Who we are
TK Academy is a trading name of TK Capital Group (Company No. 1503570), a company registered in the Commonwealth of The Bahamas. Our registered office is at Equity Trust House, Caves Village, West Bay Street, P.O. Box N-10697, Nassau, Bahamas.
Our in-person training takes place at 33 Holland Street, London W8 4LX, United Kingdom.
You can contact us at info@tatianakarelinaacademy.com.
In this document, “we”, “us” and “our” refer to TK Capital Group trading as TK Academy. “You” refers to the student, prospective student or visitor to the Academy.
Summary
We collect the minimum personal data we need to provide TK Academy to you. We do not have access to the content of your Class TA conversations or any photographs you submit through Class TA. We do not store payment card details. We do not sell your data. We do not use your data to train artificial intelligence models.
The legal framework
Because we offer services to individuals in the United Kingdom and the European Union, this notice is written to comply with the UK GDPR (the UK General Data Protection Regulation), the EU GDPR and the UK Data Protection Act 2018. Bahamas data protection law (the Data Protection Act 2003) also applies to processing carried out at our registered office.
Data we collect and store
The personal data that TK Academy collects and stores on our own systems is limited to the following categories.
- Identity and contact data. Your name, email address, phone number and billing address as provided at enrolment.
- Account credentials. Your username and a hashed version of your password. We never see your password in plain text.
- Order and billing records. The plan you purchased, the price paid, the date of purchase, and an order reference. Card details are never stored on our systems.
- Course usage. Lessons watched, progress markers, notes you save, bookmarks, and time spent on each lesson.
- Apprenticeship application data. Where relevant, the information you provide when applying for the in-person apprenticeship and any related correspondence with our team.
- Technical data. IP address, device type, browser, cookies and similar identifiers used for security and to keep your session signed in.
- Support correspondence. Emails and messages you send to our support team and our replies.
Data we do not see or store
The following data is processed by third party providers as part of delivering the Academy to you. TK Academy does not have access to this data, does not store it on our own systems, and is not in a position to retrieve it.
- Class TA conversation content. When you use Class TA, your questions and any photographs you upload are processed by a third party artificial intelligence provider. We see only that a session took place and which lesson it was associated with, for the purpose of usage metering. We do not see the content of your conversations or any photographs you submit.
- Payment card details. Your card number, expiry date and security code are entered into a payment form hosted by a third party payment processor. TK Academy never sees or stores these details. We receive only a confirmation that payment was successful and a non-sensitive transaction reference.
Data we do not collect
To be explicit about what we do not do:
- We do not collect biometric data.
- We do not use facial recognition on any photograph you upload.
- We do not use your personal data, your photographs, or your Class TA conversations to train any artificial intelligence model.
- We do not sell your data to advertisers or any other third party.
- We do not track you across other websites for advertising purposes.
- We do not knowingly collect data from anyone under 18 (see “Children” below).
How we use your data
We use the data we collect to:
- Provide the Academy service you have enrolled in
- Process your payment and issue receipts
- Send service emails such as enrolment confirmations, password resets and order receipts
- Provide customer support when you contact us
- Send marketing emails about new modules, events and offers, where you have given consent (you can withdraw at any time)
- Improve the Academy, prioritise new lessons, and identify which content is most useful to students
- Keep the service secure and prevent fraud and abuse
- Comply with our legal obligations, including tax record keeping
Lawful basis under UK and EU GDPR
We rely on the following lawful bases for processing your data.
- Contract. To provide the Academy you have enrolled in and to process your payment.
- Legitimate interests. To keep the service secure, to improve it, and to communicate with existing students about related offerings. We balance this interest against your rights and you can object at any time.
- Consent. For marketing emails sent to people who have not yet enrolled, and for non-essential cookies. You can withdraw consent at any time.
- Legal obligation. To retain records for tax and accounting purposes, and to respond to lawful requests from authorities.
Third party sub-processors
We use a small number of established third party providers to deliver the Academy. We choose providers who offer strong data protection commitments and who are bound by contract to process your data only on our instructions and to maintain appropriate security.
The categories of provider we use are:
- Third party payment processors for handling card payments
- Third party email delivery providers for sending transactional and marketing emails
- Third party video hosting providers for the lesson library
- Third party artificial intelligence providers for the Class TA feature
- Third party cloud hosting providers for the Academy infrastructure
- Third party analytics providers (anonymised, where used)
A current list of named sub-processors is available on request.
International transfers
Personal data may be transferred to and processed in countries outside the United Kingdom and the European Economic Area, including the Bahamas (where our registered office is located) and the United States (where some of our service providers are based). Where this occurs, we rely on adequacy regulations, standard contractual clauses, or other lawful transfer mechanisms recognised under the UK GDPR and EU GDPR.
How long we keep your data
We keep your data only for as long as we need it.
- Account and course progress data. While your account is active, plus six years after closure to meet accounting and tax record requirements.
- Order and billing records. Seven years from the date of the transaction to comply with tax and accounting obligations.
- Class TA metadata. While your account is active, then deleted within 90 days of account closure. (Note: we do not have the conversation content itself.)
- Marketing data. Until you unsubscribe, then a suppression record is kept so we do not contact you again.
- Support correspondence. Three years from the last contact.
Backups may persist for a short period after deletion in line with standard recovery cycles. After this period, your data is permanently removed.
Your rights
You have the right to:
- Access the personal data we hold about you
- Ask for corrections to inaccurate or incomplete data
- Ask for your data to be deleted, where we have no continuing reason to retain it
- Object to processing carried out under legitimate interests
- Restrict processing in certain circumstances
- Receive your data in a portable format
- Withdraw consent at any time, where we rely on consent
- Lodge a complaint with a supervisory authority (see below)
To exercise any of these rights, email info@tatianakarelinaacademy.com. We respond within one month, or one month plus an extension where the request is complex.
UK and EU representative
Because our registered office is outside the United Kingdom and the European Union, we are required under Article 27 of the UK GDPR and the EU GDPR to appoint a representative in each jurisdiction. Details of our appointed representatives will be published here once finalised.
Complaints
If you believe we have not handled your data properly, please contact us first at info@tatianakarelinaacademy.com so we can try to resolve the matter directly.
If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office in the United Kingdom (ico.org.uk) or with the data protection authority in your country of residence in the European Union.
Security
We protect your data using industry-standard measures including encryption in transit (HTTPS for all pages, TLS for all data transfer), encryption at rest for sensitive fields, hashed password storage, access controls, and regular review of our security practices.
No system is perfectly secure. We encourage you to use a unique strong password for your TK Academy account and to log out when using shared devices.
Cookies
We use a small number of cookies to keep you signed in, remember your preferences, and (with your consent) measure how the Academy is used. See our Cookie Policy for the full list.
Children
TK Academy is a professional training programme intended for hair stylists and extensionists aged 18 or over. We do not knowingly collect data from anyone under 18. If you believe a child has provided us with personal data, please contact us and we will delete it.
Automated decision-making
We do not make automated decisions about you that produce legal or significant effects. Class TA produces answers using artificial intelligence, but its responses are educational guidance, not binding decisions about you.
Changes to this policy
We may update this policy from time to time. Material changes will be notified by email and posted here with a new effective date. Continued use of TK Academy after a change means you accept the updated policy.
