Privacy Policy

Gaia Luxury Ltd (“we”, “us”) is the data controller for personal data processed through Path2Academy.

Registered office: 75 Victoria Road, Worthing, England, BN11 1UN. Company number 15136889.

Privacy and support contact: support@path2academy.com. Use the same address for data-protection queries; there is no separate dedicated privacy inbox at launch.

Parent or legal guardian account holders (18+).

Child/player data you provide for players aged 7–16 (children do not operate their own accounts).

We do not collect school name, medical, SEND or disability information at launch.

Account and contact details (such as name, email, optional mobile, country) and authentication data.

Player details you enter (such as first name, age/date of birth, position, club/level, preferred foot).

Optional reference photo used only to help identify the player in submitted footage.

Football match and skill footage and related identification notes you upload.

Generated reports, scores, Football Development Index™ outputs, Development Bands™, assessment-generated 30-Day Plans and membership Train Now history, plus development-history features where applicable.

Free Player Pathway consultation answers (parent name/email, player first name, age, environment and goal answers) used to generate an Action Plan. This free consultation does not collect footage or photos.

Optional marketing-email consent status, consent wording version and timestamps where you opt in.

UTM/source attribution values associated with a free consultation where provided.

First-party website analytics data when that feature is enabled (session identifier, landing page, referrer, UTM/source values, coarse device category and page-view counts). We do not store IP addresses for this analytics feature and we do not use fingerprinting for it.

Payment and membership status data from our payment provider (we do not store full card numbers).

Support communications you send us.

To create and secure accounts and provide the assessment and membership services.

To identify the correct player in footage, run AI-assisted analysis, and generate reports and plans.

To deliver the free Player Pathway Action Plan and related transactional result email/PDF downloads.

To send optional promotional nurture emails only where separate marketing consent is given, and to honour unsubscribe and purchase-suppression requests.

To process payments, entitlements, cancellations and customer support.

To protect the service against abuse, fraud and security threats.

To understand website traffic and marketing attribution using first-party analytics, and to produce anonymised and aggregated operational statistics to improve the service. Identifiable footage and photos are not reused for marketing, research, general AI model training, or unrelated promotion.

Contract: we process the parent’s information needed to provide the purchased assessment or membership service and to manage the account.

Legitimate interests: where appropriate, for secure operation, fraud prevention, support and delivery of the assessment or free Action Plan result, subject to the rights and best interests of the child. Limited anonymised and aggregated operational statistics may also be used to improve the service.

Legal obligation: billing, accounting and regulatory records where the law requires us to keep them.

Explicit consent: only where we genuinely rely on consent for a separate optional purpose, including optional Player Pathway marketing emails. Completing the free consultation or purchasing an assessment does not by itself constitute marketing consent.

The final lawful-basis assessment for child/player information remains documented in our DPIA and lawful-basis record and requires professional legal review before public launch. This policy does not claim final legal approval.

The reference photo is optional. It is used only to help identify the player in submitted footage. It is not used for facial recognition or as biometric data, and it is not sent to AI as a reference image.

Submitted football footage is processed using AI-assisted analysis (including Google Gemini for video analysis and OpenAI for text-based report generation steps).

Reports are not currently individually reviewed by a human football coach.

We do not use customer footage or photos for general AI model training, marketing, or research.

The parent/account holder through their account.

Authorised Path2Academy personnel only where genuinely necessary (for example support investigations or complaints).

Contracted technology providers required to host, process payments, send transactional email, or run analysis (see processors below).

Reports are not automatically shared with clubs, coaches, academies or scouts.

Supabase — authentication, database and private video/photo storage.

Vercel — website hosting and application delivery.

Stripe — payments and subscription billing.

Resend — transactional email delivery.

Google Gemini — AI-assisted video analysis.

OpenAI — AI-assisted text/report generation steps.

Data processing agreements and international-transfer documentation for these providers are marked for verification before public launch. This policy does not claim those reviews are complete.

Our providers may process personal data outside the United Kingdom.

Where a restricted transfer occurs, Gaia Luxury Ltd will use an appropriate lawful transfer mechanism under UK data protection law.

Further information about transfers may be requested through support@path2academy.com.

This policy does not state that every data processing agreement or transfer review is complete.

Account and profile data: while active and for 24 months after last activity, then normally delete or anonymise unless needed for legal, fraud, accounting or dispute purposes.

We normally delete player photos and footage within 90 days after the report is delivered, subject to the exceptions explained below.

Exceptions: we may keep photos or footage longer where temporarily needed for an active complaint, support investigation, legal dispute, or requested reassessment still in progress.

Reports, scores, FDI, Development Bands and plans: while the account is active and for 24 months after cancellation or last activity, subject to earlier valid deletion requests and legal obligations.

Billing and accounting records: six years from the end of the relevant financial year, or longer where legally required.

After membership cancellation, completed paid reports and their assessment-generated 30-Day Plans remain accessible during the retention period; membership benefits including new Train Now sessions stop according to the paid access period.

Non-converted Player Pathway consultation leads: normally up to 24 months from creation, then delete or anonymise unless needed for disputes, abuse prevention or law.

These retention periods describe our normal practice. They are not a claim that deletion is fully automated.

To request access, correction, deletion, restriction, objection, or data portability where applicable, email support@path2academy.com.

At launch, account deletion is handled by email request.

We will respond without undue delay and normally within one month of receiving a valid request. Where permitted by law, we may extend this period by up to two further months where a request is complex or numerous. If we need an extension, we will explain this within the first month.

This statutory data-rights timeframe is separate from our general support response target of 1–2 working days.

Deletion should include stored player photos, match footage, skill footage, and personal profile/database records not legally required. Encrypted backups may expire through the provider’s normal backup-retention cycle.

You may also complain to the UK Information Commissioner’s Office (ICO).

We use authentication, access controls, private storage for uploaded media, and HTTPS in transit.

No method of transmission or storage is perfectly secure; please keep your login details confidential.

We send transactional emails required to operate the service (for example payment confirmation, assessment submitted, report ready, failed membership payment, membership cancellation, entitlement notices, and free Player Pathway Action Plan delivery).

Optional promotional Player Pathway nurture emails are sent only where marketing consent was separately ticked. You can unsubscribe in one click. Promotional nurture stops after unsubscribe or after a verified purchase linked to the same authenticated parent account email.

Marketing consent is never required to receive the free Action Plan or to use paid services.

See also our shorter Child and Parent Privacy Notice.

We design the service for parent-managed accounts and do not offer child self-serve accounts at launch.

Path2Academy uses Google Analytics 4 to understand website usage. Where a visitor allows optional analytics and advertising cookies, Path2Academy also uses Microsoft Clarity and Meta measurement tools, including the Meta Pixel and Conversions API.

Microsoft Clarity provides heatmaps and session recordings only on eligible public, adult-facing pages intended for parents or legal guardians. Strict masking is enabled, custom identifiers are not used, and private account, player, assessment, footage, dashboard, report and administration routes are excluded.

The purpose is to understand traffic, how adult visitors use the public website, and whether advertising leads to visits, free-assessment engagement, paid-assessment starts or purchases.

For selected conversion events, browser and server event identifiers may be used so Meta can deduplicate the same conversion measured through the Pixel and Conversions API.

We do not intentionally disclose child or player identities, questionnaire answers, football assessment data, uploaded footage, report content or development scores to Google Analytics, Microsoft Clarity or Meta for this purpose.

Google Analytics traffic measurement is active on the Path2Academy website. Microsoft Clarity and Meta advertising measurement remain permission-gated; visitors can keep optional tools off and can later revisit Cookie settings.

Google, Microsoft and Meta act under their own privacy terms for data they receive through their analytics or advertising technologies. Our Cookie Policy explains when these services are used and the choices available to visitors.