PRIVACY POLICY

The Virtuoso Academy – Automate, Scale, Thrive

Version 4.0 | Effective: February 2026

This Privacy Policy explains how Sentient Sky Ltd (trading as “The Virtuoso Academy”) collects, uses, stores, and protects your personal data when you visit our websites, use our services, or purchase our products.

We comply with the UK GDPR, EU GDPR, HIPAA (where applicable), CCPA, the Australian Privacy Act 1988, and all other applicable data protection legislation.

1. Data Controller

The data controller is Sentient Sky Ltd, registered in England and Wales (Company No. 12222356), trading as The Virtuoso Academy.

Data Protection Contact: [email protected]
General Contact: [email protected]

A formal Data Protection Officer (DPO) will be appointed if required by law. Until then, all data protection enquiries are handled via the above contact.

2. Information We Collect

2.1 Information You Provide Directly

Name, email address, and contact details
Payment information (processed by Stripe; no card data stored)
Professional information provided via quizzes or forms
Community posts and interactions
Support enquiries and correspondence
Documents submitted for guarantee or refund claims
ELITE application data (practice size, revenue range, technology stack, goals, jurisdiction, motivation)
ELITE coaching session recordings (with consent) and session notes
ELITE priority support communications (Slack or Voxer)
Practice-specific information for Bespoke Implementation Blueprint development

2.2 Information Collected Automatically

IP address, browser type, device and operating system
Usage data such as pages visited and time spent
Cookie data (see Section 8)

2.3 Information from Third Parties

Payment confirmation from Stripe
Newsletter engagement data from Beehiiv
Advertising performance data from Meta

3. How We Use Your Information

To deliver Courses and provide platform access
To process payments and issue receipts
To communicate about purchases, delivery, and support
To deliver the Thrive Brief newsletter (if subscribed)
To personalise learning experiences
To improve our Website, Courses, and services
To send marketing communications (with consent)
To prevent fraud and ensure platform security
To meet legal and regulatory obligations
To develop ELITE Bespoke Implementation Blueprints
To conduct and record ELITE coaching sessions
To provide ELITE priority support via private channels

4. Legal Basis for Processing (UK/EU GDPR)

Contractual necessity: Delivering purchased services
Consent: Marketing, cookies, coaching session recordings
Legitimate interests: Analytics, fraud prevention, service improvement
Legal obligation: Tax and regulatory compliance

You may withdraw consent at any time.

5. Data Processors and Third-Party Services

Provider	Purpose	Location	Safeguards
Stripe, Inc.	Payment processing	United States	PCI-DSS Level 1; SCCs
Beehiiv, Inc.	Newsletter delivery	United States	SCCs; DPA
BuddyBoss / WordPress	Community and course delivery	US / EU	Encrypted transfer
Meta Platforms, Inc.	Advertising analytics	United States	SCCs; EU-US DPF
WhatsApp Business API	Customer communication	United States	Meta SCCs
Google Analytics (GA4)	Website analytics	United States	Anonymisation enabled
Klarna	Buy-now-pay-later (US only)	Sweden / US	PCI compliant
Slack / Voxer	ELITE priority support	United States	Encrypted messaging
Zoom / Google Meet	ELITE coaching sessions	United States	Enterprise-grade encryption

We do not sell or trade personal information.

6. International Data Transfers

Where data is transferred outside the UK or EEA, we rely on Standard Contractual Clauses, the EU-US Data Privacy Framework (where applicable), and additional safeguards.

7. Data Retention

Account and purchase data: Account duration plus 6 years
Newsletter data: Deleted within 30 days of unsubscribe
Analytics data: Anonymised; 26 months
Support correspondence: 2 years
Payment records: 6 years
Refund evidence: 6 years
ELITE application data: 2 years
ELITE coaching recordings: 12 months post-programme
ELITE Blueprint source data: Retained while account remains active
ELITE Slack/Voxer communications: 12 months post-programme

8. Cookies and Tracking

We use essential, analytics, and advertising cookies. EU and UK visitors are shown a consent banner before non-essential cookies are set.

9. Your Rights

9.1 All Users

Access your personal data
Correct inaccurate data
Unsubscribe from marketing

9.2 UK and EEA Residents

Erasure and restriction
Data portability
Object to processing
Lodge a complaint with the ICO

9.3 California Residents

Right to know and delete
Non-discrimination

9.4 Australian Residents

Access and correction rights
Right to complain to the OAIC

Contact [email protected] to exercise your rights.

10. Marketing Communications

Marketing messages are sent only where permitted. You may unsubscribe at any time. Transactional messages will still be sent where required.

11. Children’s Privacy

Our services are not intended for individuals under 18 years of age.

12. Security

Encrypted data transmission (SSL/TLS)
PCI-DSS Level 1 payment processing
Access controls and authentication
Encrypted ELITE coaching and support channels

No system is completely secure, but we take commercially reasonable steps to protect your data.

13. Changes to This Policy

Updates will be posted with a revised version number and effective date. Material changes will be communicated by email.

14. Contact Us

Privacy: [email protected]
General: [email protected]

Sentient Sky Ltd T/A The Virtuoso Academy
Registered in England and Wales – Company No. 12222356

Version History

Version	Date	Changes
1.0	October 2025	Initial release
3.0	February 2026	Major rebuild with expanded compliance
4.0	February 2026	Added ELITE data handling, coaching recordings, Blueprint data, and new processors