Privacy Policy

1. Personal Data We Collect

We collect personal data that you provide directly to us, as well as information generated through your interactions with our services. This may include your name, email address, phone number, date of birth, residential address or country of residence, nationality, languages spoken, professional role, employer details, job or application information, CVs, portfolios, website addresses, social media handles, follower metrics and other similar identifiers. We may also receive photos or videos that you submit or that are captured at events, as well as voice recordings or screen recordings taken during meetings, workshops or digital interactions. Additional information relating to your interests, form submission dates, application responses and any long form answers provided within questionnaires or interviews may also be collected.

Where relevant, and only when voluntarily provided or required for specific services, we may process information relating to health or disability needs, accessibility requirements, demographic characteristics such as gender or ethnicity and cultural or religious information. We treat such information with heightened care due to its sensitive nature.

In connection with payments, we may process billing addresses, VAT or company details and invoice records. Payment card details are not stored by us and are handled securely by third party payment processors such as Stripe, PayPal or Apple Pay.

We also collect certain technical and usage information when you interact with our websites or platforms. This may include IP addresses, cookie data, device and browser information, analytics identifiers, platform usage insights, server logs and information collected through tools such as Google Analytics, Meta Pixel, TikTok Pixel, Snapchat Pixel, LinkedIn Insight Tag or Hotjar. Within our Roblox experiences, we may collect gameplay information such as progress, achievements and experience points. Within Discord, we may process user IDs, participation data and certain message information where required for moderation and safety.

We may further collect information relating to participation in our academy programmes, workshops, talent pool, employment or apprenticeship pathways, event registrations, airport visits, assessment results, certificates achieved and mentorship or coaching notes. All information submitted through Airtable, Webflow, Kit, Microsoft Forms, Canva or similar tools may be processed as part of these activities.

2. How We Use Personal Data

We use personal data to operate, deliver and improve our services. This includes communicating with you, providing access to training or academy programmes, reviewing applications, coordinating events, administering our community platforms, supporting moderation and safeguarding within Discord and Roblox, managing talent pool submissions, facilitating sponsorship reporting, verifying eligibility for certain activities and responding to enquiries or customer support requests.

Data is also used for marketing, analytics, segmentation and the optimisation of our websites, social media activities and digital tools. We may process personal data to meet our contractual obligations, administer payments, prevent fraud, fulfil legal requirements, manage internal operations and support the development of new services, programmes or features. Where we rely on consent, you may withdraw it at any time.

3. Lawful Bases for Processing

We process personal data in accordance with applicable data protection laws and rely on a combination of lawful bases depending on the nature of the processing. These include consent, the performance of a contract, compliance with legal obligations, our legitimate interests in operating and improving our services and, in limited cases, public interest considerations where relevant. We will inform you of the applicable basis where required by law.

4. Data Relating to Children and Minors

We take the protection of minors seriously. Our Roblox experiences may be accessed by individuals under the age of 18 and, in such cases, we collect only the limited information required for gameplay, safety and platform functionality. Discord, which is used for community engagement, is intended for users aged thirteen or over, and accounts identified as belonging to individuals under this age will be removed in accordance with platform rules.

For academy services, events or any programmes intended for younger participants, we may require consent from a parent or guardian. We do not knowingly collect personal data from children under thirteen except through platforms that independently manage age verification, such as Roblox. Any data relating to minors is handled with particular care and only to the extent necessary to deliver the relevant service.

5. Where Personal Data Is Stored

Personal data may be stored across several secure systems and platforms used within our operations. These include Airtable, ConvertKit/Kit, Webflow, Discord, Roblox backend systems, Microsoft 365, Google Drive, Apple iCloud, Zapier, Stripe, PayPal, LearnWorlds or equivalent learning management systems, Notion and encrypted local devices. These platforms are chosen for their security features and compliance with recognised industry standards.

6. Who Has Access to Personal Data

Access to personal data is limited to authorised individuals who require such access for operational, administrative, educational, technical or legal purposes. These may include members of our senior leadership team, administrative staff, community managers, moderators, developers, content and marketing teams, contractors and freelancers engaged to support our services, finance and accounting personnel, customer support teams, event staff, IT service providers and legal or compliance advisors. Access is granted on a role-specific, need-to-know basis.

7. Sharing Personal Data With Third Parties

We may share personal data with selected third parties where necessary to deliver our services or comply with legal obligations. These may include sponsors or brand partners, employers engaged in talent referral activities, educational institutions, event partners, analytics and advertising providers, email and communication service providers, payment processors, cloud storage or hosting partners, IT support services, external contractors, legal or financial advisors and regulatory authorities where required. Personal data is never sold to third parties.

8. International Transfers of Personal Data

Certain third party platforms we use may store or process personal data outside the United Kingdom or European Economic Area. Where such transfers occur, we rely on established legal mechanisms such as Standard Contractual Clauses, adequacy decisions or contractual safeguards to ensure that personal data is protected to standards consistent with applicable laws.

9. Data Retention

We retain personal data only for as long as it is reasonably necessary for the purposes set out in this Policy or as required by law. Factors that determine retention periods include the nature of the data, the purpose for which it was collected, legal or regulatory requirements and operational needs. Marketing and CRM data is generally retained until individuals unsubscribe or request deletion, while financial and tax records are retained for the minimum statutory period. Data relating to the talent pool, academy participation, events, Discord communities and Roblox gameplay may be retained for durations appropriate to the services offered or for as long as the associated account remains active.

10. Security Measures

We take reasonable and proportionate steps to protect personal data from loss, misuse, unauthorised access, disclosure or alteration. These measures include two factor authentication for administrative access, strong password requirements, device and cloud encryption, secure hosting environments, HTTPS across our websites, role based access controls, periodic reviews of access permissions, secure backups and platform level protections implemented within services such as Discord and Roblox. While we maintain appropriate safeguards, no system can be guaranteed as completely secure.

11. Data Breach Procedure

If we identify a personal data breach that is likely to result in a risk to individuals' rights or freedoms, we will notify the relevant supervisory authority in accordance with legal requirements. Where the law requires, we may also inform affected individuals. All breaches will be documented internally, and we will take steps to minimise harm and reduce the likelihood of recurrence. A designated Data Protection Lead will oversee breach management responsibilities within our organisation.

12. Your Rights

Depending on your location and the applicable legal framework, you may have rights concerning your personal data. These rights may include access, correction, deletion, restriction of processing, objection to processing, data portability, withdrawal of consent and rights relating to automated decision making. Requests to exercise these rights can be made using the contact details below, and we will respond in accordance with applicable laws.

13. Contact Information

If you have questions about this Privacy Policy or wish to exercise your data protection rights, you may contact us using the following details.

Email: Info@TheAirportGuy.co.uk Address: 5 Brayford Square, London, E1 0SG, United Kingdom Data Protection Lead: The Airport Group Data Protection Lead

14. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technologies or legal requirements. Any updates will be published on our websites and will take effect upon posting. Continued use of our services after such updates constitutes acceptance of the revised Policy.