Privacy Policy
Last updated: 20th November 2025
1. Who We Are
Working Smarter Learning (“WSL”) is part of ThenSomehow, which is a trading name of RABSON AND STARK LIMITED (“we”, “us”, “our”).
Data Controller:
RABSON AND STARK LIMITED
of Haywards Heath RH17 7BA
Contact email: [email protected]
We are committed to protecting your personal data and respecting your privacy.
2. What Personal Data We Collect
We collect the following categories of information:
Information you provide to us
When you create an account, enrol in a course, subscribe, download resources, or contact us, we collect:
Name
Email address
Any information you voluntarily provide (e.g., survey responses, messages, feedback)
Course usage data
When using WSL, we may collect:
Course progress
Quiz results
Completion status
Interactions with course content
Technical and device information
Collected automatically through our platform (Thinkific) or analytics tools:
IP address
Device type
Browser type
Operating system
Time zone
Log data (pages viewed, links clicked, session duration)
Payment information
If you purchase a paid product, payments are processed securely by third-party providers (e.g., Stripe, PayPal).
We do not store your full payment card information.
Cookies and tracking technologies
We use cookies and similar technologies for:
Essential site functionality – required for login, account creation, and course access
Analytics and performance – help us understand website usage
Functionality – remember your preferences
Marketing (where consent is given) – to track your activity
You can manage or block cookies via your browser, but disabling essential cookies may limit your access.
3. How We Use Your Personal Data
We use your personal data for the following purposes:
To provide our services (Contractual necessity)
Creating and managing your account
Delivering courses, lessons, and resources
Providing customer support
Processing purchases and transactions
To improve our services (Legitimate interests)
Monitoring performance and usage
Troubleshooting technical issues
Enhancing course content and user experience
To send you marketing communications (Consent)
If you opt in, we may email you about:
New courses or updates
Resources, articles, or events
Insights from ThenSomehow
Our products and services
You can withdraw consent at any time by clicking “unsubscribe” or emailing us.
To ensure security and comply with the law
Protecting against fraud or misuse
Meeting our legal and tax responsibilities
4. Lawful Bases for Processing
We process personal data under the following lawful bases:
Consent – for email marketing and optional communications.
Contractual necessity – to provide access to courses and account features.
Legitimate interests – for analytics, service improvement, and site security.
Legal obligations – where required for financial, regulatory, or compliance reasons.
5. Sharing Your Personal Data
We share your data only with trusted third parties necessary to provide our services. These include:
Thinkific (LMS platform hosting the courses)
Email service providers (e.g., Mailchimp, ConvertKit, HubSpot—depending on our current provider)
Payment processors (Stripe, PayPal)
Analytics tools (e.g., Google Analytics)
Cloud hosting or IT service providers
These parties may process your data only according to our instructions and for the purposes of providing their services.
We do not sell your personal data.
6. International Data Transfers
Some of our service providers are located outside the UK or European Economic Area (EEA).
We ensure all international transfers comply with GDPR using:
Adequacy decisions (e.g., Canada, where Thinkific is based)
Standard Contractual Clauses (SCCs) for US and other providers
Additional safeguards where required
7. Data Retention
We retain personal data only as long as necessary for the purposes described above.
Typical retention periods:
Account data: until you delete your account or request deletion
Marketing data: until you withdraw consent (unsubscribe)
Course activity data: retained while your account remains active
Transaction data: up to 6 years (legal requirement)
When we no longer need your data, we securely delete or anonymise it.
8. Your Rights Under GDPR
You have the following rights over your personal data:
Right of access – to request a copy of your personal data
Right to rectification – to correct inaccurate information
Right to erasure – to request your data be deleted
Right to restrict processing
Right to data portability
Right to object – including to marketing
Right to withdraw consent – at any time
Right to lodge a complaint with the UK ICO (www.ico.org.uk)
To exercise any rights, contact us at: [email protected].
9. Cookies and Tracking Technologies
We use cookies to:
Make our site function
Remember your preferences
Analyse site usage
Improve performance
Provide relevant content (where consented)
Non-essential cookies will only run after you give consent via our cookie banner.
You can adjust your cookie preferences at any time.
10. Children
Our services are not intended for children under the age of 16.
By using our site, you confirm you are at least the age of majority in your region.
11. Links to Other Websites
Our content may contain links to third-party websites.
We are not responsible for their privacy practices and recommend reviewing their privacy policies.
12. Changes to This Policy
We may update this Privacy Policy from time to time.
Changes take effect when posted on this page.
If we make material changes, we will notify you on our website or by email.
13. Contact Us
If you have questions, concerns, or wish to exercise your rights, please contact us:
Or write to us at the address below:
ThenSomehow
c/o Rabson Stark Limited
Suite C2 Horsted Keynes Business Park
Cinder Hill Lane
Horsted Keynes, Haywards Heath
RH17 7BA