Privacy Policy.

1. Introduction

Welcome to VOLOCOACH (“we”, “us”, or “our”).

VOLOCOACH is a mobile application designed to facilitate offline sports coaching sessions between independent coaches and learners, and to provide optional AI-powered lesson note features.

We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how and why we collect, use, share, and protect your personal data when you use the VOLOCOACH mobile application (the “App”) and related services.

2. Data Controller

For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, the Data Controller is:

VOLOCOACH LIMITED
Company Number: 16916102
Registered Office: 128 City Road, London, United Kingdom, EC1V 2NX
Email: privacy@VOLOCOACH.com

3. Personal Data We Collect

We collect only the personal data necessary to operate the App, facilitate bookings, enforce platform rules, and provide optional AI-powered features.

A. Information You Provide to Us

Identity Data: Full name, Username, Date of birth (for age verification purposes only).

Contact Data: Email address, Telephone number.

Profile Data:

• Learners: Sports preferences, Skill level, Profile photo (optional).
• Coaches: Professional qualifications, Certifications, Biography, Experience, Pricing, DBS verification status (see Section 4).

Payment & Transaction Data:

• Payments are processed by Stripe. We do not store full credit or debit card numbers.
• We retain: Payment tokens, Booking history, Refund/Cancellation records, and Coach payout history.

User Content – Audio Data (Optional Feature):

With your explicit consent, we may process audio recordings captured by the Coach during your session solely to generate AI-powered lesson notes and summaries.

B. Information Collected Automatically

Location Data: Precise or approximate location data (GPS), where enabled, to support “find nearby coaches or courts” functionality. You may disable location access at any time via your device settings.

Technical Data: IP address, Device type, Operating system, and App version.

Usage & Reliability Data: App interaction history, Attendance records (including no-shows, late cancellations, and breaches of platform policies).

Note: These records are essential for maintaining platform safety, preventing abuse, and enforcing our Terms of Service.

4. Special Categories & Sensitive Data

DBS Information (Coaches Only)

• We do not collect or store copies of DBS certificates.
• We record only the DBS verification status (e.g., “Verified” / “Not Verified”) for safeguarding and trust purposes.
• This information constitutes criminal offence data under Article 10 UK GDPR and is subject to strict access controls.

Important:

VOLOCOACH does not assess, interpret, or make suitability decisions based on DBS content. Verification status is recorded solely for safeguarding display and platform integrity purposes.

5. How We Use Your Personal Data & Lawful Bases

We process personal data only where permitted by law.

Where we rely on legitimate interests, we have conducted a Legitimate Interests Assessment to ensure our interests do not override your fundamental rights. You may object to such processing as described in Section 11.

6. AI & Audio Processing (“Smart Voice Notes”)

Consent

• Optional: Audio recording is never enabled by default.
• Coach Responsibility: Where the optional “Smart Voice Notes” feature is used, recording is initiated by the Coach and requires the Learner’s explicit consent (verbal or via App) prior to recording.
• Withdrawal: Consent may be withdrawn at any time. Refusal will not affect the ability to book sessions.
• Minors: For sessions involving minors, Coaches must obtain consent from a parent or legal guardian.

VOLOCOACH does not independently verify, record, or store evidence of consent. Responsibility for obtaining valid consent rests solely with the Coach.

Processing

Audio data is transmitted securely to trusted cloud-based processors and is processed solely for the purpose of generating lesson notes and summaries for the relevant coaching session.

Retention & Training

• Deletion: Original audio recordings are permanently deleted within 24 hours following text generation. Only text-based notes are retained.
• No Model Training: VOLOCOACH does not use personal audio recordings to train public, general-purpose, or third-party AI models.

Automated Decision-Making

VOLOCOACH does not use AI-generated content to make automated decisions that produce legal or similarly significant effects within the meaning of Article 22 of the UK GDPR.

7. Sharing of Personal Data

We share personal data only where necessary for the operation of the App.

Between Users

• Coaches may view Learners’ names and skill levels for lesson preparation.
• Learners may view Coaches’ public profiles, qualifications, pricing, and reviews.

Independent Data Controllers

Note on Coaches: Coaches act as independent data controllers in respect of any personal data they access through the App. Coaches are legally responsible for complying with UK GDPR when processing such data. VOLOCOACH is not responsible for, and does not control, any personal data processing conducted by Coaches outside the VOLOCOACH platform.

Service Providers (Processors)

All processors act under contractual obligations and process data only on our documented instructions:

• Stripe: Payment processing, payouts, refunds, and dispute handling.
• Cloud Providers: Hosting and data storage.
• AI Providers: Speech-to-text and summarisation.

Legal & Safety Disclosures

We may disclose personal data where required by law or to prevent fraud, protect safety, enforce Terms, or respond to legal requests.

8. International Data Transfers

Some of our service providers are located outside the United Kingdom. Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including:

• The UK International Data Transfer Agreement (IDTA);
• The UK Addendum to the EU Standard Contractual Clauses; or
• Transfers to countries deemed “adequate” by the UK Government.

9. Data Security

We implement appropriate technical and organisational measures to protect personal data, including:

• Encryption in transit (SSL/TLS);
• Tokenisation of payment data (via Stripe);
• Role-based access controls.

Access to personal data is limited to personnel and partners with a legitimate business need.

10. Data Retention

We retain personal data only for as long as necessary:

• Account Data: Retained while your account remains active.
• Transaction & Tax Records: Retained for 6 years in accordance with UK legal obligations.
• Dispute & Enforcement Records: Retained for up to 6 years to defend against legal claims, chargebacks, or regulatory inquiries.
• Audio Recordings: Deleted within 24 hours.

When data is no longer required, it is securely deleted or anonymised.

11. Your Rights Under UK GDPR

You have the right to:

• Access your personal data.
• Rectify inaccurate data.
• Request Erasure (“right to be forgotten”).
• Restrict or Object to processing.
• Withdraw Consent at any time (where processing is based on consent).

To exercise these rights, contact: 📧 privacy@VOLOCOACH.com

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

12. Children’s Privacy

VOLOCOACH does not permit children to create accounts or use the App independently.

Any coaching sessions involving minors must be booked and managed by a parent or legal guardian using their own account.

We do not knowingly collect personal data directly from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the App or by email where appropriate.

14. Contact Us

For questions or concerns regarding this Privacy Policy, please contact our Data Protection Officer:

📧 privacy@VOLOCOACH.com
📍 VOLOCOACH LIMITED
128 City Road, London, United Kingdom, EC1V 2NX