PRIVACY POLICY

Last updated: 26th July 2026

1. Who we are

This Privacy Policy explains how Lupo Academy trading as Lupo Academy, collects, uses, stores and shares personal information.

Lupo Academy is the data controller for the personal information described in this policy.

Our contact details are:

Business name: Lupo Academy
Legal name: Lupo Academy
Business address: 21 Shipton Way, Basingstoke, Hants, RG22 6JX
Email: tracey@lupoacademy.co.uk
Telephone: 07825 548600
Website: www.lupoacademy.co.uk
ICO registration number: N/A

2. Personal information we collect

Depending on how you interact with us, we may collect:

Identity and contact information

• Name
• Email address
• Telephone number
• Postal address
• Emergency contact details where relevant

Information about your dog

• Name, age, breed and sex
• Training history
• Behavioural information
• Health, veterinary or medication information
• Photographs and videos
• Information about previous incidents or safety concerns

Information about your dog may also be personal information where it is connected to you.

Booking and payment information

• Services and products purchased
• Booking dates
• Payment status
• Transaction references
• Refund and cancellation records
• Invoices and accounting information

Payment-card details are normally processed directly by payment providers such as Stripe or PayPal. We do not normally receive your complete card details.

Online-course information

• Teachery account details
• Course enrolments
• Course progress
• Workbook or assessment submissions
• Videos submitted for assessment
• Written feedback and assessment results
• Support questions and messages

Communications

• Emails
• Contact-form submissions
• Messages sent through social media or support groups
• Notes made during telephone conversations
• Complaints and feedback

Photographs and recordings

• Class photographs
• Training footage
• Assessment videos
• Testimonials
• Images or recordings submitted by you

Technical information

• IP address
• Device and browser information
• Login and security records
• Website usage
• Cookie choices
• Information collected by our website, course platform or other service providers

Marketing preferences

• Whether you have agreed to receive marketing
• The types of communication requested
• Unsubscribe and objection records

Health and accessibility information

You may choose to tell us about a health condition, disability or accessibility requirement where this is relevant to safe participation.

This may be special-category personal data. We will only use it where we have an appropriate lawful basis and additional legal condition, such as your explicit consent or where it is necessary to protect someone in an emergency.

3. How we collect information

We collect information:

• Directly from you when you book, purchase, enquire or attend
• Through our website and online forms
• Through Teachery, Jotform and similar platforms
• Through payment providers
• When you email, telephone or message us
• When you join a support group
• When you submit an assessment
• When photographs or recordings are created with appropriate notice and consent
• From another household member where they make a booking on your behalf

4. Why we use your information

We may use personal information to:

• Respond to enquiries
• Take and manage bookings
• Process payments and refunds
• Provide classes, appointments and digital products
• Create and manage course accounts
• Deliver assessments and feedback
• Provide customer support
• Communicate changes, safety information or service updates
• Understand your dog’s needs and manage safety
• Maintain financial, tax and business records
• Prevent fraud and protect accounts
• Resolve complaints and legal disputes
• Improve our services
• Send marketing where permitted
• Use agreed photographs, videos or testimonials for promotional purposes
• Comply with legal and regulatory obligations

5. Our lawful bases

We rely on different lawful bases depending on why we are using the information.

Contract

We use information where it is necessary to take steps at your request before a booking or to perform our agreement with you.

This includes:

• Processing bookings
• Taking payment
• Providing a course
• Setting up an account
• Delivering support or assessment
• Contacting you about the purchased service

Legal obligation

We use information where necessary to comply with obligations relating to tax, accounting, consumer protection, insurance, court orders or other applicable laws.

Legitimate interests

We may use information where reasonably necessary for our legitimate business interests, provided those interests are not overridden by your rights.

This may include:

• Business administration
• Service planning
• Preventing fraud
• Protecting our website and accounts
• Maintaining records
• Dealing with complaints
• Establishing or defending legal claims
• Improving our services
• Sending limited communications to existing customers where legally permitted

Where we rely on legitimate interests, we consider the necessity and impact of the processing.

Consent

We may rely on consent for:

• Promotional photographs or videos showing identifiable people
• Testimonials
• Certain electronic marketing
• Optional sharing of sensitive health or accessibility information
• Other optional uses that are not necessary to provide the service

Consent will be requested separately and will not be assumed from acceptance of our Terms and Conditions.

You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Vital interests

In a genuine emergency, we may use or share information where necessary to protect someone’s life or physical safety.

6. Photographs, video and promotional material

We may take photographs or videos during services.

Where an identifiable customer is to appear in marketing, we will normally ask for separate consent.

Refusing consent will not affect your ability to attend or purchase.

You may withdraw consent for future use by contacting us. We will stop new use and remove material from our own channels where reasonably practicable.

We may not be able to remove:

• Printed material already distributed
• Copies previously downloaded
• Material shared or reposted by other people
• Archived material that we must retain for legal reasons

We will not use assessment videos for general marketing unless you have separately agreed.

7. Marketing communications

Accepting our Terms and Conditions or buying a service does not automatically mean that you have agreed to receive all marketing.

Where consent is required, we will provide a separate choice that is not pre-ticked.

In some circumstances, the law may allow us to send marketing about similar services to existing customers. Every marketing email will provide a way to unsubscribe.

You may ask us to stop direct marketing at any time. We may retain a minimal suppression record so that we remember not to contact you again for marketing.

8. Who we share information with

Where necessary, we may share information with:

• Teachery, for online-course hosting and access
• Stripe or PayPal, for payment processing
• Jotform, for forms, submissions and assessments
• Website, email, calendar and cloud-storage providers
• Video-conferencing providers such as Zoom
• Facebook or other community platforms where you choose to join a group
• Accountants, insurers, legal advisers and professional consultants
• Contractors who help us operate the business
• HM Revenue & Customs and other public authorities
• Law-enforcement agencies, courts or regulators where required
• A purchaser or successor if the business is lawfully transferred

We only share information where there is a valid reason and limit the information to what is reasonably necessary.

Third-party platforms may also act as independent data controllers for some uses. Their own privacy policies will apply to those activities.

9. International data transfers

Some of our service providers may store or process information outside the United Kingdom.

Where personal information is transferred internationally, we will take reasonable steps to ensure that an appropriate legal safeguard is used. This may include:

• A UK adequacy regulation
• Approved contractual safeguards
• Another lawful transfer mechanism

Further information about a particular provider’s arrangements may be available in that provider’s privacy notice.

10. How long we retain information

We keep personal information only for as long as reasonably needed.

Our normal retention periods are:

Booking, payment and contractual records

Normally retained for up to six years after the transaction or end of the customer relationship, where required for accounting, tax, insurance or legal purposes.

Online-course accounts

Account and enrolment information is retained while ongoing course access remains available.

If an account is closed, relevant contractual and transaction records may be retained for up to six years.

General enquiries

Enquiries that do not result in a booking are normally deleted within 12 months, unless there is a reason to retain them longer.

Assessment submissions

Video and file submissions are normally deleted within 90 days after final feedback or completion of any included resubmission.

We may retain written feedback, results and transaction records for longer as part of your course and business records.

Health and accessibility information

This is normally deleted within 12 months after the relevant service ends, unless it is needed in connection with an accident, complaint, insurance matter or legal claim.

Marketing records

Marketing details are retained until you unsubscribe, withdraw consent or object.

A minimal record may be kept after an unsubscribe request to ensure that your preference continues to be respected.

Photographs and promotional recordings

Promotional material is retained while it remains relevant and consent remains valid. We will review stored promotional material periodically and remove it when it is no longer reasonably needed.

Website and security logs

Technical logs are normally retained for up to 12 months, unless they are required for security investigation, fraud prevention or legal purposes.

We may retain information for longer where a complaint, legal claim or regulatory investigation is ongoing.

11. How we protect information

We take reasonable technical and organisational measures to protect personal information.

These may include:

• Password-protected accounts
• Access controls
• Secure payment processing
• Secure cloud services
• Software updates
• Limited staff or contractor access
• Appropriate deletion and retention procedures

No online system is completely risk-free, but we take reasonable steps to reduce the risk of unauthorised access, loss, misuse or disclosure.

12. Your rights

Depending on the circumstances, you may have the right to:

• Ask for a copy of your personal information
• Ask us to correct inaccurate information
• Ask us to delete information
• Ask us to restrict how information is used
• Object to certain processing
• Object to direct marketing
• Receive certain information in a portable format
• Withdraw consent
• Complain about how your information is being handled

Some rights are subject to legal exemptions. For example, we may need to retain transaction records for tax or legal purposes even after you ask us to delete your account.

To exercise a right, contact tracey@lupoacademy.co.uk

We may need to confirm your identity before responding.

13. Complaints about data protection

Please contact us first so that we have an opportunity to address your concern.

You also have the right to complain to the Information Commissioner’s Office if you are unhappy with how we use your personal information.

14. Cookies

The Lupo Academy website does not currently use analytics, advertising or other non-essential cookies.

Purchases, course access and certain other services are provided through third-party websites. Those providers may use cookies when you visit their websites. Their use of cookies is governed by their own privacy and cookie information.

If we introduce cookies or similar technologies on this website in the future, we will update this notice and, where required, provide appropriate cookie controls before any non-essential cookies are used.

15. Links and third-party websites

Our website and course materials may link to external websites or platforms.

We are not responsible for how those organisations process personal information. You should review their privacy information before providing data directly to them.

16. Changes to this policy

We may update this policy to reflect changes to our services, providers or legal obligations.

The latest version will be published on our website with the date it was last updated.