MY THEORY COACH

Privacy Policy

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Effective date: 16 September 2026

This policy explains what personal information My Theory Coach collects, why we use it, how long we keep it, who we may share it with, and the choices and rights available to you.

1. Who we are

My Theory Coach is an online UK car theory-learning service available at mytheorycoach.co.uk. It is operated by Ashford Driving Academy. For data protection purposes, Ashford Driving Academy is the controller of personal information collected through My Theory Coach.

You can contact us through the Contact page at mytheorycoach.co.uk or by telephone/WhatsApp on 0330 043 0451.

2. Information we may collect

Depending on how you use My Theory Coach, we may collect the following information:

Account and contact details, such as your name, email address and account/member identifier.

Subscription and transaction information, such as your plan status, renewal date, payment status and transaction references. We do not need to see or store your full card details.

Learning profile information you choose to provide, such as preferred language, current theory level, learning preferences or areas you find difficult.

Learning activity, such as quiz and mock-test attempts, answers, scores, topics studied, progress history, features used, session dates and approximate time spent using the service.

Questions and messages submitted to the Theory Coach or the website assistant, together with the responses generated.

Support enquiries, complaints, refund requests and related correspondence.

Technical and website-use information, such as device/browser information, log data, security events, cookie choices and analytics information where enabled.

Official theory-test result or other outcome information only if you choose to provide it to us for progress or service-evaluation purposes.

3. Information about learning needs and neurodiversity

You may choose to tell My Theory Coach that you have, or identify with, a learning need or condition such as autism, ADHD, dyslexia or anxiety. Information of this kind may reveal health or disability information and can be special category data under UK data protection law.

Providing this information is optional. Where we ask for or use special category information to personalise learning or evaluate how the service works for different learner groups, we will rely on your explicit consent as well as an appropriate UK GDPR lawful basis. You can withdraw that consent for future use at any time.

We will not use information about neurodiversity, disability, anxiety or other health-related matters to target advertising, pressure you to buy, or decide whether you are allowed to subscribe.

4. Why we use personal information

We use personal information for the following purposes:

To create and manage member accounts and provide access to My Theory Coach.

To administer monthly subscriptions, renewals, cancellations, refunds and customer support.

To save learning progress and allow learners to continue where they left off.

To provide quizzes, mock tests, explanations, language support and personalised learning assistance.

To maintain security, prevent misuse, diagnose faults and investigate technical problems.

To understand how learners use the service, including session length, starting scores, later scores, topic performance and feature usage, so we can evaluate and improve the service.

To understand the types of questions visitors ask the website assistant and, where appropriate, whether an enquiry later results in a subscription, so we can improve information on the website and identify where visitors may be getting stuck.

To produce aggregated or anonymised statistics about learning progress, service performance and user experience.

5. Our lawful bases

The lawful basis depends on why we are using the information. We may rely on:

Contract: where processing is needed to provide the subscription, member account, Theory Coach access or features you have requested.

Legal obligation: where we must keep or disclose information to comply with tax, accounting, consumer or other legal requirements.

Legitimate interests: where we need to operate securely, improve the product, understand usage, analyse common website questions, measure the customer journey or protect the business, provided those interests are not overridden by your rights and interests.

Consent: where consent is required, including certain cookies or similar technologies.

Explicit consent: where you voluntarily provide special category information, such as health, disability or neurodiversity information, and we use it for personalisation, evaluation or research-type analysis.

6. Learning progress and outcome monitoring

My Theory Coach may measure learning progress over time. This can include a starting or baseline score, later quiz/mock scores, topics attempted, questions answered, approximate time spent, feature use and later assessment results. Where you voluntarily tell us an official test result, we may also use that information to understand outcomes.

The purpose is to understand whether the service is helping learners and which features are most useful. Where possible, reporting will use aggregated or anonymised information rather than identifying individual learners.

We do not use these measures to make solely automated decisions that have legal or similarly significant effects on you.

7. Website assistant questions and enquiry analysis

When you use the website assistant, we may keep the question you asked, the assistant response, the date/time and a limited session or account identifier where available. We may analyse this information to identify common questions, improve the website, improve the assistant and understand where an enquiry does or does not lead to a subscription.

We will aim to use the minimum information necessary for this analysis. Where we only need overall trends, we will use aggregated or anonymised data. We do not sell these questions or use sensitive learning/health information to target sales messages.

8. Artificial intelligence processing

My Theory Coach and the website assistant use artificial intelligence services to generate explanations and responses. Questions or prompts may therefore be sent to our AI service provider for processing so that a response can be generated.

At the time of this policy, the service uses OpenAI API technology. OpenAI states that API inputs and outputs are not used to train its models by default unless the API customer explicitly opts in to data sharing. We do not ask learners to include unnecessary sensitive or confidential information in free-text questions.

AI-generated information may occasionally be incorrect. My Theory Coach is a learning aid and does not replace the Highway Code, DVSA information, professional legal advice or other authoritative sources.

9. Payments

Payments and recurring subscriptions are processed through the website and its payment providers, including Wix and the payment services connected to Wix. Payment providers may process card and payment information under their own privacy terms and security arrangements.

We may receive limited information about a transaction, such as whether a payment succeeded, the amount, date, plan and transaction reference. We do not need to store your full payment-card number or security code.

10. Cookies and analytics

The website uses cookies and similar technologies. Some are strictly necessary for functions such as security, login, membership and payment. Other cookies or analytics technologies may help us understand website use and improve the service.

Where UK law requires consent for non-essential cookies or similar technologies, they will only be used after you have been given a clear choice. You can change your cookie choices using the website cookie controls where available.

This Privacy Policy does not replace a cookie notice or cookie-consent banner. The website should provide separate information and controls for non-essential cookies.

11. Who we may share information with

We may share personal information with trusted service providers where this is necessary to operate My Theory Coach. These may include:

Wix and its processors, for website hosting, membership, subscriptions, payments, communications and site functionality.

Payment processors connected to Wix, for processing payments and recurring subscriptions.

OpenAI, for AI processing used by the Theory Coach and website assistant.

Email, support, security, analytics or technical service providers that we choose to use.

Professional advisers, regulators, law-enforcement bodies or other parties where disclosure is required or permitted by law.

We do not sell personal information to advertisers.

12. International transfers

Some technology providers used by My Theory Coach operate internationally, so personal information may be processed outside the United Kingdom. Where UK data protection law requires safeguards for an international transfer, we expect the relevant provider arrangements to use an approved transfer mechanism, adequacy arrangement or other lawful safeguard.

13. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, taking account of legal, accounting, security and dispute-resolution requirements. Our current approach is:

Account, subscription and transaction records may be kept for up to six years after the relevant transaction or end of the customer relationship where needed for tax, accounting or legal purposes.

Learning progress and identifiable usage records will normally be kept while an account is active and for up to 24 months after the last meaningful account activity, unless there is a good reason to keep them longer or you ask for earlier deletion where the law allows.

Website-assistant questions and ordinary support logs will normally be kept for up to 12 months, unless they are needed for an ongoing support issue, complaint, security investigation or legal claim.

Optional special category profile information will be kept only while it is useful for the purpose you consented to, and will be deleted or anonymised when it is no longer needed or where consent is withdrawn and no other lawful reason requires retention.

Aggregated or genuinely anonymised statistics may be retained for longer because they no longer identify an individual.

14. Security

We use reasonable technical and organisational measures to protect personal information. These include access controls, account authentication, secure website connections and use of established technology providers. No online system can be guaranteed to be completely secure, so we also aim to minimise the personal information we collect and retain.

15. Your data-protection rights

Depending on the circumstances and the lawful basis we rely on, you may have rights to:

Ask for access to the personal information we hold about you.

Ask us to correct inaccurate or incomplete information.

Ask us to erase information in certain circumstances.

Ask us to restrict processing in certain circumstances.

Object to processing based on legitimate interests.

Receive certain information in a portable format where the right to data portability applies.

Withdraw consent at any time where we rely on consent or explicit consent. Withdrawal does not make earlier lawful processing unlawful.

To exercise a right, contact us through mytheorycoach.co.uk. We may need to verify your identity before acting on a request.

You also have the right to complain to the UK Information Commissioner's Office (ICO) if you are unhappy with how your personal information has been handled.

16. Children and younger learners

My Theory Coach may be used by learner drivers who are under 18. We therefore aim to use clear language, collect only information that is necessary, apply a high level of privacy by default and avoid using children's information for unnecessary commercial profiling.

Where a feature involves optional sensitive information, analytics or profiling that may affect younger users, we will consider the additional protections required by UK data-protection law and the Children's Code. Where appropriate, we may use age-appropriate notices or consent steps.

17. Changes to this policy

We may update this Privacy Policy when the service, technology, legal requirements or data practices change. The latest version will be published on mytheorycoach.co.uk with an updated effective date. If we introduce a materially new use of personal information, we will provide appropriate information before that processing begins.

18. Contact

For privacy questions, access requests or other data-protection enquiries, please contact My Theory Coach through the Contact page at mytheorycoach.co.uk or on 0330 043 0451.

This document is intended as a practical privacy notice for the service. It should be kept under review as new analytics, research, marketing or third-party integrations are introduced.