1. Who we are

This policy explains how Niyo Labs Ltd (“Niyo”, “we”, “us”, “our”), part of the Niyo group of companies, handles personal data. We are the controller of the personal data described here, which means we decide how and why it is used. We are registered with the Information Commissioner’s Office (ICO) under registration number ZB050051. Niyo Labs Ltd is registered in England and Wales under company number 11371368.

We follow the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and the Data (Use and Access) Act 2025.

This policy covers:

• visitors to our websites, including people who use Ask Niyo or the AI career map
• people who apply for, join or complete our programmes, including She Builds and our open cohorts
• users of Niyo Learn
• employers, SMEs, corporates, funders and other partners, and the people we deal with there
• mentors, coaches, speakers and volunteers
• job applicants
• people who sign up to our updates or attend our events

Our employees receive a separate staff privacy notice. If a funder or partner runs a programme with us and is also a controller of your data, they will give you their own privacy notice as well.

2. Contact us and our Data Protection Officer

Our Data Protection Officer (DPO) oversees how we handle personal data and answers questions about this policy, including requests to use your rights.

Email

compliance@niyo.co

Post

Data Protection Officer, Niyo Labs Ltd, UG05 Zellig Building, Gibb Street, Birmingham, B9 4AT, United Kingdom

If you need this policy in another format, such as large print, audio or plain text, please ask us.

3. The personal data we collect

Personal data is any information that identifies you, directly or indirectly. It does not include anonymised data. Depending on how you deal with us, we may collect:

If you do not give us information we need for a contract or a legal requirement (for example, the evidence a funder needs to confirm you are eligible), we may not be able to offer you a place on that programme. We will always tell you when this is the case.

4. Where we get your data

• From you, when you fill in a form, apply, use Niyo Learn, take part in a programme, attend an event, email us or talk to us.
• From partners who refer you, such as employers, funders, local authorities, combined authorities, Jobcentre Plus and community organisations.
• From employers who sponsor or second you onto a programme, or who interview you through Demo & Hire.
• From public sources, such as LinkedIn and Companies House, for business contacts.
• From our technology, such as our website, Niyo Learn and our email tools, through cookies and similar technologies (see section 10).

5. How we use your data and our lawful bases

We only use personal data when the law allows us to. For each purpose, we rely on one of the following lawful bases under Article 6 of the UK GDPR:

• Contract: we need the data to give you a service you have asked for, or to take steps before entering into a contract with you.
• Legal obligation: the law requires us to use the data.
• Legitimate interests: we use the data for our reasonable business interests, or those of a third party, in a way you would expect and that does not override your rights. You can ask us for the balancing test we carried out.
• Consent: you have clearly agreed. You can withdraw consent at any time, and this does not affect anything we did before you withdrew it.
• Public task: in some funded programmes, we use data to carry out a task in the public interest on behalf of a public body.

Change of purpose. We only use your data for the purpose we collected it for, or for a purpose that is compatible with it. If we need to use it for an unrelated purpose, we will tell you first and explain our lawful basis.

6. Sensitive data

Some information is given extra protection by law. This includes ethnicity, health and disability, religion, sexual orientation, and data about criminal convictions. We only collect it when we need to, and we protect it with extra safeguards.

• Equality monitoring. We ask optional questions to check that our programmes reach and serve people fairly, and to report anonymised figures to funders. You can choose “prefer not to say”. We rely on the substantial public interest condition for equality of opportunity or treatment (Data Protection Act 2018, Schedule 1, paragraph 8), or on your explicit consent where we ask for it.
• Health, disability and access needs. We use what you tell us to make reasonable adjustments and support you. We rely on our obligations under the Equality Act 2010, or on your explicit consent.
• Safeguarding. If we are worried about your safety or someone else’s, we may record and share information with the right authorities. We rely on the safeguarding of children and individuals at risk condition (Data Protection Act 2018, Schedule 1, paragraph 18) and, where relevant, our Prevent duty.
• Criminal records. We only carry out criminal record (DBS) checks for roles that legally require them, such as staff and mentors working with young or vulnerable learners, and in line with the law.

We keep an appropriate policy document that explains how we comply with the law when we rely on these conditions. You can ask us for a copy.

7. Funded programmes

Many of our programmes are funded by government and industry partners, including Innovate UK. Funders need certain information to check eligibility, pay for places, measure results and prevent fraud. For funded programmes, we may share your data with:

• the funder of your programme, such as the Department for Education, Innovate UK, the Department for Science, Innovation and Technology, or a combined authority
• the Learner Records Service, where a programme requires a Unique Learner Number
• Ofsted, for inspections
• auditors and evaluators the funder appoints

These organisations may use the data as controllers in their own right, under their own privacy notices. Before you enrol, we will tell you who funds your programme and point you to their notice. Funders may also contact you after the programme to ask how it helped you.

8. AI and automated decisions

We use AI to make our services more useful, for example in Ask Niyo, the AI career map and parts of Niyo Learn.

• What you type is sent to our AI service providers to generate a response. They act as our processors, under contracts that stop them using your data to train their own models.
• Please do not enter sensitive personal information, such as health details, into Ask Niyo.
• AI answers can be wrong. For anything binding, email info@niyo.co.
• The career map suggests programmes based on your answers. These are recommendations only.
• We do not make decisions about you that have legal or similarly significant effects (such as accepting or rejecting an application) using solely automated processing. A member of our team reviews every application.
• If we ever introduce significant automated decision-making, we will tell you first, explain how it works, and give you the right to have a person review it, to give your views, and to challenge the decision.

9. Marketing

We only send marketing emails or texts to individuals who have opted in, or who have bought or applied for a similar service from us and did not opt out at the time (the “soft opt-in”). We may send relevant updates to business contacts at their work email address, based on our legitimate interests.

Every message includes an unsubscribe link. You can also email compliance@niyo.co at any time. When you unsubscribe, we keep your email on a suppression list so we do not contact you again. Unsubscribing does not affect messages we need to send about a programme you are on.

We never sell your personal data, and we do not share it with third parties for their own marketing.

10. Cookies and similar technologies

Our website stores a small amount of information on your device. For example, it remembers whether you chose light or dark mode. Storage like this is strictly necessary to provide something you asked for, so it does not need your consent.

We only use non-essential cookies, such as for advertising, with your consent. Where the law allows, we may use analytics to understand how our site is used and improve it. If we do, we will tell you clearly and give you a simple way to say no. Our cookie policy lists the cookies we use.

11. Who we share your data with

We share personal data only when we need to, and only as much as is necessary:

• Service providers (processors) who work for us under contract and only on our instructions. These cover cloud hosting, our CRM and email platforms, our learning platform, video calls, payments, HR and recruitment, AI services, IT support and security.
• Employers and partners involved in your programme, such as when we introduce you for an interview, a live brief or Demo & Hire. We share only what is needed, and we tell you before we do.
• Payl8r, our finance partner, if you choose to spread the cost of a programme. Social Money Ltd t/a Payl8r is a separate controller. It will carry out identity, credit and affordability checks, and handle your application under its own privacy notice. We share only the details needed to set up your plan, such as your name, contact details and the programme cost, and Payl8r tells us whether your plan is approved and how payments are going.
• Funders, regulators and inspectors, as described in section 7.
• Other Niyo group companies, where they help deliver a service to you.
• Professional advisors, such as lawyers, accountants, auditors and insurers.
• Police, courts and other authorities, when the law requires it, to protect someone from harm, or to establish or defend legal claims.
• A buyer or investor, if we sell, merge or restructure all or part of our business. Your data would remain protected under this policy, and we would tell you about any change of controller.

12. International transfers

We store and process personal data mainly in the UK and the European Economic Area. Some of our service providers may process data in other countries, such as the United States. When data leaves the UK, we make sure it is protected. We do this either by transferring it to a country the UK has approved as having adequate protection (including US organisations certified under the UK Extension to the EU–US Data Privacy Framework), or by using the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment. You can ask us for details of these safeguards.

13. How we protect your data

We are Cyber Essentials certified, which means our security controls have been independently checked against the UK Government’s cyber security standard. Our measures include:

• encryption in transit and, where available, at rest
• role-based access and multi-factor authentication
• confidentiality obligations for everyone who works for us
• regular data protection training
• careful checks on the suppliers we use

No system is completely secure, but we work hard to protect your data and we keep our measures under review. If a personal data breach happens, we will report it to the ICO within 72 hours where the law requires us to. If the breach is likely to put your rights at high risk, we will tell you without undue delay.

14. How long we keep your data

We keep personal data only for as long as we need it for the purpose we collected it for, including to meet legal, accounting, funder and reporting requirements. Our standard retention periods are:

We may keep data for longer if there is a complaint, a legal claim or an investigation. When we no longer need data, we delete it securely or anonymise it.

15. Your rights

Under UK data protection law, you have the right to:

• Access: get a copy of your personal data and information about how we use it.
• Rectification: have inaccurate or incomplete data corrected.
• Erasure: have your data deleted where we have no good reason to keep it.
• Restriction: ask us to pause using your data, for example while we check its accuracy.
• Object: object to us using your data on the basis of legitimate interests or public task, and to direct marketing at any time.
• Portability: receive data you gave us in a commonly used, machine-readable format, or have it sent to another organisation.
• Withdraw consent: wherever we rely on your consent.
• Rights about automated decisions: see section 8.

To use any of these rights, email compliance@niyo.co. You do not usually need to pay. We may ask you to confirm your identity before we act. We will reply within one month. If your request is complex, or you make several requests, we may extend this by up to two more months, and we will tell you why. When you ask for a copy of your data, we will carry out reasonable and proportionate searches. If a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse it, and we will explain why. Some rights do not apply in every situation; for example, we may need to keep certain records for a funder. If a right does not apply, we will tell you why.

If you have a Niyo Learn account, you can view and update much of your information yourself, and close your account at any time.

16. Complaints

If you are unhappy with how we have handled your data, please tell us first so we can put it right. Email compliance@niyo.co. We will acknowledge your complaint within 30 days, investigate it, and tell you the outcome without undue delay.

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection, at ico.org.uk/make-a-complaint ↗ or on 0303 123 1113.

17. Young people

Our website and programmes are for people aged 16 and over. If a programme includes learners aged 16 or 17, we follow our safeguarding policy, give information in clear and age-appropriate language, and involve a parent or carer where that is appropriate. We do not knowingly collect personal data from children under 16. If you think we have, please contact us and we will delete it.

18. Other websites

Our site links to other websites, such as funders, certification registries and event platforms. We are not responsible for how they handle your data, so please read their privacy notices.

19. Changes to this policy

We review this policy regularly. If we make significant changes, we will post them here and, where appropriate, tell you by email before they take effect. This version was last updated on 8 October 2026.

1. Purpose and scope

This policy explains how Niyo Labs Ltd (“Niyo”, “we”, “us”) selects, contracts, pays, manages and exits the organisations and individuals in our supply chain. It also explains how we keep quality high and protect learners, clients and funders when we work with others.

It applies to everything we do, including:

• our AI accelerator programmes, delivered through She Builds and open cohorts
• our Founder Path and entrepreneurship programmes
• Niyo Learn and our other digital products
• SME projects, corporate training and workforce programmes
• programmes we deliver for government, combined authorities and other funders
• events, career days and Demo & Hire

It covers delivery partners and subcontractors (for example, training providers, tutors, coaches, assessors and mentors engaged under contract), associates and freelancers, employer and industry partners who contribute to delivery, and suppliers of technology, venues, content, marketing and professional services.

Where a funder or commissioning body sets its own subcontracting rules, we follow those rules as well as this policy. If the two differ, the stricter requirement applies.

2. Why we use a supply chain

We work with partners when they help us deliver a better result than we could alone. We do this to:

• bring specialist expertise and industry practice into our programmes
• reach learners and communities we would not otherwise reach
• give learners and clients more choice, flexibility and access to employers
• deliver at the right scale, on time and at a fair cost
• build capacity in smaller, specialist and underrepresented-led organisations

We do not subcontract simply to pass on work or to earn a margin. Each partnership must add clear value for learners, clients or funders.

3. Roles and responsibilities

• Board and senior leadership own this policy, approve significant partnerships and high-value contracts, and oversee supply chain risk.
• Programme and service leads identify the need for a partner, manage day-to-day delivery, and monitor quality and learner experience.
• Operations and finance run due diligence, contracts, payments, fees and audit trails.
• Our compliance lead oversees data protection, safeguarding and regulatory requirements across the supply chain. Contact them at compliance@niyo.co.
• Partners and suppliers deliver to the agreed standard, follow this policy and their contract, and tell us promptly about any issue.

4. Choosing partners

Identifying the need. Before we bring in a partner, we confirm what is needed, why we cannot or should not deliver it ourselves, and what success looks like.

Fair selection. We choose partners through an open and proportionate process. For larger contracts, we compare quotes or run a competitive process. We record why we chose each partner.

Selection criteria include:

• expertise, qualifications and track record in the area
• quality of delivery, learner outcomes and references
• fit with our mission, values and learners
• value for money
• financial stability and appropriate insurance
• safeguarding arrangements, including DBS checks where needed
• data protection and information security, with Cyber Essentials or equivalent for partners handling personal data
• commitment to equality, diversity and inclusion
• social value, including fair pay, local employment and environmental responsibility

Due diligence. Before work starts, we check legal status, insurance, safeguarding, data protection, conflicts of interest and, where relevant, registration on the UK Register of Learning Providers and any funder eligibility rules. We repeat checks proportionately during the contract.

5. Contracts and onboarding

Every partnership has a written agreement before delivery starts. Agreements set out:

• the scope of work, deliverables, standards and timescales
• fees, payment terms and any charges
• how quality and performance are measured, and what happens if standards are not met
• safeguarding, Prevent, equality, health and safety, and data protection duties, including a data processing agreement where the partner handles personal data on our behalf
• intellectual property, confidentiality and conflicts of interest
• funder requirements that pass down to the partner, including audit access
• notice, termination, handover and exit arrangements

New partners receive an induction to our standards, systems and learners. This includes any mandatory training, such as safeguarding, Prevent and data protection.

6. Fees and charges

Where we lead a programme and subcontract part of its delivery, we may keep part of the funding or charge a fee to cover the support and assurance we provide. Any fee is agreed in writing before delivery starts and may cover:

• Quality assurance, including observations, learner feedback, assessment sampling and improvement planning
• Contract and programme management, including recruitment and enrolment support, scheduling and partner liaison
• Compliance and funder reporting, including eligibility checks, evidence, data returns and audit
• Systems and platforms, including access to Niyo Learn and our learner management tools
• Mandatory training and other agreed support or resources

We set fees openly, keep them proportionate to the support given, and review them at least once a year. Where a funder requires it, we publish our fee rates and the support they pay for.

Under-delivery. If a partner does not deliver what was agreed (for example, if they deliver fewer guided learning hours, fewer learners or lower-quality outputs), we may reduce or recover payments in proportion, as set out in the contract.

Paying partners. We pay correctly invoiced, undisputed invoices on the terms agreed in the contract. We aim to pay smaller partners promptly, and we pass on funder payment terms where they apply.

7. Value for money

All costs must be reasonable and proportionate. We judge this by:

• market rates and benchmarking against similar services
• the complexity, specialism and risk of the work
• the quality and outcomes the cost secures
• compliance with funder rules and value for money requirements

We use competitive quotes or tendering for higher-value purchases. When we deliver public contracts, we follow the Procurement Act 2023 and any procurement rules our funder sets.

8. Ethics and compliance

We expect every partner and supplier to meet the same standards we hold ourselves to:

• Safeguarding and Prevent. Partners who work with learners follow our safeguarding and Prevent policy, carry out DBS checks where required, and report concerns to our designated safeguarding lead without delay.
• Data protection. Partners comply with the UK GDPR and the Data Protection Act 2018, and only process personal data as our contract allows. See our privacy policy.
• Information security. Partners who handle our data or systems keep appropriate security controls. We prefer Cyber Essentials certification or an equivalent standard.
• Equality, diversity and inclusion. Partners comply with the Equality Act 2010 and support fair access for every learner.
• Fair work. As a Living Wage Employer, we expect partners to treat their people fairly. Third-party contractors who regularly work for us must be paid at least the real Living Wage.
• Anti-bribery, fraud and tax evasion. We do not tolerate bribery, fraud, or helping anyone to evade tax, in line with the Bribery Act 2010 and the Criminal Finances Act 2017. Gifts and hospitality must be modest and recorded.
• Modern slavery. We do not tolerate modern slavery or human trafficking anywhere in our supply chain, and we expect partners to take the same approach (Modern Slavery Act 2015).
• Conflicts of interest. Staff and partners must declare any conflict of interest. Anyone with a conflict takes no part in the decision.
• Health and safety. Partners keep learners, staff and visitors safe in line with health and safety law.
• Environment. We prefer partners who reduce waste, travel and their environmental impact.

We may audit partners, ask for evidence, or visit delivery, with reasonable notice. Serious breaches can lead to suspension or termination of the contract, and to us reporting the matter to a funder or the relevant authority.

9. Quality and performance

We manage partner performance actively and fairly:

• We agree clear standards and key performance indicators at the start, such as attendance, completion, learner satisfaction, progression and job outcomes.
• We monitor delivery through observations, learner and client feedback, data and regular review meetings.
• We share findings openly, and we agree improvement plans with partners when standards slip.
• We include partner delivery in our self-assessment and our readiness for Ofsted inspection, since we remain responsible for the quality of all provision delivered in our name.
• We take learner, client and partner feedback seriously and use it to improve this policy and our programmes.

10. Risk management

For each significant partnership, we identify and manage the risks, including:

• poor quality or inconsistent delivery
• a partner leaving, or becoming unable to deliver
• scheduling conflicts and capacity gaps
• data breaches or security incidents
• safeguarding incidents
• financial failure, fraud or non-compliance with funder rules
• disputes and damage to our reputation

We avoid relying too heavily on any single partner for critical delivery, and we keep a contingency option for each key service.

11. Continuity and contingency

Our aim is that learners and clients feel little or no disruption if a partner has to step away, whether temporarily or permanently.

Notification and assessment. Partners must tell their Niyo programme lead as soon as they know they cannot deliver. The programme lead assesses the impact with senior leadership and agrees a response within two working days.

Temporary cover. We reschedule sessions where needed, or provide a qualified substitute from our team or approved associates. We give them the materials, context and briefing they need.

Permanent replacement. We appoint a new partner using the selection criteria in section 4, and we onboard them with a full handover, so learners keep their progress.

Supporting learners and clients. We tell learners and clients promptly and clearly about any change, explain what it means for them, and offer extra support where needed, such as catch-up sessions, additional coaching or wellbeing support.

12. Exiting a partnership

When a partnership ends, whether through completion, notice, non-renewal or termination, we manage the exit professionally and respectfully. This includes:

• agreeing a handover plan and timeline
• handing over learner records, progress reports, materials and work in progress
• returning or securely deleting personal data, and confirming this in writing
• removing access to our systems and platforms on the day the partnership ends
• settling final payments, including any adjustments for under-delivery
• holding an exit review to capture feedback and lessons learned

We aim to end partnerships on good terms, and we will provide a fair reference where appropriate.

13. Records and reporting

We keep clear records of how we select partners, our contracts, fees, payments, performance and outcomes. We report openly to funders and commissioners, such as the Department for Education, Innovate UK and combined authorities, as our agreements require. We keep these records for at least six years, or longer if a funder requires it.

14. Raising concerns

Anyone can raise a concern about a partner, a supplier or how this policy is applied. This includes learners, clients, staff and partners themselves. Email compliance@niyo.co. You can also raise concerns in confidence under our whistleblowing policy. We will never treat anyone unfairly for raising a concern in good faith.

15. Review

Senior leadership reviews this policy at least once a year, and also before we start a new programme or contract that relies on partners, or when the law or funder rules change. This version was last updated on 8 October 2026.

1. Our commitment

Niyo Labs Ltd (“Niyo”, “we”, “us”) is committed to the highest standards of honesty, openness and accountability across everything we do: our AI accelerator programmes (including She Builds and open cohorts), the Founder Path, Niyo Learn, our work with SMEs, corporates and governments, our events, and the work our partners deliver for us.

Speaking up protects learners, clients, funders, colleagues and Niyo itself. This policy encourages anyone who suspects wrongdoing to raise it early and in the right way. It explains how we will respond, and the protection you have under the Public Interest Disclosure Act 1998, which is part of the Employment Rights Act 1996.

2. Who can use this policy

This policy applies to everyone who works with or for Niyo, including:

• employees, including those on fixed-term, part-time or probationary contracts
• workers, agency staff, interns and apprentices
• freelancers, associates, contractors and consultants
• coaches, mentors, tutors, assessors and volunteers
• delivery partners, subcontractors and suppliers, and their staff
• board members and advisors
• former staff and partners

Learners, employers, funders and members of the public can also use this route to raise serious concerns about wrongdoing. The legal protection for whistleblowers mainly covers workers, but we will treat everyone who raises a genuine concern fairly and with respect.

3. What counts as whistleblowing

Whistleblowing means telling us about wrongdoing that affects others or the public interest. You can raise a concern about something that has happened, is happening, or is likely to happen, including:

• fraud, theft, bribery or financial mismanagement, including misuse of public or grant funding
• false or misleading claims to funders, such as about learner eligibility, attendance, outcomes or evidence
• a criminal offence
• failure to meet a legal obligation, or a breach of contract or funding rules
• risks to the health, safety or wellbeing of learners, staff or anyone else
• safeguarding failures, or a failure to follow our safeguarding or Prevent policies
• serious breaches of data protection or information security
• discrimination, harassment (including sexual harassment) or bullying that is being ignored or covered up
• damage to the environment
• academic or assessment malpractice, such as falsifying results
• serious breaches of our policies, such as conflicts of interest, or our supply chain policy
• deliberately hiding any of the above

You do not need proof. You only need a reasonable belief that wrongdoing has happened, is happening or is likely to happen, and, for legal protection, that raising it is in the public interest. If you are not sure, raise it anyway.

4. What this policy does not cover

Some issues have their own procedures, which will usually deal with them faster and better:

• Personal grievances about your own employment, such as pay, workload or a disagreement with a manager, go through our grievance procedure. If a personal issue also involves wider wrongdoing, you can raise it under this policy.
• Complaints about the quality of a programme or service go through our complaints and appeals process.
• Safeguarding concerns about a learner or anyone at risk must be reported to our designated safeguarding lead straight away under our safeguarding policy. Do not wait to use this policy. If someone is in immediate danger, call 999.
• Data protection requests about your own information are covered in our privacy policy.

5. How to raise a concern

Step 1: Speak to your Niyo contact or manager. For many concerns, the quickest route is to tell your line manager or programme lead, in person or in writing. They will pass it to the Whistleblowing Officer.

Step 2: Contact the Whistleblowing Officer directly. If you prefer not to speak to your manager, if they are involved, or if nothing has happened, contact our Whistleblowing Officer:

Email

compliance@niyo.co, with “Whistleblowing” in the subject line

Post

Private and confidential, Whistleblowing Officer, Niyo Labs Ltd, UG05 Zellig Building, Gibb Street, Birmingham, B9 4AT

Step 3: Escalate if you need to. If your concern involves the Whistleblowing Officer, write to the Chief Executive. If it involves the Chief Executive, or you believe it has not been handled properly, write to the Chair of the Board. Use the postal address above and mark the envelope “Private and confidential, for the attention of the Chair”.

What to include. If you can, tell us what happened, when and where, who was involved, how you know, and any documents or evidence. Do not investigate the matter yourself, gather evidence in ways that break the law or our policies, or confront the people involved.

You can bring a colleague or trade union representative to any meeting about your concern. They must respect confidentiality.

6. Confidentiality and anonymity

We will keep your identity confidential and share it only with the people who need to know to investigate, unless you agree otherwise or the law requires us to share it. If we need to share your identity, we will talk to you first wherever we can.

You can raise a concern anonymously, and we will look into it. However, anonymous concerns are harder to investigate, we cannot give you feedback, and it is harder to protect you. We encourage you to give your name and trust us to keep it confidential.

Please keep the fact that you have raised a concern, and any details of it, confidential too. This protects you, the investigation and anyone involved.

7. What happens next

• Within 5 working days, we acknowledge your concern and, where possible, offer you a meeting.
• Within 10 working days, the Whistleblowing Officer assesses the concern and decides on next steps. These could be an internal investigation, an independent investigator, referral to another procedure, or reporting to the police, a funder, Ofsted or another regulator.
• During the investigation, we keep you updated on progress and expected timescales. We aim to finish most investigations within 3 months, and we tell you if it will take longer.
• At the end, we tell you the outcome as far as we can. Confidentiality and legal duties to others may limit how much we can share.

People named in a concern will be treated fairly. They will be told about the allegations at the right time and given the chance to respond. Nobody will be judged until the facts are established.

If we find wrongdoing, we will act to stop it, put it right and prevent it happening again. This may include disciplinary action, ending a contract, recovering funds, and reporting to the relevant authorities. If you are not satisfied with how we handled your concern, you can escalate it as set out in section 5, or raise it with an external body as set out in section 9.

8. Your protection

We will not tolerate anyone being harassed, victimised, disadvantaged or dismissed for raising a genuine concern, even if it turns out to be mistaken. This includes threats, exclusion, loss of work, or a partner losing a contract. Anyone who retaliates against a whistleblower, or tries to stop someone from speaking up, will face disciplinary action or the end of their contract.

If you believe you have been treated badly for raising a concern, tell the Whistleblowing Officer or the Chair of the Board straight away.

No agreement with Niyo, including a confidentiality clause or settlement agreement, can stop you from making a protected disclosure.

Deliberately making a false or malicious allegation is a serious matter and may lead to disciplinary action. This does not apply to honest mistakes.

9. Raising a concern outside Niyo

We hope you will feel able to raise concerns with us first, and in most cases that is the best way to resolve them. However, the law allows you to raise concerns with a prescribed person or regulator, and in some situations you may feel you need to. Relevant bodies include:

• Ofsted, for concerns about the quality of education and training, or safeguarding
• The Department for Education, Innovate UK or the combined authority that funds your programme, for concerns about the use of public funding
• The Information Commissioner’s Office, for data protection concerns
• The Health and Safety Executive, for health and safety risks
• HM Revenue and Customs and the Serious Fraud Office, for tax or serious fraud

The government publishes the full list of prescribed people and bodies ↗.

Independent advice. Protect ↗, the whistleblowing charity, gives free and confidential advice on 020 3117 2520. You can also get advice from a trade union or a solicitor. Talking to a legal advisor in confidence is always protected.

We strongly discourage going to the media or posting online. In most cases, you will not be legally protected if you do, unless strict conditions are met.

10. Roles and responsibilities

• The Board has overall responsibility for this policy, receives anonymised reports of concerns and outcomes, and handles concerns about the Chief Executive.
• The Chief Executive makes sure concerns are taken seriously and resourced properly.
• The Whistleblowing Officer receives and assesses concerns, oversees investigations, protects whistleblowers, keeps records, and reports to the Board.
• Managers and programme leads listen to concerns, pass them on promptly, and make sure nobody is treated unfairly for speaking up.
• Everyone covered by this policy should raise genuine concerns and support investigations.
• Delivery partners must have their own whistleblowing arrangements, tell their staff about this policy, and report concerns about Niyo-funded work to us.

We train managers to handle concerns well, and we explain this policy during induction for staff and partners.

11. Records and data

We keep secure, confidential records of every concern, the investigation and the outcome. We keep them for 6 years after the case closes, or longer if a legal claim or funder requires it. We handle the personal data involved in line with the UK GDPR, the Data Protection Act 2018 and our privacy policy.

12. Review

The Board reviews this policy at least once a year, and also when the law or funder requirements change. We use anonymised data on concerns and outcomes to check the policy is working and that people feel safe to speak up. This version was last updated on 8 October 2026.

This policy does not form part of any employment contract, and we may change it at any time.

1. Our commitment and scope

Niyo Labs Ltd (“Niyo”) believes everyone has the right to learn and work free from harm. Safeguarding means protecting people’s health, wellbeing and human rights, and enabling them to live free from abuse, harm and neglect. We take a whole-organisation approach: safeguarding is everyone’s responsibility, not only the safeguarding team’s.

This policy applies to all our activity: our AI accelerator programmes (She Builds and open cohorts), the Founder Path, Niyo Learn and other online learning, SME and corporate programmes, government-funded delivery, events, career days and Demo & Hire. It applies to employees, associates, freelancers, coaches, mentors, volunteers, board members, and to delivery partners and subcontractors working on our behalf.

It protects all learners, including those aged 16 and 17, who are children in law, and adults at risk: anyone aged 18 or over who has care and support needs, is experiencing or at risk of abuse or neglect, and cannot protect themselves because of those needs.

2. Legal and statutory framework

This policy follows:

• the Children Act 1989 and 2004, Working Together to Safeguard Children and Keeping Children Safe in Education, for learners under 18
• the Care Act 2014, for adults at risk
• the Counter-Terrorism and Security Act 2015 and the Prevent duty guidance
• the Safeguarding Vulnerable Groups Act 2006, and Disclosure and Barring Service (DBS) requirements
• the Equality Act 2010, the Human Rights Act 1998, the UK GDPR and the Data Protection Act 2018
• the Online Safety Act 2023, and the requirements of Ofsted and our funders

3. Roles and responsibilities

• The Board has overall responsibility for safeguarding. A named board member champions safeguarding and reviews this policy and anonymised safeguarding reports at least once a year.
• The Designated Safeguarding Lead (DSL) is a senior member of staff trained to an advanced level. They lead our safeguarding and Prevent work, receive and act on concerns, make referrals, keep records and advise colleagues.
• Deputy Designated Safeguarding Leads cover when the DSL is unavailable, so there is always someone to contact during delivery hours.
• Managers and programme leads make sure their teams and partners understand this policy, and make sure safeguarding is built into the design of every programme and event.
• Everyone must be alert to signs of harm, report concerns straight away, and never promise to keep a disclosure secret.
• Delivery partners must have their own safeguarding and Prevent arrangements that meet our standards, and must report any concern about Niyo learners to our DSL the same day.

4. Recognising abuse and risk

Abuse can be physical, emotional, sexual, financial or material. It can also take the form of neglect, self-neglect, discrimination, domestic abuse, coercive control, modern slavery, organisational abuse, or exploitation, including criminal and sexual exploitation and county lines. Other risks we look out for include:

• mental health crises, suicidal thoughts and self-harm
• radicalisation and extremism
• online abuse, harassment, sextortion, scams and the misuse of AI, such as deepfakes
• sexual harassment and sexual violence, including between learners
• forced marriage, female genital mutilation and so-called honour-based abuse
• homelessness, and financial hardship that puts someone at risk

Changes in behaviour, attendance, appearance or engagement can all be signs that someone needs help.

5. How to report a concern

If someone is in immediate danger, call 999.

If a learner tells you something: stay calm and listen. Do not ask leading questions or investigate. Explain that you cannot keep it secret but will only share it with people who need to know. Write down what was said, in their words, as soon as possible, with the date, time and your signature.

Report it the same day to the DSL or a deputy: email compliance@niyo.co with “Safeguarding” in the subject line, or speak to your programme lead, who will contact the DSL straight away. If you cannot reach the safeguarding team and someone is at risk, contact the local authority children’s or adult social care team, or the police, directly.

If the concern is about a member of staff, an associate or a partner, report it to the DSL, or to the Chief Executive if the concern involves the DSL. For concerns about anyone working with learners under 18, we involve the Local Authority Designated Officer (LADO). We follow our duty to refer to the DBS when the law requires it.

Learners can raise concerns about themselves or others with any member of Niyo staff, or directly with the safeguarding team.

6. How we respond

• The DSL assesses every concern promptly and decides on action, which might be support from Niyo, a referral to specialist services, a referral to social care, or a report to the police.
• Wherever possible, we involve the person concerned and respect their wishes. For adults, we work with their consent unless there is a risk to them or others, a crime, or a legal duty to act.
• We share information lawfully and only on a need-to-know basis. Data protection law never stops us sharing information to keep someone safe.
• We keep secure, confidential records of every concern, decision and action, separate from learning records.

7. Prevent

As a provider of education and training, we have a duty to have due regard to the need to prevent people from being drawn into terrorism. We meet this duty in a proportionate way, as part of our wider safeguarding work. We:

• assess the risk of radicalisation in our programmes, and keep an action plan up to date
• train staff and partners to recognise people who may be vulnerable to radicalisation, and to know what to do
• promote fundamental British values: democracy, the rule of law, individual liberty, and mutual respect and tolerance for people of different faiths and beliefs, and none
• make sure external speakers and events are checked and managed
• filter and monitor our online platforms appropriately
• work with local Prevent teams and, where needed, refer people to Channel, a voluntary, confidential programme that offers support

Prevent concerns are reported to the DSL in the same way as any other safeguarding concern. The Prevent duty does not limit lawful free speech or debate. Our programmes encourage people to discuss difficult ideas respectfully. If you suspect terrorist activity, call the Anti-Terrorist Hotline on 0800 789 321, or 999 in an emergency.

8. Online safety

Much of our learning happens online, through Niyo Learn, live sessions and community spaces. We:

• set clear codes of conduct for learners, staff and partners in all online spaces
• use secure platforms, and moderate community channels
• never allow one-to-one contact with learners under 18 through personal accounts or private messaging
• teach learners about online safety and the responsible use of AI as part of our programmes
• deal quickly with online bullying, harassment, image-based abuse and inappropriate content

9. Safer recruitment and training

• We follow safer recruitment practice for everyone who works with learners. This includes identity and right-to-work checks, two references, an explanation of any gaps in employment history, and DBS checks at the right level for the role.
• Interview panels for roles working with learners include someone trained in safer recruitment.
• Everyone completes safeguarding and Prevent training at induction, with regular refresher training. The DSL and deputies complete advanced training at least every two years.
• Our code of conduct sets clear professional boundaries, including on personal relationships, gifts, social media and lone working.

10. Partners, employers and events

Employers and partners who host learners, run live briefs or take part in Demo & Hire must follow our safeguarding expectations. Where needed, we carry out health and safety and safeguarding checks on venues and placements. We give hosts a named Niyo contact, and we brief them on how to report concerns. Events have a safeguarding plan and a named lead on the day.

11. Support and wellbeing

We want learners to thrive, not just stay safe. We offer pastoral support, signpost learners to specialist services, and make reasonable adjustments. If you are struggling and need to talk now, you can contact Samaritans for free at any time on 116 123.

12. Review

The Board reviews this policy at least once a year, after any serious incident, and when the law or statutory guidance changes. This version was last updated on 8 October 2026.

1. Why this matters to us

Niyo began by opening technology careers to people ready to take them. The next decade of work will be shaped by AI, and we believe the people who build it should reflect the society it serves. Equality, diversity and inclusion are not a policy add-on for us. They are the reason our programmes exist.

This policy applies to Niyo Labs Ltd and to everything we do: our programmes, Niyo Learn, our work with SMEs, corporates and governments, our events, our recruitment, and our partners and suppliers.

2. Our legal duties

We comply with the Equality Act 2010, which protects people from discrimination because of nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origin), religion or belief, sex, and sexual orientation.

We do not tolerate:

• direct discrimination, which means treating someone less favourably because of a protected characteristic
• indirect discrimination, which means applying a rule or practice that puts people with a protected characteristic at an unfair disadvantage, without good reason
• harassment, including sexual harassment, which means unwanted conduct that violates someone’s dignity or creates a hostile environment
• victimisation, which means treating someone badly because they have complained about discrimination or supported someone else’s complaint
• failure to make reasonable adjustments for disabled people

We take reasonable steps to prevent sexual harassment of our staff, as the Worker Protection (Amendment of Equality Act 2010) Act 2023 requires. We also expect the same standards in every learning space we run.

3. She Builds and positive action

Women remain significantly underrepresented in AI and technology roles, and among founders who receive investment. To help address this, we run She Builds, a women-only route into two AI accelerator programmes, with 100 places fully funded by Innovate UK and DCMS: AI Transformation & Productivity (women adopt AI tools at a 25% lower rate than men, Harvard Business School) and Cybersecurity & AI (women are 16% of the UK cyber workforce and 12% of senior roles, DSIT 2026). Our other accelerators run open to everyone only. It is provided as positive action under section 158 of the Equality Act 2010. This allows organisations to offer targeted training and support to a group that is underrepresented or at a disadvantage, when it is a proportionate way to address that gap.

Every She Builds programme is also available through an open cohort, so nobody is excluded from the learning itself. We review the evidence for She Builds regularly, to make sure it remains justified and proportionate.

We may also take other lawful positive action. This could include targeted outreach to underrepresented communities, bursaries, or extra support for people facing particular barriers. Positive action never means lowering standards, and in recruitment we always appoint on merit.

4. For learners

• Our programmes are designed so people can join from any background, including those without a degree or a technical history. We set entry criteria based on what people need to succeed, not on traditional credentials.
• We personalise learning pathways to each person’s goals, starting point and circumstances.
• We offer flexible formats and timings, and we design for accessibility from the start, including captioned content and materials compatible with screen readers.
• We make reasonable adjustments for disabled learners and learners with long-term conditions or learning differences. Tell us what you need at any point, and we will work with you to agree adjustments.
• We support learners from different faiths and cultures, including reasonable flexibility around religious observance.
• We challenge discriminatory language or behaviour in sessions, online spaces and events.

5. For our people

• We recruit, pay, develop and promote people fairly and on merit. We use structured interviews and diverse panels where we can.
• We are a Living Wage Employer.
• We support flexible working, and parents and carers, and we make reasonable adjustments for colleagues.
• We train everyone in equality, inclusion and preventing harassment.

6. For employers, partners and suppliers

We expect our partners to share these values and to comply with the Equality Act 2010. We help employers that recruit from our programmes to use inclusive hiring practices, and we will not work with organisations that discriminate unlawfully. See our supply chain policy.

7. Measuring progress

We ask learners and applicants optional equality monitoring questions so we can see who we reach, who progresses and where barriers remain. Answers are confidential, stored separately from assessments, and never used to make decisions about individuals. We report findings in anonymised form to our Board and funders, and we use them to improve. See our privacy policy.

8. Raising a concern

If you have experienced or seen discrimination, harassment or victimisation, please tell us. Learners and clients can use our complaints and appeals policy. Staff can use our grievance procedure. Anyone can use our whistleblowing policy for wider wrongdoing. We will never treat anyone unfairly for raising a concern in good faith.

9. Responsibilities and review

The Board and Chief Executive are accountable for this policy, and every manager is responsible for putting it into practice. Everyone who works with us is expected to treat others with dignity and respect. The Board reviews this policy at least once a year. This version was last updated on 8 October 2026.

1. Who can complain and about what

Anyone who uses or is affected by Niyo Labs Ltd’s services can make a complaint. This includes learners, applicants, employers, SMEs, corporate and government clients, partners, and members of the public. You can complain about:

• the quality of teaching, coaching, materials or Niyo Learn
• the information, advice or support we gave you
• how you were treated by our staff, associates or partners
• administration, communication or delays
• discrimination, harassment or a failure to make reasonable adjustments
• events, venues and employer activities we organised

You can also appeal certain decisions (see section 6). Some issues follow a different process: safeguarding concerns (see our safeguarding policy), whistleblowing (see our whistleblowing policy), requests about your personal data (see our privacy policy), and staff grievances.

2. Our principles

• Complaining is easy, free and confidential.
• We treat every complaint fairly and objectively. Complaints are investigated by someone who was not involved in the matter.
• We never treat anyone less favourably because they made a complaint.
• We offer help to anyone who needs it to make a complaint, including reasonable adjustments and accessible formats. You can bring someone to support you, or ask someone to complain on your behalf with your permission.
• We learn from every complaint and use what we learn to improve.

3. Stage 1: Resolve it informally

Many concerns can be resolved quickly. Speak or write to your programme lead, coach or main Niyo contact. They will try to resolve the issue within 5 working days. If you would rather not speak to them, or the issue is serious, go straight to Stage 2.

4. Stage 2: Make a formal complaint

Email compliance@niyo.co with “Complaint” in the subject line, or write to Niyo Labs Ltd, UG05 Zellig Building, Gibb Street, Birmingham, B9 4AT. Please include:

• your name and contact details, and your programme or service
• what happened, when, and who was involved
• what you have already done to resolve it
• what you would like us to do to put things right

Please complain as soon as possible, ideally within 3 months of the issue, or of you becoming aware of it. We may accept complaints after this if there is a good reason.

What happens next:

• We acknowledge your complaint within 5 working days and tell you who is handling it.
• A senior member of staff who was not involved investigates. They may ask to speak to you and to others.
• We send you a full written response within 20 working days. It explains what we found, what we will do, and how to escalate if you are not satisfied. If the investigation needs longer, we tell you why and give you a new date.

5. Stage 3: Review by senior leadership

If you are not satisfied with our Stage 2 response, you can ask for a review within 10 working days of receiving it. Email compliance@niyo.co and explain why. The Chief Executive, or a director or board member they nominate who has not been involved, will review how your complaint was handled and the outcome, and respond within 20 working days. This is our final internal response.

6. Appeals

You can appeal against a decision we have made about you, including:

• an assessment result, grade, certificate decision, or a judgement of malpractice
• a decision about your eligibility for a funded place, or about your application
• withdrawal from a programme, or a decision under our learner code of conduct
• a decision about reasonable adjustments

To appeal, email compliance@niyo.co with “Appeal” in the subject line within 10 working days of being told the decision. Explain which decision you are appealing and why, and include any evidence. Grounds for appeal include: the correct procedure was not followed; relevant evidence was not considered; new evidence has come to light; or the decision was unreasonable.

We acknowledge your appeal within 5 working days. Someone who was not involved in the original decision reviews it and gives you a written outcome within 15 working days. For assessments that lead to an external qualification, you can then appeal to the awarding organisation under its own procedure. We will tell you how.

7. If you are still not satisfied

If you have been through our process and are still unhappy, you can contact:

• the funder of your programme, such as the Department for Education, Innovate UK or a combined authority. We will tell you who funds your programme and how to contact them.
• Ofsted, for concerns about the quality of education and training, or about leadership and management, at gov.uk ↗
• the awarding organisation, for appeals about external qualifications
• the Information Commissioner’s Office, for data protection complaints, at ico.org.uk ↗

Consumers also have rights under the Consumer Rights Act 2015, and may choose to take independent legal advice.

8. Records and learning

We keep confidential records of complaints and appeals for 6 years, in line with our privacy policy. We review all complaints regularly, report themes and actions to our Board, and use them to improve our programmes and services.

9. Unreasonable behaviour

We understand that people may be frustrated or upset when something has gone wrong. However, we will not tolerate abusive, threatening or discriminatory behaviour towards our staff. In rare cases, we may limit how someone contacts us, but we will still deal with any genuine complaint.

10. Review

We review this policy at least once a year. This version was last updated on 8 October 2026.

1. About us and these terms

This website and our programmes are run by Niyo Labs Ltd, a company registered in England and Wales under company number 11371368, with its address at UG05 Zellig Building, Gibb Street, Birmingham, B9 4AT (“Niyo”, “we”, “us”). You can contact us at info@niyo.co.

By using our website or joining a programme, you agree to these terms. Please read them along with our privacy policy, cookie policy, safeguarding policy and complaints and appeals policy. If you are a business, SME, corporate or government client, your signed contract with us takes priority over these terms if they conflict.

2. Part A: Using our website and Niyo Learn

• You may use our website for lawful, personal and business purposes. You must not misuse it. This includes trying to gain unauthorised access, introducing malicious code, scraping it at scale, or using it to harass anyone.
• We work to keep information accurate and up to date, but programme details, dates and funding can change. The details confirmed in your offer or contract apply.
• If you create a Niyo Learn account, keep your login details secure and do not share your account. You are responsible for activity on your account. Tell us straight away if you think someone else has used it.
• We may suspend or close accounts that break these terms, or that put other users or our platform at risk.
• We may update, suspend or withdraw any part of the website or Niyo Learn. Where possible, we will give you reasonable notice if this affects a service you rely on.

3. AI features

Ask Niyo, the AI career map and some Niyo Learn features use artificial intelligence. Their answers are generated automatically, and they can be incomplete or wrong. They are for general guidance only, and are not professional, legal, financial or careers advice. They do not create a contract or a promise of a place. Please do not enter sensitive personal information. A person makes every decision about your application. See our privacy policy to learn how we handle what you enter.

4. Intellectual property

We, or our licensors, own the content on our website and in our programmes. This includes text, designs, logos, videos, course materials and software. You may use programme materials for your own learning. You must not copy, sell, share, publish or use them to train AI models without our written permission.

“Niyo”, “She Builds”, “Rewrite the Code” and our logos are our trade marks.

5. Links to other sites

Our website links to other sites, such as funders, partners and certification registries. We do not control them and are not responsible for their content or their privacy practices.

6. Part B: Applying for a programme

• Submitting an application or completing the career map does not guarantee you a place. Places are confirmed only when we send you a written offer and you accept it.
• The information you give us must be true and complete. For funded programmes, we must check your eligibility. You agree to provide evidence when we ask, such as proof of identity, address, age, or right to live or work in the UK. We may withdraw an offer or a place if information is false or eligibility cannot be confirmed.
• Some programmes, including She Builds, are positive action programmes for specific groups. Our equality policy explains why. Each one is also available through an open cohort.

7. Funded places

Many of our programmes are funded by government and industry partners. If you take a funded place, you are not charged a fee, but you agree to:

• attend and take part in the programme as agreed, and tell us promptly if you need to miss a session or pause
• complete the assessments and project work the programme requires
• provide the information and evidence the funder needs, including about your progress and what you go on to do after the programme
• follow our learner code of conduct

Funders set the rules for these places. If you stop taking part without good reason, we may withdraw your place, so that it can be offered to someone else. We will always talk to you first, and take your circumstances into account. Some funders may limit whether you can take another funded place in the future.

8. Paid programmes, fees and cancellations

• For paid programmes, the price, what it includes and the payment terms are set out in your offer. Prices include VAT where it applies.
• Your 14-day right to cancel. If you buy a programme as a consumer online, by phone or by email, you can cancel within 14 days of the date your enrolment is confirmed, without giving a reason, under the Consumer Contracts Regulations 2013. We only start within those 14 days if you ask us to. If you do and then cancel, we may deduct a proportionate amount for the part of the programme already delivered. Your right to cancel ends once the programme has been fully delivered. If you consent to immediate access to digital content, such as self-paced content on Niyo Learn, you lose your right to cancel for that content once access begins. We ask for this consent at enrolment and confirm it in writing.
• To cancel, email info@niyo.co. Where a refund is due, we will pay it within 14 days of receiving your cancellation, using the original payment method, or in line with your finance provider’s procedures if you paid through Payl8r.
• After the cancellation period. Cancellations, refunds, deferrals and transfers are governed by our Cancellation & Refund Policy, which you review and accept when you enrol. Programme fees are not ordinarily refundable after the statutory cancellation period has expired or been lawfully lost, except where the law requires a refund or we expressly agree one.
• Paying monthly with Payl8r. You can spread the cost of a paid programme with Payl8r, our finance partner. Your finance agreement is a separate contract between you and Social Money Ltd t/a Payl8r, which is authorised and regulated by the Financial Conduct Authority (FRN 675283). Finance is subject to status and affordability checks. Niyo is not a lender and does not decide whether you are approved. If you cancel your enrolment within your 14-day cancellation period, your finance agreement is cancelled automatically and we will tell Payl8r. Outside that period, cancelling or withdrawing from a programme does not automatically cancel your finance agreement or remove any outstanding payments, so contact Payl8r directly to use your rights under it, including your separate right to withdraw within 14 days under the Consumer Credit Act 1974. Where we must give a refund by law, we will process it in line with Payl8r’s procedures. Before you apply, make sure you can afford the repayments. Missing payments could affect your credit rating.
• If you pay us directly in instalments and miss a payment, we will contact you before we take any action. We may pause your access until the payment is made.

9. Changes to programmes

We continually improve our programmes, and we may make reasonable changes to content, tutors, timetables or delivery methods. If we make a significant change that affects you, we will tell you as early as possible. If you do not accept it, you may withdraw and receive a refund of any fees for the part of the programme not yet delivered. If we cancel a programme, you will receive a full refund of any fees paid, or a place on another cohort if you prefer.

10. Learner conduct

We want every learning space to be safe, respectful and inclusive. You agree to treat others with respect, follow our safeguarding and online safety expectations, keep shared confidential information private, submit your own work, and use AI tools in line with each programme’s guidance. Serious or repeated breaches may lead to suspension or removal from a programme. You can appeal under our complaints and appeals policy.

11. Your work and employer opportunities

• You own the work you create on our programmes, such as your projects, code and pitch decks, except for any of our materials you have built into it.
• With your permission, we may showcase your work, story or photos. You can withdraw that permission at any time for future use.
• When you work on a live brief or project for an employer or SME, you may need to agree to that organisation’s terms, such as on confidentiality or ownership of what you create. We will tell you before you start.
• We introduce learners to employers through career days, Demo & Hire and our network. We cannot guarantee a job, an interview or investment.

12. Our responsibility to you

We will provide our programmes and services with reasonable care and skill. If we fail to keep to these terms, we are responsible for loss or damage you suffer that is a foreseeable result of our failure. We are not responsible for loss that was not foreseeable.

Nothing in these terms limits our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for anything else that the law does not allow us to limit. Nothing in these terms affects your legal rights as a consumer.

If you use our website or programmes for business purposes, we are not liable for loss of profits, business or opportunity. Our total liability to you is limited to the fees you paid for the relevant service, or £1,000 if no fees were paid.

13. Complaints, law and changes to these terms

If something goes wrong, please use our complaints and appeals policy.

These terms are governed by the law of England and Wales, and the courts of England and Wales have jurisdiction. If you are a consumer living in Scotland or Northern Ireland, you may also bring proceedings in your local courts.

If any part of these terms is found to be invalid, the rest of the terms still apply. If we choose not to enforce a term straight away, we can still enforce it later.

We may update these terms from time to time. The version that applies to a programme is the one in force when you accepted your offer. This version was last updated on 8 October 2026.

1. What cookies are

Cookies are small files that a website saves on your device. Similar technologies, such as local storage, do the same job. In this policy, “cookies” covers all of them. Under the Privacy and Electronic Communications Regulations (PECR), as updated by the Data (Use and Access) Act 2025, websites can only store information on your device without your consent if it is strictly necessary for a service you asked for, or falls within a small number of other exemptions.

2. Cookies we use

This website currently uses:

Ask Niyo and our forms do not set cookies of their own. When you use Ask Niyo, your question is processed as described in our privacy policy.

3. Analytics and other cookies

We do not currently use analytics, advertising or social media tracking cookies on this website. If we introduce them, we will update this policy first and:

• ask for your consent before setting any advertising, social media or other non-essential cookies, with options to accept or reject that are equally easy to use
• for analytics used only to improve our website, either ask for your consent or, where the law allows, give you clear information and a simple way to opt out
• never use cookies to sell your data or build advertising profiles

4. Niyo Learn and other services

When you sign in to Niyo Learn or another Niyo service, it uses strictly necessary cookies to keep you logged in and to keep your account secure. Any other cookies those services use are described there, and are only set with your consent where it is needed.

5. How to control cookies

You can delete or block cookies and local storage in your browser settings at any time. If you clear the niyo-theme setting, the site will return to its default dark mode. Blocking strictly necessary cookies may stop parts of the website, or Niyo Learn, from working. Find out more at ico.org.uk ↗.

6. Contact and changes

Questions about cookies? Email compliance@niyo.co. We update this policy whenever we change the cookies we use. This version was last updated on 8 October 2026.

1. Enrolment and payment commitment

By enrolling in a Niyo programme, learners commit to the programme fees and payment terms agreed at registration.

All programme fees are non-refundable following the expiry or lawful loss of applicable statutory cancellation rights, except where a refund is required by law or expressly agreed by Niyo.

This policy applies to learners who pay for a programme themselves, including through Payl8r. Funded places and places paid for by an employer are covered in section 8.

2. Statutory cancellation rights

Where applicable, learners who enrol online, by phone or by email have a statutory 14-day cancellation period, starting on the day their enrolment is confirmed.

Training services will not begin during this period unless the learner expressly requests it. Learners who expressly request that training services begin during this period may be required to pay a proportionate amount for services delivered before cancellation.

For qualifying digital content supplied immediately, learners may lose their statutory cancellation right once supply begins, provided they have given the legally required express consent and acknowledgement, and Niyo has confirmed this in writing. Learners who do not give this consent receive access once the cancellation period has ended.

3. How to cancel and how refunds are paid

To cancel, email info@niyo.co with your name, programme and a clear statement that you wish to cancel. You do not have to give a reason during the statutory cancellation period.

Where a refund is due, Niyo will issue it without undue delay and in any case within 14 days of receiving the cancellation, using the original payment method. Where the programme was paid for through Payl8r or another finance provider, the refund will be paid in line with that provider’s procedures (see section 5).

4. Cancellation after the statutory period

Once the applicable cancellation period has expired, Niyo does not ordinarily offer refunds for:

• Changes in personal circumstances or availability.
• A decision not to continue with the programme.
• Failure to attend scheduled training or participate in learning activities.
• Dissatisfaction arising solely from a change of personal preference or career goals.

Any cancellation charge or retention of fees will be subject to applicable consumer law, including requirements of fairness and proportionality. Where fees are retained, learners keep access to the programme for the period they have paid for.

5. Payl8r and third-party finance

Learners choosing Payl8r or another approved finance provider enter into a separate finance agreement.

If a learner cancels their enrolment within the statutory 14-day cancellation period, a linked finance agreement is cancelled automatically, as required by law, and Niyo will notify the finance provider.

Outside that period, cancellation or withdrawal from a programme does not automatically cancel a finance agreement or remove any outstanding payment obligations.

Learners must contact their finance provider directly to exercise their rights under their finance agreement, including the separate 14-day right to withdraw from a credit agreement under the Consumer Credit Act 1974.

Where Niyo is legally required to issue a refund, the refund will be processed in accordance with the applicable finance provider’s procedures.

6. Programme changes, cancellation and statutory rights

If Niyo cancels a programme, materially fails to deliver agreed services, or breaches applicable consumer rights, learners may be entitled to an appropriate refund or other remedy.

If Niyo makes a significant change to a programme that a learner does not accept, the learner may withdraw and receive a refund of fees paid for the part of the programme not yet delivered. Where Niyo cancels a programme, learners may choose a full refund of fees paid or a place on another cohort.

Nothing in this policy excludes or restricts statutory consumer rights.

7. Exceptional circumstances

Niyo may, at its discretion, consider programme deferrals or transfers where appropriate, for example where serious illness, bereavement or other circumstances outside a learner’s control prevent them from continuing. Any such arrangement must be agreed in writing and does not automatically entitle a learner to a refund.

8. Funded places and employer-paid places

Funded places. Learners on a place funded by government or industry partners are not charged programme fees, so the refund terms in this policy do not apply. Withdrawal from a funded place is managed under the funder’s rules and our terms and conditions.

Employer-paid places. Where an employer pays for a place, cancellations and refunds are governed by the contract between Niyo and the employer. Consumer cancellation rights do not apply to business purchases.

9. Acceptance

Learners must review and accept this policy before completing enrolment or entering into a finance arrangement.

Questions or complaints about this policy can be raised under our complaints and appeals policy.

10. Enrolment acknowledgements

When you enrol, you will be asked to confirm the following. The second and third statements only appear where they apply to your programme and start date. We record your selections and include them in your enrolment confirmation.

1. EveryoneI have read and agree to Niyo’s Cancellation & Refund Policy, including the restrictions on voluntary refunds after the applicable statutory cancellation period.
2. If your training starts within 14 days of enrollingI expressly request that Niyo begin delivering training services during my 14-day cancellation period. I understand that if I cancel within that period, I may be charged a proportionate amount for services already delivered.
3. If your programme includes digital content you can access straight awayI expressly consent to immediate access to qualifying digital content and acknowledge that I will lose my statutory cancellation right for that content once its supply begins.

Ready to enrol? Go to enrolment. Questions about this policy? Email info@niyo.co.