Privacy Policy

This Privacy Policy explains how Newbold College of Higher Education (“the College”, “we”, “us”, or “our”) collects, uses, and protects your personal data when you use Newbold Connect (the “Platform”).

Newbold Connect is built and delivered using Kajabi, an online platform service provided by Kajabi, LLC. Kajabi supplies the technical infrastructure and tools; the College remains responsible for how your personal data is used on Newbold Connect.

Newbold Connect offers faith-informed, cinematic practice-first Classes, and resources designed to support whole-life discipleship in church, workplace, community, and home. The Platform does not provide an open community forum at launch. Any interaction features (e.g. curated Q&A or time-bound live sessions) are optional and only available where explicitly enabled.

We are committed to handling your personal data lawfully, fairly, and transparently, in line with UK GDPR and the Data Protection Act 2018, and, where applicable, the EU GDPR and other local laws. EU GDPR applies where we are directing our services at individuals in the European Economic Area (EEA); if you are based in the EEA, you may have additional rights under EU law which are not diminished by these UK-based arrangements.

By using the Platform, you acknowledge that your personal data will be processed in accordance with this Privacy Policy and our Terms of Use, Cookies Policy, Community Guidelines (to be published at platform launch), and Safeguarding & Sensitive Content Policy.

1. WHO ARE WE AND HOW TO CONTACT US

Controller:

Newbold College of Higher Education

St Mark’s Road

Binfield, Berkshire

RG42 4AN

United Kingdom

The College is the data controller for personal data processed through Newbold Connect.

Platform provider (processor):

Newbold Connect is hosted on Kajabi, provided by Kajabi, LLC, a US-based company. For learner and contact data processed through the Platform, Kajabi acts as our data processor, following our documented instructions and the terms of Kajabi’s Data Protection Addendum (DPA).

Data protection contact:

Email: [email protected]

If you have questions about this Policy or how we handle your data, contact us using the details above.

You also have the right to raise concerns with the UK Information Commissioner’s Office (ICO). See section 9.

2. DATA WE COLLECT

We may collect and process the following categories of personal data when you use the Platform.

2.1. Account information

Name
Email address
Password (stored in encrypted form)
Profile details you choose to provide (e.g. role, country, church affiliation where relevant)

2.2. Payment information

Billing details (name, billing address, partial card/payment details as provided by payment processors)
Transaction history (classes/memberships purchased, amounts, dates)

We do not store full card numbers or CVV codes. Payments are processed securely by third-party providers such as Stripe or PayPal under their own terms and privacy policies.

2.3. Usage and learning data

Classes you enrol in, start, or complete
Lesson progress, completion rates, and timestamps
Downloads of guides and resources
Responses to in-platform activities (e.g. reflection prompts, quizzes, assignments), where applicable
CPD/CE participation and completions, where relevant

2.4. Community and interaction data

Comments, posts, reviews, Q&A, and other contributions you make in community spaces
Direct interactions with instructors or moderators where supported
Support enquiries and correspondence with our team

2.5. Technical and device data

Collected primarily via Kajabi and its integrated tools:

IP address
Browser type and version
Device type and operating system
Time zone setting and approximate location (based on IP)
Log data (access dates/times, pages viewed, referral URLs)
Cookies and similar technologies (see section 10 and Cookies Policy)

2.6. Optional information

Survey responses, feedback forms, testimonials
Preferences (e.g. communication preferences, content interests)
Information you provide voluntarily in your profile or in response to optional questions

2.7. Special category data

We do not intentionally seek to collect special category data (e.g. health data, political opinions, sexual orientation) as part of standard account creation or course enrolment.

However, due to the nature of our content (whole-life discipleship, mental health, vocation, trauma, relationships, faith journeys), you may sometimes choose to share sensitive information, for example:

In reflective exercises or assignments
In comments or discussions
When responding to pastoral or safeguarding prompts

Where such information relates to your health, religious beliefs, or other special category data, we will only process it where:

You have explicitly chosen to share it in the context of a learning activity or community space; and
We have a clear legal basis under UK GDPR (for example, your explicit consent or, in very limited circumstances, the vital interests of you or another person – e.g. serious risk of harm).

You are strongly encouraged not to share highly sensitive personal information in open forums or public community spaces.

3. How we use your data

We use your personal data for the following purposes:

To provide the Platform and our services

Create and manage your account
Provide access to classes, memberships, CPD programmes, and community features
Track course progress and learning outcomes
Issue CPD certificates or records where applicable

To process payments and manage subscriptions

Take payments for classes, memberships, or licences
Manage renewals, cancellations, and refunds
Maintain appropriate financial records

To support and communicate with you

Respond to support requests and enquiries
Send important service communications (e.g. changes to Terms, platform issues, security notices)
Notify you about course updates, new features, and changes relevant to your account

To personalise and improve the learning experience

Understand how users engage with content and features
Improve course design, navigation, and platform usability
Tailor content recommendations and communications where appropriate
Use Kajabi’s built-in analytics tools to understand general usage patterns (aggregated where possible).
AI and automated tools: We may use automated tools (including AI-assisted services) to support accessibility features (e.g. captions/transcripts), improve platform operations (e.g. routing support enquiries), and assist with service improvement. Automated tools support—rather than replace—human review and our QA process.

To support CPD / employer relationships (where applicable)

For CPD/CE programmes funded by an employer, church, or denominational body (e.g. TED, Unions, Conferences), share relevant participation and completion data with that organisation, in line with the contract or agreement covering that access.

To maintain safety, safeguarding, and compliance

Enforce our Terms of Use and Community Guidelines
Monitor for abuse, fraud, or misuse of the Platform
Respond to safeguarding concerns or disclosures indicating risk of serious harm, in line with our Safeguarding & Sensitive Content Policy
Comply with legal obligations (e.g. responding to lawful requests from authorities)

To send marketing communications (where permitted)

With your consent, send newsletters and updates about new classes, events, and offers
Use Kajabi’s email tools to manage subscriptions and unsubscribe options in line with GDPR, CAN-SPAM, and other regulations.

To manage our business and legal risk

Maintain records for audit, compliance, and governance
Manage disputes or legal claims
Conduct internal reporting and forecasting on use of the Platform

4. Legal bases for processing

Under UK GDPR, we must identify a legal basis for each type of processing. The main bases we rely on are:

Purpose	Legal basis
Providing access to the Platform, classes, and CPD programmes; managing your account.	Contract – processing is necessary to perform the contract with you.
Processing payments, renewals, and refunds.	Contract and legal obligation (financial regulations).
Service emails about changes to Terms, security, or platform issues.	Contract and/or legitimate interests (keeping the service functional and secure).
Personalising content and improving the Platform through analytics.	Legitimate interests or consent where analytics rely on non-essential cookies.
Marketing emails and newsletters.	Consent – you can withdraw at any time via unsubscribe links or account settings.
Sharing limited data with CPD employers / sponsoring organisations.	Contract and legitimate interests, in the context of the institutional agreement.
Safeguarding-related processing (e.g. responding to disclosures of serious harm).	Vital interests, legal obligation, and where special category data is involved, substantial public interest or explicit consent as appropriate.
Record-keeping, legal claims, and compliance.	Legal obligation and legitimate interests.

Where we rely on legitimate interests, we consider and balance those interests against your rights and freedoms, and aim to process only the minimum personal data necessary for the relevant purpose.

5. DATA SHARING

We do not sell your personal data.

We may share your data with:

5.1. Service providers (including Kajabi)

Trusted third parties who support the operation of Newbold Connect, including in particular:

Kajabi (platform hosting, website, content management, email delivery, basic analytics)
Payment processors (e.g. Stripe, PayPal)
Email and communication tools that integrate with Kajabi
Video hosting and content delivery networks
Analytics providers and cookie consent tools
We may also use third-party providers to support accessibility features (e.g. captioning/transcription) and other automated operational tools. Where they process personal data on our behalf, they do so under appropriate contractual safeguards.

For learner/customer data, Kajabi acts as our processor under a Data Protection Addendum that incorporates the latest EU/UK Standard Contractual Clauses for international transfers.

These providers only process your personal data on our instructions, under written contracts, and with appropriate confidentiality and security obligations.

Kajabi may also act as an independent controller for certain contact or account data relating to our direct relationship with them as their customer (e.g. our own Kajabi account, billing, and analytics about our use of Kajabi). That processing is covered by Kajabi’s own privacy notices and terms, not this Policy.

5.2. Instructors and facilitators

We may share limited learning data with instructors and facilitators, for example:

Aggregate progress statistics for their classes
Limited learner activity where needed to support discussion or feedback (e.g. Q&A participation)

We will not give instructors direct access to your full account or payment details.

5.3. CPD sponsors/employers

For CPD or institutional programmes where an employer, church body, or denominational organisation funds or administers access, we may share relevant information with them, such as:

Enrolment status
Progress and completion data
CPD/CE credits or certification status

This will always be done in line with the agreement governing that CPD arrangement.

5.4. Legal and safeguarding purposes

We may share data with:

Law enforcement, regulators, or courts, where required by law or in connection with legal claims
Relevant services (e.g. social services, emergency healthcare, police) where we reasonably believe there is a serious risk of harm to you or another person

In such cases, we will limit any disclosure to what is strictly necessary.

5.5. Group-level and aggregated data

We may share anonymised or aggregated data (that does not identify individuals) with:

College leadership, the Board of Governors, and the Trans-European Division (TED) for reporting and planning
Partners and supporters, for example, in impact reports or presentations

6. INTERNATIONAL TRANSFERS

Because Newbold Connect runs on Kajabi and other cloud-based services, your personal data may be transferred outside the UK and the European Economic Area (EEA), including to the United States, where Kajabi and some of its subprocessors are based.

When personal data is transferred outside the UK/EEA, we put appropriate safeguards in place, such as:

UK GDPR–approved Standard Contractual Clauses (SCCs) and/or International Data Transfer Agreements (IDTAs) in Kajabi’s DPA and our contracts with other providers;
Additional technical and organisational measures, where appropriate (e.g. security certifications, access controls).

These mechanisms are consistent with Kajabi’s own approach to supporting GDPR compliance for its customers.

Further details about these safeguards can be provided on request.

7. DATA RETENTION

We only keep personal data for as long as reasonably necessary for the purposes set out in this Policy, including for legal, accounting, or reporting requirements.

As a guide:

Account data – kept while your account is active and for up to 2 years after closure, then deleted or anonymised.
Payment and transaction records – kept for 6 years in line with financial and tax regulations.
Course progress and CPD data – normally retained for 3 years after your last login, then anonymised where feasible (CPD data may be kept longer where necessary for employer or accreditation requirements).
Community/forum posts – retained until your account is deleted or for 3 years of inactivity, after which they may be anonymised or removed.
Backups – retained for up to 12 months before secure deletion.

We may keep limited records for longer if needed to:

Respond to legal claims or regulatory investigations
Maintain accurate records of safeguarding-related decisions

8. CHILDREN’S DATA

The Platform is intended for adults aged 18 and over only. We do not knowingly collect personal data from anyone under 18. Users must confirm they are 18 or over when creating an account.

If you believe someone under 18 has created an account, please contact us at [email protected] so we can close the account and delete their data promptly.

9. YOUR RIGHTS

Under UK data protection law, you have the following rights in relation to your personal data:

Right of access – to obtain a copy of your personal data and information about how we process it.
Right to rectification – to correct inaccurate or incomplete data.
Right to erasure (the “right to be forgotten”) – to request deletion of your personal data in certain circumstances.
Right to restrict processing – to limit how we use your data in certain circumstances.
Right to data portability – to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller, where technically feasible.
Right to object – to object to processing based on legitimate interests, and to direct marketing at any time.
Right to withdraw consent – where we rely on consent (e.g. marketing or certain learning activities), you can withdraw it at any time; this will not affect processing that has already occurred.

To exercise any of these rights, contact us at [email protected]. We may need to verify your identity before fulfilling your request. We aim to respond within one month, as required by law.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Website: ico.org.uk

Telephone: +44 (0)303 123 1113

We would, however, appreciate the chance to address your concerns first, so please contact us in the first instance.

10. COOKIES AND SIMILAR TECHNOLOGIES

Newbold Connect uses cookies and similar technologies provided by Kajabi and integrated tools to:

Enable core site functionality (e.g. login, checkout, video playback)
Understand usage patterns and improve the Platform (analytics)
Remember preferences (e.g. language, cookie choices)
Support marketing activities, where you have given consent

Under UK law, we must obtain your consent for non-essential cookies (such as analytics and marketing cookies). Kajabi provides mechanisms to support consent management. It is our responsibility as the controller to configure the banner appropriately and honour your choices, and it is your choice as a user to manage your preferences through the cookie banner or your browser settings.

When you visit the Platform, you will see a cookie banner giving you options to:

Accept all cookies
Reject non-essential cookies
Manage your preferences

You can change your cookie preferences at any time via the cookie settings link (e.g. in the footer) or through your browser settings. Some features may not function properly if you disable certain cookies.

For more details, including the types of cookies we use and their purposes, please see our Cookies Policy and Kajabi’s article “What are the cookies Kajabi uses?” (which we draw on to document the cookies used on Newbold Connect).

11. SECURITY

We and Kajabi implement appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, misuse, or alteration, including:

Encrypted connections (HTTPS)
Access controls and password policies
Secure configuration of our platform and hosting
Contracts and data protection obligations with Kajabi and other processors
Kajabi’s own internal security and compliance measures, designed to support GDPR and other privacy regulations.

However, no system is entirely secure. We cannot guarantee absolute security, and you are responsible for:

Keeping your password confidential
Logging out of your account on shared devices
Telling us immediately if you suspect unauthorised access to your account

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, for example:

To reflect changes to our services or platform architecture
To reflect significant changes in our use of Kajabi or other providers
To respond to legal or regulatory developments
To clarify our practices

Updated versions will be posted on this page with a revised “Last updated” date. Where we make material changes, we will take reasonable steps to notify registered users (e.g. via email or in-platform notices).

Your continued use of the Platform after changes take effect indicates that you have read and understood the updated Policy.

13. CONTACT

For privacy enquiries or to exercise your rights, please contact: