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Privacy Policy

Last updated: 2 October 2026

1. Who we are

TKOLab is operated by TKO Software Ltd, a company registered in Cyprus under number [REG. NUMBER], with its registered office at [REGISTERED ADDRESS]. For any question about this policy or your personal data, contact us by email.

2. Our role

For student records inside an academy's account, the academy is the controller and we are its processor — it decides what to collect, we only act on its instructions. If you are a student or a parent and want records changed or deleted, contact your academy. We offer academies a Data Processing Agreement under Article 28 of the GDPR on request.

We are the controller for staff accounts and for people who contact us directly.

3. What we hold and why

DataPurposeLegal basis
Student name, email, address, phone numbers, date of birth, parent or guardian name Running the academy's membership records Contract
Emergency doctor name and phone number So the academy can act in an emergency on the mats Vital interests / contract
Belts, stripes and promotion dates Grading history Contract
Charges, payments, balances, expenses Billing and accounting Contract and legal obligation
SMS messages sent and when Payment reminders and notices, on the academy's instructions Contract
Staff email, encrypted password, role Account access Contract
Enquiry name, email, phone, message Replying to you Legitimate interests

Academies commonly teach children, so these records often relate to minors. The academy is responsible for any consent required. We never use this data for marketing, profiling or automated decision-making.

4. Who else processes it

  • Heroku (Salesforce) — hosting and database
  • Stripe — payments. Card details go directly to Stripe and never reach our servers
  • sms.to (Intergo Telecom Ltd, Paphos, Cyprus) — SMS delivery. Processes within the EEA and is certified to ISO 27001:2022
  • Twilio — SMS delivery, used as a fallback route

Each receives only what it needs — an SMS provider gets a phone number and message text, not a student's grading history. We do not sell personal data or share it for advertising. Where a sub-processor transfers data outside the EEA, that transfer relies on the European Commission's Standard Contractual Clauses.

5. How long we keep it

Student records are kept for as long as the academy's account remains open. We do not currently delete records automatically once an account closes — if you want data erased, contact us or your academy and we will action it. Financial records are retained as long as accounting and tax law requires. Login codes expire within minutes.

6. Your rights

You can ask for access, correction, deletion, restriction or portability of your data, or object to its use. Email us; where we hold it for an academy we will pass your request on. You can also complain to the Office of the Commissioner for Personal Data Protection in Cyprus, or the authority where you live.

7. Security and cookies

Traffic is encrypted with TLS, passwords are stored hashed, and access is restricted by role. Student portal access uses short-lived one-time codes rather than passwords. We use only cookies needed to run the site and keep you signed in — no advertising or tracking cookies.

8. Changes

We will update the date above when this policy changes.

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