Privacy Policy

Last updated: June 2026

Who we are

Progressa Pathways is operated by Progressa Systems Ltd, the data controller for personal data processed through this site. You can contact our privacy team at privacy@progressa.systems.

What we collect

  • Account data — your name, email, password (hashed), and role (learner, employer, supporter, or supported internship provider).
  • Profile data — anything you choose to add: postcode, age band, bio, interests, accessibility preferences, support preferences, and (for employers) company details.
  • Activity data — applications you send, jobs you save, opportunities you publish.
  • Technical data — minimal logs needed to keep the service running and secure (IP address at sign-in, error reports).

Special category data

Some information you may share — accessibility needs, disability-related support preferences, private support notes — is "special category" data under UK GDPR Article 9. We process this only with your explicit consent (given when you fill in those optional sections), only to match you with suitable opportunities and to let employers prepare appropriate support, and only with strict access controls so that no other learner or unrelated employer can see it.

Lawful basis

  • Contract — for everything you need to use the service (your account, applications, employer listings).
  • Consent — for special category data (above), for optional cookies, and for marketing emails.
  • Legitimate interest — for security, fraud prevention, and to keep the platform safe.
  • Legal obligation — for tax records linked to paid subscriptions.

How long we keep it

  • Active accounts — for as long as the account is open. You can delete your account at any time from your profile.
  • After deletion — your personal data is erased immediately. Audit logs that record the deletion itself are kept for 12 months for security.
  • Billing records — kept for 6 years to meet UK tax law.
  • Inactive accounts — we may delete accounts that have been unused for 24 months after warning you by email.

Who we share it with

We never sell your data. We share only what is needed to run the service:

  • Employers see only the application details you choose to send them.
  • Supporters see only what you allow when you link them to your profile.
  • Service providers (data processors): Lovable Cloud (hosting, database, authentication, file storage — based in the EU) and our AI summarisation service (used to generate Easy Read versions of listings; only the listing text is sent, never your personal data).

International transfers

Most processing happens in the UK / EEA. Where a processor processes data outside the UK, we rely on the UK International Data Transfer Addendum and Standard Contractual Clauses with appropriate safeguards.

Your rights

Under UK GDPR you have the right to access, correct, delete, restrict, or port your data, and to object to processing or withdraw consent. You can exercise the two main rights instantly from your profile page:

  • Download my data — instant JSON export of everything we hold.
  • Delete my account — instant erasure across all our systems.

For anything else, email privacy@progressa.systems. You also have the right to complain to the UK Information Commissioner’s Office at ico.org.uk.

Cookies

We use a small number of essential cookies to keep you signed in and the site secure — these are always on. Any optional analytics or marketing cookies require your consent, which you give (or refuse) using the cookie banner. You can change your choice any time by clearing the progressa-cookie-consent-v1 entry in your browser’s site data and reloading the page.

Children

This service is intended for users aged 16 and over. If you are under 16 and have created an account, please ask a parent or supporter to contact us so we can remove it.

Changes to this policy

If we make material changes, we will notify you by email and update the "Last updated" date above.