Privacy Policy

Privacy Policy

Effective Date: April 16, 2025

This Privacy Policy outlines how Play2Skills (“we,” “our,” or “us”) collects, processes, and safeguards your personal information when you engage with our services. It explains your privacy rights under applicable data protection laws and our commitment to protecting your data.

When you access our services, we may collect and utilize certain personal information to enhance and personalize your experience. Your continued use of our services constitutes acceptance of these data practices as described in this policy.

Interpretation and Key Terms

1. Interpretation Guide

Capitalized terms throughout this Privacy Policy carry specific meanings as outlined below. These definitions apply equally to both singular and plural forms.

2. Defined Terminology

For clarity in this Privacy Policy:

• Account
  A registered user profile enabling access to our digital services.
• Company (“we”/”us”/”our”)
  Roch Academy Ltd, registered at 96 Royds Street, Rochdale, OL16 5JS, United Kingdom.
• Cookies
  Digital tracking mechanisms that store browsing information on your device to enhance website functionality.
• Service Region
  Primary operations based in England, United Kingdom, with potential international data processing.
• Device
  Any internet-capable hardware including computers, smartphones, tablets, or connected devices.
• Personal Data
  Information that directly or indirectly identifies a living individual.
• Service
  Our educational platform accessible via:
  • play2skills.com
  • playtoskills.com
• Service Partners
  Vetted third parties who assist in service delivery, analytics, or technical support under strict data agreements.
• Usage Analytics
  Automatically collected operational data including:
  • Session duration
  • Feature engagement
  • System performance metrics
• User (“you”)
  Any individual accessing our services, or organizations authorizing such access.

Data Collection and Usage

1. Information We Gather

When you interact with our platform, we collect certain personal details to deliver and enhance our services. This information falls into two primary categories:

A. Directly Provided Information

We may request the following identifiable details:

• Contact email address
• Telephone contact number
• Service engagement metrics

B. Automatically Collected Data

Our systems passively gather technical information during your visits:

Web Interaction Data:

• Device IP address
• Browser specifications (type, version)
• Visited pages with timestamps
• Session duration metrics
• System diagnostic information

Mobile-Specific Data (when applicable):

• Mobile device model and OS
• Unique device identifiers
• Mobile browser characteristics
• Network connection details

This technical data helps us optimize performance and troubleshoot issues. All information is collected in accordance with UK data protection regulations.

Cookie Policy & Data Usage

1. Tracking Technologies We Implement

To enhance your experience and service quality, we employ various digital tracking methods:

A. Cookie Types & Controls

• Standard Browser Cookies
  Small text files stored on your device that enable core website functions. You may disable these through browser settings, though this may limit service features.
• Flash-Based Storage
  Local shared objects that retain preferences for rich media content. These require separate management from standard cookies.
• Tracking Pixels
  Microscopic image files that help us analyze engagement patterns and email open rates.

B. Duration-Based Classification

• Session Cookies
  Temporary files deleted when you close your browser
• Persistent Cookies
  Remain on your device between browsing sessions

2. Specific Cookie Applications

Cookie Category	Type	Administrator	Primary Function
Essential	Session	Our Systems	Enable core service functionality and security
Preference	Persistent	Our Systems	Remember your language/account settings
Consent	Persistent	Our Systems	Track your cookie permission status

3. How We Process Personal Information

We utilize collected data to:

Service Operations

• Maintain and secure user accounts
• Fulfill contractual obligations
• Process service requests

Communication

• Send important service notifications
• Respond to inquiries
• Deliver relevant updates (with opt-out options)

Business Development

• Analyze usage patterns
• Improve service features
• Conduct legitimate business transitions

User Experience

• Personalize interface settings
• Measure engagement metrics
• Optimize marketing effectiveness

For detailed cookie management options, please visit our dedicated [Cookie Policy] page.

Data Sharing Disclosure

1. Circumstances for Data Sharing

We maintain strict confidentiality of your personal information, except in these specific scenarios:

A. Operational Necessity

• Trusted Service Providers
  We engage verified partners who assist with:
  • Service performance monitoring
  • Analytical assessments
  • User communication delivery

B. Corporate Transactions

During business restructuring events including:
✓ Mergers or acquisitions
✓ Asset sales or transfers
✓ Financial reorganizations

We may transfer user data as part of transaction proceedings, always subject to equivalent privacy protections.

C. Corporate Family

Information may be shared with:

• Parent organizations
• Subsidiary companies
• Joint venture partners

All affiliated entities are contractually bound by this privacy policy’s terms.

D. Partner Collaborations

We may disclose limited information to:

• Offer co-branded services
• Provide exclusive promotions
• Deliver partner-sponsored content

E. Public Interactions

Content you voluntarily share in:

• Public forums
• Community features
• User-generated content areas

May become visible to other users and potentially redistributed beyond our platform.

F. Consent-Based Disclosures

With your explicit permission, we may share information for:

• Special program participation
• Third-party service integration
• Other authorized purposes

Data Retention & International Transfer Policy

1. Data Retention Practices

We maintain personal information only for necessary operational and legal periods:

A. Retention Period Determination

We consider these factors when retaining your data:

• Active Usage: Duration of your account activity
• Legal Requirements: Statutory obligations (typically 3-7 years)
• Business Necessity: Ongoing service requirements
• Dispute Resolution: Potential legal proceedings

B. Data Category Retention

Data Type	Typical Retention Period
Account Information	While active + 3 years post-inactivity
Transaction Records	7 years for financial compliance
Usage Analytics	12-36 months (anonymized after 6 months)
Marketing Data	Until opt-out or 3 years post-collection

2. Cross-Border Data Transfers

A. Transfer Circumstances

Your information may be processed in:

• Our UK headquarters (Rochacademy Ltd, Manchester)
• Partner locations globally
• Cloud servers in compliant jurisdictions

B. Transfer Safeguards

We implement rigorous protections including:
✓ EU Standard Contractual Clauses
✓ UK GDPR adequacy determinations
✓ Enterprise-grade encryption in transit
✓ Regular vendor compliance audits

C. Your Rights Regarding Transfers

You may:

• Request transfer impact assessments
• Withdraw consent (where applicable)
• Ask about specific safeguards for your data

We will never transfer data to jurisdictions without:

• Recognized adequacy status OR Equivalent protective measures

Data Disclosure & Protection Policy

1. Circumstances for Data Disclosure

A. Corporate Restructuring Events

In cases of:

• Business mergers
• Company acquisitions
• Asset transfers

We may disclose personal information to relevant parties. You will receive:
✓ Prior notification of any data transfer
✓ Details about the new privacy policy
✓ Options regarding your data (where applicable)

B. Legal Compliance Disclosures

We may share information when legally required to:

• Respond to court orders or subpoenas
• Comply with government investigations
• Meet regulatory reporting requirements

C. Protective Disclosures

We reserve the right to disclose data when necessary to:

• Prevent imminent physical harm
• Investigate suspected illegal activities
• Defend against legal claims
• Protect company property rights
• Ensure service integrity

2. Data Security Measures

Our Protection Framework Includes:

• Enterprise-grade encryption protocols
• Regular security audits
• Restricted access controls
• Continuous system monitoring

Security Reality Disclaimer:

While we implement industry-standard protections including:
✓ TLS 1.2+ encryption
✓ Multi-factor authentication
✓ Regular penetration testing

Please understand that:
• No digital system offers 100% security
• Users share responsibility for account protection
• We cannot guarantee against sophisticated cyber threats

We commit to:

• Immediate breach notification (as required by law)
• Prompt mitigation of vulnerabilities
• Continuous security improvements

Children’s Privacy & External Links
Last Updated: [Current Date]

1. Youth Data Protection

A. Parental Consent Framework

Our platform offers services suitable for children under these conditions:
✓ Parent/guardian must complete all registrations
✓ We collect only:

• Child’s first name (no surnames)
• Age range (not exact birthdate)
  ✓ Parent contact information is verified

B. Data Handling Practices

• Collected youth data is:
  • Used solely for age-appropriate content delivery
  • Never used for profiling or marketing
  • Stored in encrypted formats
• Limited sharing occurs only with:
  • Education partners (under strict contracts)
  • Technical service providers (minimal data)

2. External Website Links

Important Notice About Third Parties:

We may provide links to external resources for:

• Educational supplements
• Payment processing
• Technical support

Critical user information:
⚠️ We don’t govern external site practices
⚠️ Links don’t imply endorsement
⚠️ Always review destination site policies

3. Policy Updates & Contact

A. Revision Procedures

We may modify this policy to reflect:

• New service features
• Regulatory changes
• Security improvements

Update notifications include:
✓ Website banners (30 days minimum)
✓ Email alerts (for account holders)
✓ Revised “Last Updated” dating

B. Contact Channels

For privacy inquiries:

• Primary: dataprotection@play2skills.com
• Alternative: info@play2skills.com
• Postal:
  Data Protection Officer
  Rochacademy Ltd
  3-5 Gale Street, Syke
  Rochdale OL12 0SQ, UK

Response timeline:
• Email: Within 5 business days
• Formal requests: 30 calendar days (per UK GDPR)