VIA Academy Privacy Policy

Updated: 31 October 2024

This Privacy Policy applies to the following platforms operated by VIA Academy:

• The VIA Academy mobile application (the “VIA Academy App”)
• The QPR Virtual Academy at qpr.viaacademy.com and its subdomains,and The Posh Virtual Academy at pufc.viaacademy.com and its subdomains (together, the “Virtual Academies”);
• The VIA Academy Coach Feedback website at feedback.viaacademy.com (“VIA Academy Coach Feedback”); and
• The VIA Academy website at viaacademy.com (the “VIA Academy Website”)

(together, the “Services”).

You should read it because it contains important information about how we collect and use your information when you use our Services.

The most important things to know are: 

1. When you register for the Services and use the Services 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 Services, including to let you use interactive and personalised features, to enable you to purchase paid features and to provide features to you, to advertise our products to you, and to communicate with you about your purchases.
3. We want everyone to have a good experience on our Services, 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 Services
4. You can change and delete your information, including your videos, at any time 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” or by phone or WhatsApp at +44 7311345970. You can also use the “Contact Us” function in the VIA Academy App or on the relevant Virtual Academy platform.

Introduction

The Services are made available by KaiZhan Limited, a company registered in England and Wales under company number 12610906 whose registered office is at 506 Kingsbury Road, London, NW9 9HE, United Kingdom (“KaiZhan” or “us” or “we”) and whose VAT number is 382742381 and whose email address is hello@viaacademy.com.

We operate the QPR Virtual Academy on behalf of Queens Park Rangers Football & Athletic Club Ltd a company registered in England and Wales under company number 60094 whose registered office is at Loftus Road, South Africa Road, London, W12 7PJ, United Kingdom and whose VAT number is 677979738 (“QPR”).

We operate the Posh Virtual Academy on behalf of Peterborough United FC, a company registered in England and Wales under company number 290803 whose registered office is at Weston Homes Stadium, Peterborough, Cambs, PE28AL, United Kingdom and whose VAT number is 120167319 (“PUFC” or “Posh”).

This Privacy Policy documents how we collect and process your personal data through the Services.

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 any time by emailing hello@viaacademy.com with the subject line “Privacy Policy” or by phone or WhatsApp at +44 7311345970. You can also use the “Contact Us” function in the VIA Academy App or on the relevant Virtual Academy platform.

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.

When any user (including a child) attempts to create a user account and/or to access any features that require the collection or processing of personal data, we will ask them to provide their date of birth.

If a child self-identifies as being under 13 years old, 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 are a parent/guardian registering for the Services on behalf of your child aged under 13 or accessing 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.

If you believe that a child under age 13 has provided personal data on our Services 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.

i. Special procedures for children under 13 years of age: VIA Academy App and VIA Academy Coach Feedback

When any user (including a child) chooses to create a Registered Account via the VIA Academy App or VIA Academy Coach Feedback, 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 VIA Academy App or VIA Academy Coach Feedback platform in order to get Coach Feedback or enter the Coach Feedback Monthly Draw;
• Permission for the child to “be followed” by Academy coaches on the VIA Academy App and make his/her videos visible to Academy coaches; and
• Permission for the child to receive relevant push notifications on the VIA Academy 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 13th 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.

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.

ii. Special procedures for children under 13 years of age: Virtual Academies

Children under 13 are only granted limited ‘guest’ access to the Virtual Academies. If your child is aged under 13 years old, your child will not be permitted to create a Virtual Academy account and/or to access any features that require the collection or processing of the child’s personal data, including Academy Feedback and the Pro Membership. If you wish to allow your child to use those features, you will need to access those features on behalf of your child using your own registered user account.

If a child self-identifies as being under 13 years old the child will not be permitted to sign-up on any Virtual Academy, however they can continue to use the Virtual Academies with limited ‘guest’ access. We will not store any child’s date of birth or use their child’s date of birth for any other purpose, and we will not collect any further personal data from any child. Any child who has self-identified as being under 13 years old will be blocked from accessing any features that involve the collection and processing of personal data.

If a child aged under 13 wishes to use any feature that involves the collection and processing of personal data, he/she must seek the express consent of their parent and the parent must access the feature on behalf of the child from the parent’s own registered user account.

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 detect your age and 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.

i. Date of Birth

Whenever you attempt to sign-in or sign-up to the Services we will ask you to enter your date of birth. We collect this information directly from you. We collect and process this data (which does not identify you) strictly for the purposes of determining your age.

ii. Registration using email and password

When you create a Registered Account using email and password, or edit your user account details, we may collect the following data directly from you: email address, password, date of birth, and parent email address (for children aged under 13 only). We may also collect your IP address, an FCM token (unique identifier) and referral source which will be obtained automatically from your device.

iii. Registration using social log-in providers

When you register via “social login providers” (currently Apple, Facebook, Google, QPR Club and Posh Account) those platforms may share with us your email address, your first/last name, your profile picture (if any) and a unique ID. When you register via such platforms, you may be notified by those platforms of the data we will have access to. We will collect such information, including the referral source, from the social login provider in order to provide you access to the Services. We will not disclose any of your personal data to such platforms. We may also collect your IP address and an FCM token (unique identifier) which will be obtained automatically from your device.

iv. Creating and editing your profile

When you create or edit your User Profile we may collect the following data directly from you: first and last name, username, nationality, player position (football/soccer), profile picture (for users over 13 only) and football team gender.

v. Accessing the Services

In addition to the information that we collect during the registration process, as part of your/your child’s use of the Services we may also collect the following data from you:

• Uploading videos to the Pitch
  
  If you choose to upload videos and video descriptions to the Pitch, we will collect video files containing your image and voice and your written descriptions which may or may not contain your personal data.
  
  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).
  
  YOU 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).
• Interactive features
  ‍
  If you choose to use any interactive features, submitting responses to surveys, polls and questions, “reacting” to content and submitting questions to the Academy Intelligence Coach ("AI Coach"), to the extent that you provide us with personal data in such responses we may collect such personal data directly from you.
  
  When you use the “Ask my own question” feature of the AI Coach, we will collect and process the information that you submit. The AI Coach is not designed to collect personal data and we recommend that you do not submit personal data to the AI Coach. However, to the extent that you choose to submit your own questions to the AI Coach and to the extent that you submit personal data as part of such questions, we will collect such personal data directly from you.
• Academy Feedback
  ‍
  If you choose to use the Academy Feedback or Coach Feedback feature, we may collect the following personal data directly from you:
  • Video files containing the player’s image and voice
  • Text describing who the relevant player is
  • Player’s name
  • Player’s age
  • Player’s position
  • Text describing what the player wants to improve on
  
  If you are using our Academy Feedback/Coach Feedback feature on behalf of someone else, we may also collect their personal data from you.
  
  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). IN THE CASE OF PERSONS UNDER 13, YOU MUST HAVE PERMISSION FROM THE CHILD’S PARENT TO USE THE CHILD’S PERSONAL DATA.
  
• Payment (over 18 only)
  ‍
  Purchases must be completed by an adult aged 18 or above. When purchasing any paid features, including Academy Feedback/Coach Feedback and Pro Memberships, we may collect the purchaser’s email address, payment information and purchase history. Such information is collected directly from the purchaser.
  
• Usage and Analytics Data
  ‍
  When you use the Services we may collect user data from your use of the Services (including information about your device, log files and your interactions with the Services’ 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 obtained automatically from your device. You may also elect to provide us with more information as part of feedback surveys, and in the event that you provide any personal data in such survey responses, we will collect such personal information directly from you.
  ‍
  We use third party service providers, including Google Analytics (GA4) to collect some anonymised usage data related to your behaviour on the Services. This information is important to us for improving the user experience and determining the effectiveness of our Services.  
  ‍
  Google Analytics may collect first-party cookies, data related to the device/browser, IP address (GA4 does not log or store IP addresses), and your activities on the Services to measure and report statistics about your interactions on the Services. We run GA4 only in an anonymised version for statistical reporting purposes and have disabled all other data-sharing features. We do not send any personally identifiable information to Google Analytics.
  ‍
  Our Cookies Policy provides further details of such collection and use.
  

vi. Log Files

We also follow a standard procedure of using access 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 internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. This information is collected automatically from your device. The purpose of the information is for administering the Services , security monitoring and improving system performance.

Our Cookies Policy provides further details of such collection and use.

vii. Direct Contact

In the event of direct contact for any reason, we may collect further personal data via the contact means (e.g. via the VIA Academy App, our Customer Portal, our support, email addresses or social media channels).

viii. Meta Pixel, Meta CAPI and Advanced Matching

We use Meta Ads to market our products. In order to measure, analyse and enhance the success of our campaigns, we have integrated the Meta Pixel and Meta Conversion API into the Services. The Meta Pixel and Meta Conversion API enable us to record your activity and event data in the Services (e.g. when you register, pages you visit and purchases) and to share such information with Meta, alongside a hashed/anonymised version of your contact information (your account email address or purchaser email address). This helps us to analyse the effectiveness of the Meta ads and optimise our future Meta Ads campaigns including through re-targeting and custom audiences.

Our Cookies Policy provides further details of such collection and use. Details about how this data is shared with Meta are outlined in section D below.

ix. 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?

i. VIA Academy App

• Personal Data visible to VIA Academy 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 VIA Academy App users. For users aged 18+, their Followers/Following lists will also be visible to VIA Academy App users initially (however this can be adjusted in profile settings.)
• Followers and Following
  ‍
  Users aged 13 years and over can be followed by all VIA Academy 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”, VIA Academy 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.
  
  Children aged under 13 years old can only be followed by Academies (and not by any other VIA Academy 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 VIA Academy App’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 VIA Academy App 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 VIA Academy App, 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.

ii. Academy Feedback/Coach Feedback

When you purchase Academy Feedback/Coach Feedback we will share the following data with relevant Academy coaches and staff from your chosen Academy who are involved in analysing your videos and providing your Feedback:

• Player name
• Player age
• Player position
• Videos featuring the user’s image and/or voice
• Written description of who the player is
• Player’s improvement points which may or may not contain personal data relating to the player

iii. 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 VIA Academy App, via the VIA Academy Website, and via physical, social and digital marketing channels belonging to VIA Academy and/or our partners, in connection with the Monthly Draw.

iv. Academy Intelligence Coach

As part of our ongoing efforts to improve the AI Coach and to ensure the safe and responsible use of the tool, User Inputs may undergo human review including for the purposes of accuracy-checking and expanding the knowledge base of the AI Coach.

v. 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@superawesome.com for any questions related to their use of personal data. SuperAwesome’s privacy policy can be found at https://www.kidswebservices.com/privacy-policy.
• 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. We also use base models from AWS under the AWS Bedrock service to power our AI Coach. 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 Services for data and trend analysis, and to collect data if the Services crash. This includes data about the user’s device or browser and their activities on the Services. 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 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 websites. Hotjar is a technology service that helps us better understand website 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.
• Depending on the product you select, we may use video processing services from StepOut in order to provide our Coach Feedback/Academy Feedback video analysis service. As part of such video processing we may share your submitted video file, name, Academy ID and player identification data (shirt number and shirt colour) with StepOut.
• We use Meta Ads to market our products on Meta. In order to measure, analyse and enhance the success of our Meta ad campaigns, we share certain event data (e.g. page views and registration/purchase activity) and hashed/non-identifiable contact information (purchaser or account email address). Meta processes this information on our behalf and according to our instructions for the following purposes:
  
  (a) To match the contact information against Meta user IDs and to combine such user IDs with corresponding event data. Meta will delete contact information following the match process. We hash all customer information before it is sent to Meta and Meta promptly discards the hashed information after matching.
  
  (b) For measurement and analytics purposes. This enables Meta to prepare reports on our behalf on the impact of our advertising campaigns, including attributing conversions with impressions shown through Meta’s platforms and to generate analytics and insights about people and their use of our products.
  
  (c) To target our ad campaigns to people who interact with our business, including through Meta’s “custom audiences” feature. You can de-activate the re-marketing function in your Meta ad settings at https://accountscenter.facebook.com/ad_preferences.
  
  (d) Meta may also use this data in aggregated and anonymised form in connection with their own ads targeting and ads delivery activities.
• Depending on the product you select, we may use video processing services from StepOut in order to provide our Coach Feedback/Academy Feedback video analysis service. As part of such video processing we may share your submitted video file, name, Academy ID and player identification data (shirt number and shirt colour) with StepOut.

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.

vi. Other 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 users of our Services 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

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

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

i. Deletion

Please note that deleting your account will erase your user account and all of your data across all of the Services, including your access to any content you have uploaded or paid for (such as Academy Feedback videos received). Prior to deleting your account we recommend that you download any content you wish to retain access to.

• 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 VIA Academy App
  
  To delete your registered account in the VIA Academy 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.
• How to request deletion of your personal data using email
  
  You can request deletion of your account by emailing hello@viaacademy.com with the subject line “Account Deletion”. If you delete your account we will permanently delete all of the personal information we have about you, including your account information, videos and activity. Account deletion via email may take up to 36 hours.
  
• How to request deletion of your personal data in the Virtual Academies
  ‍
  To delete your registered account in the Virtual Academies, log in to one of the Virtual Academies, 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, videos and activity.
  

ii. 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.

iii. 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. You can also use the “Contact Us” function in the VIA Academy App or on the relevant Virtual Academy platform.

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 Services.