Privacy Policy

Updated: 25 March 2024

This is our Privacy Policy for the VIA Academy mobile app and website. You should read it because it contains important information about how we collect and use your information when you use our App and Site.

The most important things to know are: 

1. When you sign up to our App or Site and use the App or the Site as a registered user, we will collect some data about you and anyone else whose details you give us.
2. The reason we collect data about you is to give you the best possible experience with our App and Site, including to let you use interactive and personalised features (like building your profile, uploading videos, sending videos, “following” other users and letting other users “follow” you), to provide paid services to you like our Coach Feedback, and to communicate with you about services you purchase.
3. We want everyone to have a good experience on our App and Site, and so we ask that you also respect others’ privacy too. For example, if you take a video that shows another person in it, you need to make sure that the other person knows about it and is happy for you to upload their video to the App or the Site.
4. You can change and delete your information, including your videos, at any time in the App or by contacting us. You can also delete your whole account at any time, and if you do that we will delete all of the information we have about you, including any videos you’ve uploaded. If you opt-in to receive promotional emails from us, you can unsubscribe at any time.
5. If you feel confused, unhappy or worried about how any of your information is being used, you can contact us any time by emailing hello@viaacademy.com with the subject line “Privacy Policy”, by using the in-app Contact Us function, or by phone or WhatsApp at +44 7311345970.

Introduction

This Privacy Policy documents how  KaiZhan Limited (Co Reg No 12610906) (“KaiZhan”, “we”, “our”, “us”, and their derivatives) collects personal data, principally through our VIA Academy mobile application (the “App”) and website (including http://www.viaacademy.com and its subdomains, collectively, the “Site”) (together, the “Services”) and how we process your data.

Our Services are only offered in English. So, by using our Services in English, you are confirming that you understand English well enough to understand this Privacy Policy. If you have any questions about this Privacy Policy, please contact us by emailing us at hello@viaacademy.com with the subject line “Privacy Policy”, by using the in-app Contact Us function, or by phone or WhatsApp at +44 7311345970.

A. IMPORTANT NOTICE FOR PARENTS OR GUARDIANS OF CHILDREN UNDER 13 YEARS

Our Services are designed for and marketed to both adults and children aged 8 and above. Protecting the children who use our Services is our priority. In relation to any proposed use of our Services by a child under the age of 13 years, we require the express consent of parents or guardians (referred to throughout as “parent”) to such use and we encourage the parents of any child who wishes to use our Services to observe, participate in, and/or monitor and guide your child’s use of our Services.

Certain features of our Services, if activated, will involve the collection and processing of the personal data of children. We require that the parent of a child under 13 years old provides permission and agrees to this Privacy Policy before that child can use our Services. We also reserve the right to verify that the person providing such consent does, in fact, hold parental responsibility for the child. If you believe that a child under age 13 has provided personal data on our App or Site without parental consent, please contact us immediately and we will take action to identify the information provided and, if required, remove such information from our records.

If you are a parent/guardian registering for the Services on behalf of your child aged under 13, then you accept and agree that any use of the Services by the child (and any collection/use of the child’s data as part of his/her use of the Services) is on the terms of this Privacy Policy.

i. Special registration procedures for children under age 13

When any user (including a child) chooses to create a Registered Account via our Services, we will ask them to provide their date of birth. If a child self-identifies as being under 13 years old, the child will be required to complete a parental notice, verification and consent process before they can create a Registered Account. To initiate the parental notice, verification and consent process, we will ask the child to provide the email address of their nominated parent. We will also collect an FCM token (ie. a unique identifier) from the child’s device in order to respond to the child’s request for parental consent.

The parent will be directed to our “parent portal” at parents.viaacademy.com, where they will be asked to verify their identity as an adult and to consent to various permissions on behalf of their child. As detailed below, the parent may agree to the collection and use of their child’s information, but still not allow disclosure of their child’s information to third parties, except to the extent such disclosure is part of the Services.

The following permissions are required to activate the child’s Registered Account:

• Permission for the child to create a Registered Account and user Profile; and
• Permission for the child to upload videos and written content to the App.

The child’s parent will also be asked to manage the child’s permissions for the following extra, optional features: 

• Permission for the child to upload videos and written content to the App or Site in order to get Coach Feedback or enter the Coach Feedback Monthly Draw;
• Permission for the child to “be followed” by Academies on the App and make his/her videos visible to Academies; and
• Permission for the child to receive relevant push notifications on the App.

Parents will also be required to agree to this Privacy Policy and our VIA Academy Terms on behalf of the child.

Until we receive parental permission for the required permissions stated above, the child can only use the Services in Guest mode. While the Services are being used in Guest mode, we will not collect any personal information from the child, and the child will continue to be blocked from accessing any features that allow them to provide personal information to us or to other users of the Services.

If the parent does not provide permission for the required permissions stated above within 7 days, we will delete the parent’s contact information and any data provided by the child.

If the parent does provide the required permissions stated above within 7 days, we will ask the child to provide us the information required to create a Registered Account for the child and to create a user Profile in the same way as an individual over the age of 13 years. We will not seek consent from the child following their 13^th birthday, so any consent given at this stage will be deemed to be consent from the child for so long as they continue to hold a Registered Account.

If the child subsequently requests permission for an optional feature, we will email the parent with a further permission request.

ii. Parent notifications and control over permissions via parent portal

Parents will be given the opportunity to opt-in to our marketing email list upon granting permission for their child to use the app.

We will occasionally notify the parent of the child’s activity, or of important updates relating to the child’s Registered Account or to our Services using the email address provided to us by the child at the point of registration. Such notifications will include:

• When the child uploads their first video to the App;
• When the child turns 13 years old, to alert the parents to changes to the child’s account;
• Transactional emails relating to the purchase of Coach Feedback on behalf of the child;
• Transactional emails relating to the child’s entry into the Coach Feedback Monthly Draw; and
• Important updates relating to our Terms and Policies.

The parent can manage the child’s access to both the required and optional features at any time (including revoking access) via the parent portal at parents.viaacademy.com.

If the parent chooses to revoke access to any required features, we will delete the child’s Registered Account. If the parent chooses to revoke access to any optional  features, we will disable any such features for the child and we will change any relevant privacy settings for content previously uploaded by the child.

iii. Description of parent rights

At any time, a parent may review their child’s personal information, require us to correct or delete the personal information of their child, request that we delete their child’s Registered Account, or refuse any further collection or use of their child’s personal information, by emailing us at hello@viaacademy.com with the subject line “Privacy Policy”, by using the in-app Contact Us function, or by phone or WhatsApp at +44 7311345970.

B. WHAT PERSONAL DATA DO WE COLLECT?

Where we ask you (or any child accessing the Services with your permission) for information, we will provide clear notice to you explaining what information we are requesting and why we are asking you to provide it to us. We do not require users of the Services, including children under 13 years old, to disclose more Personal Data or other information than reasonably required to use our Services.

If you are a child under 13 years old, we will seek consent from a verified parent before we collect data from you, with the exception of some limited data that we require in order to facilitate the parental consent and verification process. Until we obtain such consent from a verified parent we will not use this data for any other purpose and will not collect any further data from you.

Creating a Registered Account

All users will be prompted to create a “Registered Account” in the App or Site if they attempt to access certain interactive or paid features on either the App or the Site. For children under 13 years old, parental permission as outlined above will be required. If a user wishes to sign up for a Registered Account, we may require them to create a user Profile as well.

When users create a Registered Account and create or edit their user Profile, we may collect the following personal data:

Interactive, Community, Personalised and Paid Features

In addition to the information that we collect during the registration process, as part of your's/your child’s use of the App or Site’s interactive, community, personalised or paid features, all users with Registered Accounts may choose to upload content to the App or the Site or may be required to provide further personal data as outlined below:

PLEASE NOTE THAT YOU MUST HAVE PERMISSION TO USE THE PERSONAL DATA OF ANYONE ELSE FEATURED IN ANY CONTENT YOU PROVIDE TO US (INCLUDING IN ANY VIDEO AND/OR PHOTO).

USERS ARE NOT PERMITTED TO USE THE PERSONAL DATA OF ANY CHILDREN UNDER 13 YEARS OLD WHO ARE NOT REGISTERED USERS IN ANY CONTENT YOU PROVIDE TO US (INCLUDING IN ANY VIDEO AND/OR PHOTO).

Registration via Social Login Providers

If you register via “Social Login Providers” (currently Apple, Facebook or Google), those platforms may share your public profile information (including your profile image, email address, Apple ID and first/last name) with us. When you register via such platforms, you may be notified by those platforms of the data we will have access to. If you register via a Social Login Provider, we will not disclose any of your personal data to the Social Login Provider.

App/Site Usage

When you visit our Site we will collect user data related to your use of the Site and interactions with the Site’s pages and features, including information about your geographic location, date/time of access, (unique device identifiers), operating system, and browser type, pages visited and mouse events (movements, locations and clicks). Such information will be collected automatically from your device. You may also elect to provide us with more information as part of feedback surveys on the Site, and in the event that you provide any personal data in such survey responses, we will collect such personal information directly from you.

On our App and Site, we will also use Google Analytics (GA4) to collect some aggregated, anonymised user data related to your behaviour using automated technologies i.e., cookies or similar technologies (including pseudonymised GUIDs (global unique identifiers)). Such information will be collected automatically from your device. We run GA4 only in an anonymised version for statistical reporting purposes and have disabled all other data-sharing features.

This information is important to us for improving the user experience and determining the effectiveness of our App and Site.  Our Cookies Policy provides further details of such collection and use.

Contact Form

If you contact us directly by any means and for any reason, we may collect further personal data via the contact means (e.g. via our App, Site, email address or social media channels).

Sensitive Personal Data

Occasionally we may obtain information from you that constitutes sensitive personal data under some data protection laws (i.e., if you voluntarily provide information about your health, ethnicity or race). By providing us with your sensitive personal information, you consent to us processing that information for the purposes set out in this Privacy Policy or any collection notice provided to you.

C. HOW WE USE YOUR INFORMATION (PURPOSE AND LAWFUL BASIS)

This section explains the purposes for which we use the personal data we collect from you. For individuals in the EU, UK, and other regions with privacy laws that require us to specify our legal basis for processing, this section also lists the legal bases we rely on when processing your personal data.

D. WHO DO WE DISCLOSE YOUR DATA TO?

Personal Data visible to App Users upon registration

When a user becomes a Registered Account user, the user’s username, player position, nationality flag, and, if the user is over 13 years old, profile picture (if any), will be visible to App users. For users aged 18+, their Followers/Following lists will also be visible to App users initially (however this can be adjusted in profile settings.)

Followers and Following

For users aged 13 years and over:

• Users aged 13 years and over can be followed by all App users. When a user aged over 13 registers for the App, they will automatically be “followed” by or receive a “follow request” from official Academies.
• Users aged 13 years and over can choose who can see their Followers/Following lists by enabling or disabling the “Hide my Followers/Following lists” toggle in their Profile Settings. If a user enables this setting, only their Followers can see who they follow and who follows them. For users aged between 13-17 years old, this setting is enabled by default. For users aged 18+, this setting is disabled by default.
• Users aged 13 years and over can choose whether to enable “Follower requests”. If a user enables “Follower requests”, App users need to ask their permission to follow them. For users aged between 13-17 years old, “Follower requests” is enabled by default. For users aged 18+, “Follower requests” is disabled by default.

For children aged under 13 years old:

• Children aged under 13 years old can only be followed by Academies (and not by any other App users). “Following” by Academies will also require permission from the child’s parent/guardian via the Parent Portal.
• For children aged under 13 years old, the “Hide my Followers/Following” setting is enabled by default, and this setting cannot be changed. This means that only the child’s Followers will be able to see who the child follows and who follows them.
• For children aged under 13 years old, “Follower requests” are enabled by default, and this setting cannot be changed.

Personal data that may be visible to others depending on user activity

In addition, as part of a user’s use of the App or Site’s interactive, community, personalised or paid features,  a user may also make certain other personal data accessible to other people both within and outside the App and Site as outlined in the table below. The precise personal data that is disclosed, to whom it is disclosed, and where it is disclosed, will depend on the user’s activity within the App and Site, the age of the child, and (if the child is under 13 years old), the specific permissions set by the parent.

For children under 13 years old: 

For children aged over 13 years old and adults:

Users of all ages, including children aged under 13 years old, children aged over 13 years old, and adults, may also choose to download their own videos (featuring the user’s image and/or voice) to their device.

Coach Feedback Monthly Draw

If a user enters the Coach Feedback Monthly Draw and is selected as a winner, the following information will be shared with the Academy from whom the Coach Feedback prize is provided:

• Full name
• Age/date of birth
• Username
• Player position
• Nationality flag
• Football team gender
• Videos featuring the user’s image
• Written video descriptions that may or may not contain personal data relating to the user

The winner’s username and nationality flag may also be shared via the App, via the Site, and via physical, social and digital marketing channels belonging to VIA Academy and/or our partners, in connection with the Monthly Draw.

Service providers

In the course of using your personal data for the purposes identified in Section C, your personal data may also be disclosed to the following entities:

• Our payment services are managed by Stripe . This payment services provider acts as a separate data controller and operates subject to their own privacy notices. Users should refer to those notices for details of how their payment information is processed. We do not store payment card data. We disclose limited information to Stripe about the user's intention to purchase a product and the price. These stores process the payment and provide us with customers’ payment status, payment history and payment ID information. Please see the Stripe Privacy Policy for more information.
• We use a parental consent/verification service provider called Kids Web Services (“KWS”) to verify parents’ identity and obtain permissions for children under 13. KWS is designed specifically to support kid-friendly registrations and digital experiences, as well as parental management tools, across the web and mobile ecosystem in compliance with the Childrens’ Online Privacy Protection Act (“COPPA”), the EU’s General Data Protection Regulation (“GDPR”), and other applicable law. KWS is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. KWS is also ESRB Privacy Certified, meaning its services have been reviewed by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. You may contact KWS directly at privacy@kidswebservices.com for any questions related to their use of personal data. KWS’s privacy policy can be found at https://www.kidswebservices.com/privacy-policy.
• We utilise customer support services from a service provider called Sigma Software. Customers may share personal data with Sigma Software directly when contacting us directly for any reason, or we may share personal data with Sigma Software in the process of providing customer support or addressing customer concerns.
• We utilise infrastructure-as-a-service from service provider Amazon Web Services (AWS), including: our servers, our database, our static file storage (for videos and images), our sign-in, authorisation and authentication services, and content moderation services. AWS acts as our processor and only processes information strictly on our behalf and on our instructions. AWS does not use any of our data for their own purposes. We have our own virtual private cloud, so our resources are isolated from everyone else’s. All such data is encrypted in transit and at rest and requires relevant encryption keys in order to access it. This processing is carried out in the EU.
• We use services from Google including Google Analytics and Google Firebase to track and measure user interactions on the App and Site for data and trend analysis, and to collect data if the App or Site crashes. This includes data about the user’s device or browser and their on-Site/in-App activities. Google processes this information on our behalf and uses it to prepare reports for us. These reports don't identify the users - they are aggregated information about all our users. Google does not use any of this information for their own purposes - they act as our processor and only operate on our instructions.
• We use services from Mailchimp to send email communications to our registered users and parents of users aged under 13, including communications about important app updates and marketing communications.  In the course of providing these services Mailchimp may process personal data including first and last name, email address and profile information.
• We use a service from Hotjar in order to better understand our users’ needs and to optimise our Site. Hotjar is a technology service that helps us better understand Site users’ experience and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile. Hotjar acts as a data processor only and operates solely under our instructions. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

We contractually obligate our service providers to collect, process, and disclose personal data solely for the purposes of providing services to us as permitted under our agreements with them. We do not permit our service providers to collect, process, or disclose personal data received from us or collected on our behalf for their own purposes.

We may from time to time engage other service providers (including coaches and related club staff) to whom we may transfer personal data, subject always to ensuring that they are engaged to do so on terms that meet the requirements of applicable law as processors. These service providers will perform functions on our behalf, e.g., providing technical support for the systems where your personal data is held. They may need access to your personal data to perform their functions but will not use your personal data for any other purpose. We contractually obligate such service providers to at all times adhere to applicable data protection laws, and we will only ever disclose your personal data in accordance with the protections mandated by law.

For questions about how our service providers collect and process personal data in conjunction with providing services to us, please email us at hello@viaacademy.com with the subject line “Privacy Policy”, use the in-app Contact Us function, or contact us by phone or WhatsApp at +44 7311345970.

Third Parties

We will not share, sell or licence your personal data to any other third parties without your express prior consent. We may from time to time share anonymised, aggregated data sets with third parties for research and development purposes, but such data will not be capable of identifying any individual.

We may also disclose personal data to comply with our legal or regulatory obligations, in response to a non-mandatory request for information made by a governmental or state body, or as part of an investigation of unlawful activity. We may also disclose personal data to third parties in conjunction with merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), and in such circumstances we will seek assurances that such personal data will be processed in accordance with this policy.

E. INTERNATIONAL DATA TRANSFERS

In the case of App users or Site visitors based outside the UK, or where service providers and third parties to whom we disclose personal data (including storage) require access to your personal data outside of the UK, your personal data may be transferred to countries located outside the UK, including to countries that may not provide a similar or adequate level of protection to that provided by your country of residence, in which case we will only do so subject to the necessary protections mandated by UK data protection laws. This may include the standard data protection clauses currently adopted by the UK supervisory authority, the Information Commissioner’s Office (ICO), or such others as may be applicable to the UK from time to time. The specific measures we use to secure international data transfers will be made available on request. Google Analytics data collected through our cookies will be stored in the USA and all appropriate measures will be taken to manage that data transfer and processing in compliance with applicable data protection laws.

F. COOKIES

We follow a standard procedure of using log files. These files log visitors when they visit websites. Hosting companies do this as part of hosting services' analytics. The information collected by log files include anonymised internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. The purpose of the information is for analysing trends, administering the site, and analysing users' use of the Site.

Please see our Cookie Policy as to how we also use cookies to gather certain information via cookies and similar technologies.

G. LINKS - ADVERTISING PARTNERS PRIVACY POLICIES

The Services may, from time to time, contain links to external websites or apps operated by third parties. We do not disclose personal data collected through the Services to these third parties. We are also not responsible for these third-party websites or apps, or the content of such third-party websites or apps. Once you have left the Services, we cannot be responsible for the protection and privacy of any personal data which is provided. Please consult the privacy information provided by such third parties. We are not liable for any acts or omissions of such third parties, including in relation to data protection laws.

H. DELETION, SECURITY AND RETENTION OF YOUR PERSONAL DATA ON VIA ACADEMY

How to request deletion of your personal data using a web link

You can request deletion of your account by completing the form on this web link.

If you delete your account we will permanently delete all of the personal information we have about you, including your account information, Profile information, videos and activity. Account deletion via web link may take up to 36 hours.

How to request deletion of your personal data on the app

To delete your registered account in the app, log in, visit your Profile Settings, tap on “delete your account” and type DELETE to confirm.

If you delete your account we will permanently delete all of the personal information we have about you, including your account information, Profile information, videos and activity.

Data retention

We, and our service providers, may retain personal data for as long as a Registered Account is active and for a period of three years thereafter for research and analysis purposes, or as needed for the specific business purpose for which it was collected. In some cases, we may be required to retain personal data to comply with laws or regulations or other legal obligations, resolve disputes and enforce our agreements.

Data security

The security of personal data is important to us. We take all reasonable steps, including technical, administrative and physical safeguards, designed to protect the personal data we collect from loss, misuse and unauthorised access, disclosure, alteration and destruction. We will ask any agents and service providers to whom we may transfer your personal data to take comparable steps to protect that security. However, no method of security or method of transmission over the Internet is entirely secure.

I. YOUR RIGHTS

This section provides details regarding data subject rights available under the GDPR and UK GDPR to residents of the EU and UK. This section may not apply to residents of other countries, depending on whether those countries have data protection laws that afford the same or similar rights to individuals as the GDPR and UK GDPR.

This section does not apply to residents of the U.S. Some U.S. residents have certain data subject rights, depending on their state of residence. For more information, please see our Supplemental Privacy Policy for U.S. Consumers.

Under certain circumstances, residents of the EU and UK have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;
• Request erasure of your personal data. Subject to certain exceptions, this enables you to ask us to delete or remove personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) but you feel it impacts on your fundamental rights and freedoms;
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where you believe our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• Request the transfer of your personal data to you or to a third party; and
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please email us at hello@viaacademy.com with the subject line “Privacy Policy”, use the in-app Contact Us function, or contact us by phone or WhatsApp at +44 7311345970.

You also have the right to lodge a complaint in relation to any processing which we undertake in relation to your personal data with the UK supervisory authority, the Information Commissioner's Office (ICO) at https://ico.org.uk/.

J. HOW TO CONTACT US

If you have additional questions or require more information about this Privacy Policy, do not hesitate to email us at hello@viaacademy.com with the subject line “Privacy Policy”, or contact us by post at our registered office at KaiZhan Limited, 506 Kingsbury Road, London, United Kingdom, NW9 9HE, or by phone or WhatsApp at +44 7311345970.

We may need to update this Policy at any time and without notice and where we do this we will ensure that such changes are appropriately published and notified through the App and Site.