Last updated: 11 June 2026

Privacy Policy — Lights On Learning

1. Who We Are

This Privacy Policy explains how Explorium Ltd ("we", "us", "our") collects, uses, stores and shares your personal data. We trade as Lights On Learning, Lights On Families, Lights On Mum, Julia Black, Lights On and Discover Lights On.

We are the data controller for personal data collected through our websites (www.lightsonuniverse.com and www.explorium.co.uk) and our programmes, courses, coaching and community.

If you have any questions about this policy or how we handle your data, please contact our Data Protection Contact:

Julia Black — Data Protection Contact

Email: teamlightson@lightsonuniverse.co.uk

Address: Betchworth House, 57-65 Station Road, Redhill, Surrey, United Kingdom, RH1 1DL

2. What Personal Data We Collect and Why

We collect and process the following categories of personal data. For each category we explain what we collect, why we collect it and the lawful basis we rely on under UK GDPR.

2.1 Contact and identity data

Name, email address, postal address, phone number. Collected when you contact us, sign up to our email list, register for a workshop or purchase a product.

Lawful basis: Contract and legitimate interests.

2.2 Purchase and payment data

Details of products purchased, payment amounts and transaction history. Payment card details are processed directly by Stripe — we do not store card details ourselves.

Lawful basis: Contract; legal obligation for accounting and tax records.

2.3 Programme and coaching data

Information you share during coaching calls, community participation, self-reflection exercises (via Google Forms), scorecard responses (via ScoreApp) and any other programme activity. This may include information about your family situation, your children's learning, wellbeing, behaviour or educational needs.

Lawful basis: Contract; and where sensitive information is involved, explicit consent (see Section 2.4).

2.4 Sensitive and special category data

Given the nature of our work — supporting families and children's learning — you may choose to share information that is sensitive or constitutes special category data under UK GDPR. This includes information relating to health, wellbeing, neurodiversity, mental health, anxiety, school refusal or family circumstances.

Sharing sensitive information is entirely voluntary. We only process it where you have freely chosen to share it as part of your programme participation. We handle it with the highest level of care.

Consent for sensitive information:

By participating in our programme you consent to Explorium Ltd processing sensitive information you choose to share about yourself, your family, your child's learning needs, wellbeing, neurodiversity or mental health, where necessary to provide the programme, support your participation, manage the community, respond to queries or concerns, and meet legal or safeguarding responsibilities.

You can withdraw this consent at any time by contacting us at teamlightson@lightsonuniverse.co.uk. Withdrawal of consent does not affect processing already carried out, and we may retain limited records where needed for legal, safeguarding, complaints or business reasons.

Lawful basis: Article 6 contract or legitimate interests, plus Article 9 explicit consent for special category data.

2.5 Communications data

Any communications you send us by email, contact form, social media or any other channel.

Lawful basis: Legitimate interests (to respond to you and keep records).

2.6 Marketing data

Your email address and marketing preferences, including whether you have subscribed to our newsletter or email list via Kit (formerly ConvertKit).

Lawful basis: Consent (where you opted in) or legitimate interests under the soft opt-in for existing customers, subject to your right to opt out at any time.

2.7 Technical and usage data

Basic technical data about your visit to our websites, such as your IP address, browser type and pages visited. We do not currently run Google Analytics or advertising tracking pixels on www.lightsonuniverse.com. See our Cookie Policy for details.

Lawful basis: Legitimate interests (to maintain and improve our website).

3. How We Collect Your Data

We collect personal data in the following ways:

4. How We Use Your Data

We use your personal data to:

We will only use your data for the purpose it was collected for, or a reasonably compatible purpose. If we need to use your data for a new purpose we will tell you and explain the legal basis.

5. Platforms and Third-Party Processors

We use the following platforms to deliver our services. Each acts as a data processor on our behalf, processing your data only as instructed by us and in accordance with data processing terms:

PlatformPurposeLocationTransfer safeguard
KajabiSales pages, checkout and course deliveryUSAStandard Contractual Clauses
Mighty NetworksCommunity platformUSAStandard Contractual Clauses
Kit (ConvertKit)Email marketingUSAStandard Contractual Clauses
ScoreAppScorecard assessmentsUKN/A — UK based
ZoomCoaching calls and recordingsUSAStandard Contractual Clauses
Google FormsSelf-reflection exercisesUSAStandard Contractual Clauses
Google WorkspaceInternal email and file storageUSAStandard Contractual Clauses
StripePayment processingUSAStandard Contractual Clauses
WebflowWebsite hostingUSAStandard Contractual Clauses
CloudflareWebsite securityUSAStandard Contractual Clauses
TidycalSession bookingUSAStandard Contractual Clauses
Social platforms (Meta, LinkedIn, YouTube)Social media presenceUSAStandard Contractual Clauses

We do not sell your personal data to any third party. We may share data with professional advisers (lawyers, accountants, insurers) where necessary, and with government bodies where required by law.

6. International Transfers

Several of our platforms are based in the United States. When we transfer your personal data outside the UK we ensure appropriate safeguards are in place. For US-based processors we rely on Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner, together with a UK Addendum where applicable, or the UK-US Data Bridge where the processor participates in it.

If you would like more information about the safeguards in place for any specific transfer, please contact us at teamlightson@lightsonuniverse.co.uk.

7. Marketing Communications

We will only send you marketing emails if you have consented to receive them, or if you are an existing customer and we are marketing similar products or services — in which case you have a right to opt out at any time.

You can unsubscribe from our marketing emails at any time by clicking the unsubscribe link in any email or by emailing teamlightson@lightsonuniverse.co.uk. Opting out of marketing does not affect service emails related to a product you have purchased.

8. Call Recordings, Transcripts and AI Summaries

8.1 Programme coaching calls

Where your programme includes live coaching calls on Zoom, these calls are recorded. By joining a call you consent to being recorded. Recordings are stored securely and made accessible to programme participants only via Mighty Networks.

We use AI-assisted tools to produce transcripts and summaries of coaching calls. These summaries and key takeaways are shared with programme participants via Mighty Networks. Before any recording or transcript is processed by an AI tool, we anonymise it, removing names, children's identifiers and any other identifying personal details wherever possible. The AI tool receives anonymised content only.

8.2 Workshop recordings and marketing use

Where workshops are recorded or transcribed, anonymised excerpts or key themes may also be used for marketing purposes, for example to illustrate the impact of our approach or share insights from the session. No identifying information (including names, specific family situations or details that could identify a participant) will be used for marketing purposes without your separate explicit consent. Anonymised general themes, learnings or participant responses may be shared without individual consent where there is no reasonable risk of identification.

8.3 Recording notice

A separate Recording, Replay and Transcript Notice is included in your programme terms and welcome emails, setting out full details of how recordings are handled, who can access replays, and how you can avoid being visually recorded where needed.

9. How Long We Keep Your Data

We know you may want to understand how long we hold information about you and your family. We keep personal data only for as long as we need it for the purposes described in this Privacy Policy, including to provide our services, manage customer access, keep business and financial records, comply with legal, tax and accounting requirements, respond to queries or complaints, and protect our legitimate business interests.

Where the law requires us to keep certain records, we keep them for at least the required period. Company accounting and financial records are usually kept for at least 6 years from the end of the financial year they relate to, and may be kept for longer where legally or practically necessary.

The table below sets out our approach for each type of data we collect:

Type of dataHow long we usually keep it
Customer, purchase and payment recordsFor at least 6 years after the financial year they relate to, and longer where needed for tax, accounting, legal, customer service, dispute resolution or business record-keeping purposes.
Programme participation recordsFor as long as needed to provide the programme, manage access, support participants, respond to queries or complaints, and maintain appropriate business records.
Coaching notes, self-reflection forms and scorecard responsesFor as long as needed for the purpose collected, including programme support, customer care, service improvement, complaints, safeguarding or legal reasons. Reviewed periodically and deleted or anonymised when no longer needed.
Call recordings and replaysUsually for the period during which replay access is offered, unless needed longer for legal, safeguarding, complaint-handling, training or business reasons.
Transcripts and AI-assisted summariesKept only for as long as needed for the purpose created, then deleted, anonymised or archived.
Community posts and commentsUsually kept while the community space is active or while you remain a member, unless deleted, removed at your request, or retained for moderation, safeguarding, complaint-handling or legal reasons.
Email marketing dataUntil you unsubscribe, withdraw consent, object to marketing or ask us to delete your data. We may keep a suppression record to ensure we do not contact you again.
General enquiries and correspondenceFor as long as needed to respond and maintain appropriate business records. Reviewed periodically and deleted when no longer needed.
Testimonials and case study permissionsFor as long as we use the testimonial or case study, unless you withdraw your permission.

We may keep some information for longer where we need it to establish, exercise or defend legal claims, comply with legal or regulatory obligations, resolve disputes, or support safeguarding responsibilities.

We may anonymise personal data so that it can no longer identify you. We may use anonymised information for reflection, service improvement, training, content planning and business development.

10. Your Rights

Under UK GDPR you have the following rights in relation to your personal data:

To exercise any of these rights, email teamlightson@lightsonuniverse.co.uk. We will respond within one month. We may need to verify your identity before acting on your request. You will not normally need to pay a fee.

11. Your Right to Complain

11.1 Complain to us directly

From 19 June 2026, you have a statutory right under section 164A of the Data Protection Act 2018 to raise a data protection complaint directly with us.

How to raise a data protection complaint with us:

Email: teamlightson@lightsonuniverse.co.uk

Subject line: Data Protection Complaint

We will acknowledge your complaint within 30 days of receipt and investigate without undue delay.

We will communicate the outcome of our investigation to you in writing.

Full details of our complaints procedure are available on request.

11.2 Complain to the ICO

If you are not satisfied with our response you have the right to complain to the Information Commissioner's Office (ICO):

The ICO expects individuals to raise a complaint with the controller first. We would always encourage you to contact us first so we can try to resolve any concern directly.

12. Data Security

We take appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, alteration or disclosure. Access to your data is limited to those with a genuine need to process it.

We have procedures in place to deal with any suspected data breach and will notify you and the ICO where legally required to do so.

13. Third-Party Links

Our websites contain links to third-party websites and platforms including Mighty Networks, ScoreApp, Kajabi and social media profiles. This Privacy Policy applies only to our own websites. We are not responsible for the privacy practices of third-party sites and encourage you to read their privacy policies.

14. Children's Information

Our services are designed for adults and parents. They are not intended for children to use independently. Parents and guardians may choose to share information about their children as part of their programme participation — please share only what is relevant and what you are comfortable sharing. Information about children is treated with additional care.

We do not knowingly collect personal data directly from children. If you believe we have inadvertently received data about a child without appropriate consent, please contact us immediately at teamlightson@lightsonuniverse.co.uk.

15. Cookies

Our website www.lightsonuniverse.com uses only strictly necessary cookies, confirmed by a recent cookie scan. Our sales site www.explorium.co.uk has a cookie consent banner allowing you to manage your cookie preferences.

For full details please see our Cookie Policy.

16. Changes to This Policy

We review this Privacy Policy regularly and will update it when our data practices change or when required by law. The version date at the top of this page shows when it was last updated. We will notify active clients of any material changes by email at least 30 days before they take effect.

17. Contact Us

For any questions about this Privacy Policy or how we handle your data:

Explorium Ltd trading as Lights On Learning

Data Protection Contact: Julia Black

Email: teamlightson@lightsonuniverse.co.uk

Address: Betchworth House, 57-65 Station Road, Redhill, Surrey, United Kingdom, RH1 1DL

Website: www.lightsonuniverse.com