QPR Virtual Academy Privacy

1. When you sign up to and use the Virtual Academy, 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 let you log-in and to give you the best possible experience, including to let you use interactive and personalised features (like participating in surveys, polls and Q&As and sending videos to Academies for Feedback), to provide paid services to you like our Academy Feedback and Pro Memberships, and to communicate with you about services you purchase.
3. You can change and delete your information 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 for Academy Feedback. If you opt-in to receive promotional emails from us, you can unsubscribe at any time.
4. If you feel confused, unhappy or worried about how any of your information is being used, you can contact us any time by emailing support@qprviaacademy.com with the subject line “Privacy Policy” or by phone or WhatsApp at +44 7311345970.

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INTRODUCTION

The Virtual Academy is operated by KaiZhan Limited (Co Reg No 12610906) (“we”, “our”, “us”, and their derivatives) and Queens Park Rangers Football & Athletic Club Ltd (Co Reg No. 60094) (“QPR”). This Privacy Policy documents how we collect and process your personal data through the Virtual Academy.

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 support@qprviaacademy.com with the subject line “Privacy Policy” or by phone or WhatsApp at +44 7311345970.

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

The Virtual Academy is designed for and marketed to both adults and children aged 8 and above. Protecting the children who use the Virtual Academy is our priority. In relation to any proposed use of the Virtual Academy 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 the Virtual Academy to observe, participate in, and/or monitor and guide your child’s use.

Children under 13 are granted limited ‘guest’ access to the Virtual Academy only. 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 Virtual Academy account.

When any user (including a child) attempts to create a  Virtual Academy 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 the child will not be permitted to sign-up to the Virtual Academy, however they can continue to use the Virtual Academy with limited ‘guest’ access. We will not store anychild’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 Virtual Academy account.

If you believe that a child under age 13 has provided personal data on the Virtual Academy 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 logging in to the Virtual Academy on behalf of your child aged under 13, then you accept and agree that any use of the Virtual Academy by the child (and any collection/use of the child’s data as part of his/her use of the Virtual Academy) is on the terms of this Privacy Policy.

B. WHAT PERSONAL DATA DO WE COLLECT?

Where we ask you (or any child accessing the Virtual Academy 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 you to disclose more personal Data or other information than reasonably required to use the Virtual Academy.

i. Data collected from logged-in users (over 13 only)

Creating a Virtual Academy account and Logging in to the Virtual Academy

Only users aged 13 and above are permitted to create a Virtual Academy account and to log in to the Virtual Academy.

When you sign up or sign in using your Google, Apple or Facebook 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 log-in using your QPR Club Account, we will collect your email address, first name, last name and a unique identifier. 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, in order to provide you access to the Virtual Academy. We will not disclose any of your personal data to such platforms.

Interactive Features

Only users aged 13 and above are permitted to use interactive features. If you choose to use interactive features including by submitting responses to surveys, polls and questions, or “reacting” to posts, to the extent that you provide us with personal data in such responses we may collect such personal data directly from you.

Academy Feedback

Only users aged 13 and above are permitted to use the Academy Feedback feature. If you choose to use our Academy Feedback feature, we may collect the following personal data directly from you:

1. Video files containing the player’s image and voice
2. Text describing who the relevant player is
3. Player’s name
4. Player’s age
5. Player’s position
6. Text describing what the player wants to improve on

If you are using our Academy 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 and Pro Memberships, we may collect the purchaser’s email address, payment information and purchase history. Such information is collected directly from the purchaser.

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ii. Data collected from all Virtual Academy users (all ages)

Date of Birth

Whenever you attempt to sign-in or sign-up to the Virtual Academy as a logged-out user 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.

Analytics Data

We use third party service providers, including Google Analytics (GA4) and Hotjar, to collect some anonymised usage data related to your behaviour on the Virtual Academy. This information is important to us for improving the user experience and determining the effectiveness of our Virtual Academy.

Hotjar may collect your 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. This data is collected automatically from your device using automated technologies i.e., cookies or similar technologies (including pseudonymised GUIDs (global unique identifiers)). Hotjar stores this information on our behalf in a pseudonymised user profile.

Google Analytics may collect first-party cookies, data related to the device/browser, IP address (GA4 does not log or store IP addresses), and on-site activities to measure and report statistics about your interactions on the Virtual Academy. 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 Cookie Policy provides further details of such collection and use.

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 https://www.qpr.co.uk/privacy-notice 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 site, security monitoring and improving system performance.

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

Direct Contact

If you contact us directly by any means and for any reason, you may elect to provide and we may collect further personal data via the contact means (e.g. via our, support email address).

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.

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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.

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D. WHO DO WE DISCLOSE YOUR DATA TO?

Coach Feedback

When you purchase Coach Feedback we will share the following data with the Queens Park Rangers Academy coaches and staff who are involved in analysing your videos and providing your Feedback:

1. Player name
2. Player age
3. Player position
4. Videos featuring the user’s image and/or voice
5. Written description of who the player is
6. Player’s improvement points

Please see their privacy policy here for how they will process your personal data.

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:

1. 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.
2. 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.
3. We use services from Google including Google Analytics and Google Firebase to track and measure user interactions on the Virtual Academy for data and trend analysis, and to collect data if the Virtual Academy crashes. This includes data about the user’s device or browser and their 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.
4. We use services from Mailchimp to send marketing email communications where you have agreed to receive them.  In the course of providing these services Mailchimp may process personal data including your first and last name and email address.
5. We use a service from Hotjar in order to better understand our users’ needs and to optimise the Virtual Academy. Hotjar is a technology service that helps us better understand 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 support@qpr.viaacademy.com with the subject line “Privacy Policy”, or contact us by phone or WhatsApp at +44 7311345970.

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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 Virtual Academy users 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.

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F. COOKIES

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

G. LINKS - ADVERTISING PARTNERS PRIVACY POLICIES

The Virtual Academy 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 Virtual Academy, 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  email

You can request deletion of your account by emailing support@qpr.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 Academy

To delete your registered account in the Virtual Academy, 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, videos and activity.

Data retention

We, and our service providers, may retain personal data for as long as your 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.

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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:

1. 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;
2. 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;
3. 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;
4. 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;
5. 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;
6. Request the transfer of your personal data to you or to a third party; and
7. 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 support@qpr.viaacademy.com with the subject line “Privacy Policy”, 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 support@qpr.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 Site.

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