Privacy Policy

Effective Date: 01/07/2025
Last Updated: 01/07/2025 10:00am

1. Introduction

Welcome to Shonazz EduVerse Ltd (“we,” “our,” or “us”), a company registered in England and Wales. We operate Shonazz.com, an AI and VR-powered learning platform (“Service”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our application, or engage with our services.

This Privacy Policy is governed by UK data protection law, primarily the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We also comply with applicable international data protection laws where we serve users globally.

By accessing or using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you disagree with any part of this policy, please do not access the Service.

2. Information We Collect

2.1 Personal Information You Provide

We collect information you voluntarily provide to us, including:

Account Information: Name, email address, username, password, and profile information
Contact Information: Phone number, mailing address, and emergency contact details
Payment Information: Billing address, payment method details (processed securely by third-party payment processors)
Profile Data: Learning preferences, skill levels, educational background, and goals
Communication Data: Messages, feedback, support requests, and survey responses

2.2 Automatically Collected Information

When you use our Service, we automatically collect:

Usage Data: How you interact with our platform, features used, time spent, and navigation patterns
Device Information: IP address, browser type, operating system, device identifiers, and hardware specifications
Location Data: General location information based on IP address (with your consent for precise location)
Performance Data: System performance, error logs, and technical diagnostics

2.3 VR and AI-Specific Data

Our platform may collect:

Biometric Data: Eye tracking, head movement, and gesture data during VR sessions (anonymized when possible)
Learning Analytics: Progress tracking, completion rates, assessment scores, and learning patterns
Voice Data: Audio recordings for voice commands and language learning (processed locally when possible)
Interaction Data: VR environment interactions, AI chatbot conversations, and personalized recommendations

2.4 Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

Remember your preferences and settings
Analyse platform usage and performance
Provide personalized content and recommendations
Ensure security and prevent fraud

3. How We Use Your Information

We process your personal data in accordance with UK GDPR principles and only where we have a lawful basis to do so:

3.1 Service Provision (Lawful Basis: Contract Performance)

Provide, maintain, and improve our learning platform
Process your registration and manage your account
Deliver personalised learning experiences and content
Facilitate VR sessions and AI-powered interactions
Process payments and manage subscriptions

3.2 Communication (Lawful Basis: Contract Performance & Legitimate Interests)

Send important service updates and notifications
Respond to your inquiries and provide customer support
Send marketing communications (with your consent where required)
Notify you about new features, courses, and opportunities

3.3 Analytics and Improvement (Lawful Basis: Legitimate Interests)

Analyse usage patterns to improve our services
Conduct research and development for new features
Monitor platform performance and troubleshoot issues
Generate anonymised reports and statistics

3.4 Legal and Security (Lawful Basis: Legal Obligation & Legitimate Interests)

Comply with legal obligations and regulatory requirements
Protect against fraud, abuse, and security threats
Enforce our terms of service and policies
Resolve disputes and investigate violations

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Service Providers

We work with trusted third-party service providers who assist us in:

Cloud hosting and data storage
Payment processing
Email and communication services
Analytics and performance monitoring
Customer support tools

These providers are contractually bound to protect your information and use it only for specified purposes.

4.2 Educational Partners

With your consent, we may share relevant learning data with:

Educational institutions you’re affiliated with
Corporate training partners (for enterprise accounts)
Content creators and curriculum developers (anonymized data only)

4.3 Legal Requirements

We may disclose information when required by law or in good faith belief that such action is necessary to:

Comply with UK legal processes, court orders, or regulatory requests
Comply with international legal obligations where we operate
Protect our rights, property, and safety, or that of our users
Investigate potential violations of our terms of service
Respond to claims of illegal activity or intellectual property infringement

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to this Privacy Policy.

5. Data Security

We implement robust security measures to protect your information:

5.1 Technical Safeguards

End-to-end encryption for sensitive data transmission
Secure data storage with industry-standard encryption
Multi-factor authentication for account access
Regular security audits and vulnerability assessments

5.2 Organizational Measures

Limited access to personal data on a need-to-know basis
Employee training on data protection and privacy
Incident response procedures for security breaches
Regular review and update of security policies

5.3 VR-Specific Security

Local processing of biometric data when possible
Anonymization of movement and interaction data
Secure transmission protocols for VR session data
User controls for data sharing preferences

Note: While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

6. Your Rights and Choices

Under UK GDPR, you have the following rights regarding your personal data:

6.1 Right of Access (Article 15)

Request confirmation of whether we process your personal data
Request a copy of your personal data and processing information
Export your learning progress and achievements

6.2 Right to Rectification (Article 16)

Request correction of inaccurate or incomplete personal data
Update your profile and preference settings
Request corrections to learning records

6.3 Right to Erasure (Article 17)

Request deletion of your personal data in certain circumstances
Delete your account and associated data (subject to legal retention requirements)
Request removal of specific information where no longer necessary

6.4 Right to Restrict Processing (Article 18)

Request limitation of processing in specific circumstances
Suspend certain data processing activities
Maintain but not actively process your data

6.5 Right to Data Portability (Article 20)

Receive your personal data in a structured, commonly used format
Transmit your data to another controller where technically feasible
Download your account information and learning records

6.6 Right to Object (Article 21)

Object to processing based on legitimate interests
Opt-out of direct marketing communications
Object to profiling and automated decision-making

6.7 Right to Withdraw Consent (Article 7)

Withdraw consent for processing where consent is the lawful basis
Control cookie and tracking preferences
Modify data sharing preferences

6.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk if you believe your data protection rights have been violated.

7. Children’s Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

7.1 Age Verification

We require users to confirm they are 13 or older during registration
Parental consent is required for users between 13-17 years old
Special protections apply to educational accounts for minors

7.2 Educational Use

For educational institutions using our platform with minors:

We comply with COPPA and FERPA regulations
Enhanced privacy protections and data minimization
Institutional oversight and parental notification requirements

8. International Data Transfers

As a UK-based company, we primarily process data within the UK. When we transfer personal data outside the UK, we ensure appropriate safeguards are in place:

8.1 Adequacy Decisions

We may transfer data to countries recognised by the UK as providing adequate protection
Current adequacy decisions include EEA countries and specific third countries approved by the UK

8.2 Standard Data Protection Clauses

We use UK-approved Standard Contractual Clauses (SCCs) for transfers to non-adequate countries
Additional safeguards and impact assessments where required
Regular monitoring of data protection standards in destination countries

8.3 Cloud Services and Processors

Our cloud service providers implement appropriate technical and organisational measures
Data processing agreements ensure UK GDPR compliance
Regular audits and assessments of international service providers

9. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations:

9.1 Account Data

Active accounts: Retained while account is active plus 30 days after closure
Inactive accounts: Deleted after 3 years of inactivity (with prior notice)

9.2 Learning Data

Progress and achievements: Retained for 7 years for educational records
VR interaction data: Anonymized after 90 days, deleted after 2 years
Communication data: Retained for 3 years for support purposes

9.3 Legal and Compliance

Financial records: Retained per applicable tax and accounting laws
Legal disputes: Retained until resolution plus applicable statute of limitations

10. Third-Party Services

Our platform may integrate with third-party services:

10.1 Educational Tools

Learning management systems (LMS)
Video conferencing platforms
Assessment and grading tools

10.2 Social Features

Social media integration
Collaboration platforms
Community forums

Note: Third-party services have their own privacy policies. We encourage you to review these policies before using integrated services.

11. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements.

11.1 Notification Process

Email notification to registered users
Prominent notice on our website
In-app notifications for material changes

11.2 Effective Date

Changes become effective 30 days after notification
Continued use constitutes acceptance of updated policy
Right to object or close account if you disagree with changes

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@shonazz.com
Phone: +441212743569
Address:
Shonazz EduVerse Ltd
128 City Road,
London, EC1 2NX
England, United Kingdom

Data Protection Officer: dpo@shonazz.com

13. Jurisdiction-Specific Information

13.1 United Kingdom (Primary Jurisdiction)

This Privacy Policy is governed by UK data protection law. As our primary jurisdiction, we comply with:

UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Privacy and Electronic Communications Regulations (PECR)
Relevant sector-specific regulations

UK Supervisory Authority: Information Commissioner’s Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113

13.2 European Union (GDPR)

For EU users, we comply with EU GDPR requirements:

Equivalent rights to UK GDPR users
Appropriate safeguards for UK-EU data transfers
EU representative available upon request

13.3 United States

For US users, we comply with applicable state privacy laws:

California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
Virginia Consumer Data Protection Act (VCDPA)
Other state-specific privacy legislation

13.4 Other Jurisdictions

We comply with applicable data protection laws in all jurisdictions where we serve users, including:

Canada (Personal Information Protection and Electronic Documents Act)
Australia (Privacy Act 1988)
Other applicable regional privacy laws

Note: Where conflicts arise between different jurisdictions, UK law takes precedence for users based in the UK, while users in other jurisdictions receive protections equivalent to or greater than local requirements.