OFQUAL reporting requirements and tax or accounting obligations.
AI & Automated Decision-Making
Zavmo uses artificial intelligence to create personalised learning experiences. Our AI-powered system, which includes 18 specialist virtual agents, analyses your learning patterns, preferences, and progress to adapt content delivery in real time.
How Our AI Works
Our platform employs a multi-agent AI architecture to personalise your learning. This involves assessing your preferred cognitive style, adapting content difficulty and format to match your needs, recommending learning pathways aligned with nationally recognised qualifications, and providing real-time feedback through our Virtual Characters.
Your Rights Regarding AI
You have the right to request human review of any significant decisions made solely by automated processing. You may also request an explanation of how our AI system has personalised your learning experience. To exercise these rights, contact us at hello@zavmo.ai.
Our commitment: Zavmo's AI is designed to enhance learning, not to make decisions that produce legal or similarly significant effects on you. We have been officially ISO 42001 approved, demonstrating our commitment to the highest standards of responsible AI management.
Who We Share Your Data With
We do not sell your personal data to third parties. We may share your data with the following categories of recipients, only where necessary and with appropriate safeguards in place.
Your Employer or Organisation
If you access Zavmo through your organisation, we share learning progress and completion data with your designated organisational administrators as required under our enterprise service agreement.
Awarding Bodies & Regulators
Where you are pursuing OFQUAL-regulated qualifications, we share necessary assessment and certification data with the relevant awarding organisations and regulatory bodies.
Service Providers
We work with carefully selected third-party service providers who assist with hosting and cloud infrastructure, email delivery and communications, payment processing, and analytics and platform monitoring. All service providers are bound by data processing agreements and are required to process data in compliance with UK GDPR.
Legal Requirements
We may disclose your data if required to do so by law, regulation, legal process, or enforceable government request.
International Data Transfers
Zavmo primarily stores and processes data within the United Kingdom and European Economic Area. Where we transfer personal data outside these regions, we ensure appropriate safeguards are in place, including UK International Data Transfer Agreements (IDTAs), Standard Contractual Clauses approved by the Information Commissioner's Office (ICO), and transfers to countries with an adequacy decision from the UK Government.
You may request further details about the safeguards we apply by contacting us at hello@zavmo.ai.
How Long We Keep Your Data
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.
| Data Type | Retention Period |
|---|---|
| Account data | Duration of your account plus 12 months |
| Learning records & xAPI data | Duration of account plus 6 years (qualification records) |
| Qualification & certification data | Indefinitely (regulatory requirement) |
| Marketing consent records | Until consent is withdrawn plus 12 months |
| Technical logs | 90 days |
| Support communications | 24 months from resolution |
When data is no longer required, it is securely deleted or anonymised so that it can no longer be linked to you.
How We Protect Your Data
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, or misuse.
Our security measures include encryption of data in transit (TLS 1.2+) and at rest, role-based access controls with least-privilege principles, regular security assessments and penetration testing, secure software development practices, staff training on data protection and information security, and incident response procedures aligned with ICO breach notification requirements.
Whilst we strive to protect your personal data, no method of transmission or storage is completely secure. We encourage you to use strong, unique passwords and to notify us promptly if you become aware of any unauthorised access to your account.
Your Rights Under UK GDPR
Under the UK General Data Protection Regulation and the Data Protection Act 2018, you have the following rights in relation to your personal data:
Right of Access
You have the right to request a copy of the personal data we hold about you. This is known as a Subject Access Request (SAR).
Right to Rectification
You can ask us to correct any personal data that is inaccurate or incomplete.
Right to Erasure
You can request that we delete your personal data in certain circumstances, such as when it is no longer necessary for the purpose it was collected.
Right to Restrict Processing
You can ask us to limit how we use your personal data whilst we investigate a concern you have raised.
Right to Data Portability
You have the right to receive the personal data you provided to us in a structured, commonly used, machine-readable format.
Right to Object
You can object to our processing of your personal data where we are relying on legitimate interest as our legal basis.
Rights Related to Automated Decision-Making
You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. See Section 5 for details on Zavmo's AI processing.
To exercise any of these rights, please contact us at hello@zavmo.ai. We will respond to your request within one calendar month. In complex cases, we may extend this by a further two months, but we will notify you if this is the case.
Cookies & Tracking Technologies
Zavmo uses cookies and similar technologies to provide and improve our platform. Cookies are small text files stored on your device when you visit our website.
Essential Cookies
These are necessary for the platform to function and cannot be disabled. They include session management, authentication, and security cookies.
Functional Cookies
These remember your preferences such as language settings, accessibility options, and learning interface customisations to enhance your experience.
Analytics Cookies
With your consent, we use analytics cookies to understand how visitors interact with our website. This data is anonymised and used to improve our platform's performance and usability.
Managing Cookies
You can manage your cookie preferences through the cookie banner displayed when you first visit our site. You may also adjust your browser settings to refuse or delete cookies. Please note that disabling essential cookies may affect the functionality of the platform.
Children's Privacy
Zavmo's platform is designed for adult learners and professionals. We do not knowingly collect personal data from children under the age of 16. If you become aware that a child under 16 has provided us with personal data, please contact us at hello@zavmo.ai and we will take steps to delete such data promptly.
Where the platform is used within an educational or organisational setting that includes learners aged 16–17, additional safeguards and parental/guardian consent requirements apply in accordance with the UK Age Appropriate Design Code (Children's Code).
Third-Party Links
Our platform and website may contain links to third-party websites, services, or resources. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party service before providing your personal data.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform features. When we make significant changes, we will notify you by posting a notice on our website and, where appropriate, by email.
We encourage you to review this policy periodically. The "Last Updated" date at the top of this page indicates when this policy was most recently revised.
Our Regulatory Compliance Commitment
Zavmo is fully committed to operating within the highest standards of data protection law and regulatory compliance. We adhere to all applicable legislation and industry frameworks governing personal data, AI governance, and educational standards in the United Kingdom.
Data Protection Legislation
We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR). Our data processing practices are designed to meet the standards set by the Information Commissioner's Office (ICO) and are subject to regular internal review.
AI Governance & Ethical Standards
Zavmo has been officially approved and certified under ISO 42001 for Artificial Intelligence Management Systems, independently verifying that our AI governance meets the highest international standards. We follow rigorous AI principles ensuring transparency, fairness, and accountability in all automated processing and personalised learning delivery.
Educational & Qualification Standards
Zavmo operates in accordance with OFQUAL regulatory requirements for qualification delivery and assessment. Our learning content is validated through Learning Specification Triangulation, mapping to National Occupational Standards (NOS) and nationally recognised qualification frameworks.
Equality & Accessibility
We comply with the Equality Act 2010, the UK Accessibility Regulations 2018, and the Age Appropriate Design Code (Children's Code) where applicable. Our platform is built with neuroinclusive design principles, ensuring equitable access for all learners.
Our pledge: Zavmo follows all regulated rules and laws governing data protection, AI ethics, and educational standards in the United Kingdom. If you have any questions about our compliance practices, please contact us at hello@zavmo.ai.
Questions About Your Privacy?
We are here to help. If you have any questions about this Privacy Policy or how we handle your personal data, do not hesitate to reach out.
hello@zavmo.ai