Last updated: [DATE]
1. Who we are
[Virtual CHRO] (“VCXO Academy”, “we”, “us”, “our”), registered in the Arab Republic of Egypt, with its registered address [The Greek Campus, Unit A12, Gate 17, Mall of Arabia, 6th of October, Giza, Egypt.], is the data controller for the personal data described here.
This policy explains what personal data we collect through vcxoacademy.com, our learning platform, our social media advertising, and our enrollment process; why we collect it; who we share it with; and your rights over it.Â
2. The personal data we collect
What you give us
|
Data |
When |
Examples |
|---|---|---|
|
Contact and identity |
Inquiry forms, Facebook/Instagram lead forms, WhatsApp, account registration |
Name, email, mobile/WhatsApp number, job title, employer, city |
|
Account |
Creating an account on the learning platform |
Username, password (stored encrypted), profile details you add |
|
Enrollment |
Enrolling in a Program |
Program of interest, professional background, employer billing details for corporate enrollments |
|
Payment |
Paying online |
Billing name and address, transaction reference, card type and last four digits. We do not receive or store your full card number, expiry date or CVV — these go directly to our payment provider |
|
Learning |
Using the platform |
Courses accessed, progress, assessment results, attendance, certificates issued |
|
Communications |
Emailing, messaging or calling us |
Message content, support tickets, call notes |
|
Session recordings |
Live online sessions |
Voice, image (if your camera is on) and chat messages, where a session is recorded and we told you in advance |
|
Feedback |
Surveys, reviews, testimonials |
Ratings, comments, and any testimonial you agree to let us publish |
Collected automatically. Cookies and similar technologies record your IP address and approximate location, device and browser, referring source, pages viewed, and actions such as form submissions or WhatsApp clicks. Section 6 covers the tools and how to control them.
From others. We may receive your details from Meta when you submit an instant lead form on one of our ads, from LinkedIn where you interact with our content, and from your employer where it enrolls you. We do not knowingly collect sensitive personal data as defined by the PDPL — please do not include it in messages to us unless we have asked.
3. Why we use your data, and our legal basis
|
Purpose |
Legal basis |
|---|---|
|
Creating and managing your account |
Performance of our contract with you |
|
Delivering Programs, tracking progress, issuing certificates |
Performance of the contract |
|
Taking payment, invoicing, keeping accounting records |
Performance of the contract; legal obligation |
|
Responding to inquiries and providing support |
Performance of the contract; your consent where you contacted us before enrolling |
|
Marketing our Programs to you by email, SMS or WhatsApp |
Your explicit consent, withdrawable at any time |
|
Showing you our ads on Facebook, Instagram and LinkedIn, including retargeting |
Your consent, given through our cookie banner |
|
Measuring how the Site and our campaigns perform |
Your consent (analytics cookies); our legitimate interest where no cookie is involved |
|
Publishing a testimonial or success story naming you |
Your separate, specific consent, asked for at the time |
|
Preventing fraud and misuse, enforcing our Terms |
Our legitimate interest in protecting our business and learners |
|
Meeting tax, accounting and other legal obligations |
Legal obligation |
Where we rely on consent you can withdraw it at any time (section 9). Withdrawal does not affect processing already carried out, or data we must keep for legal or contractual reasons.
4. Marketing communications
We send marketing by email, SMS, or WhatsApp only where you have given clear, affirmative consent through a box separate from your acceptance of our Terms. Every marketing email carries an unsubscribe link; you can stop WhatsApp or SMS marketing by replying “STOP” or emailing [academy@vcxo-group.com], and we act within [7] days.
Service messages tied to an active enrollment — joining links, schedule changes, receipts — are part of delivering the Program you paid for, are not marketing, and cannot be opted out of while your enrollment is active.
5. Who we share your data with
We do not sell your personal data. We share it with:
- Our learning platform provider — hosts your account, course materials and progress data.
- Payment providers — [Fawry / Paymob / card acquirer], to take payment and handle refunds and chargebacks.
- Hosting, email and CRM providers — to run the Site, send communications and manage inquiries.
- Advertising and analytics platforms — Meta, LinkedIn and Google, as described in section 6.
- WhatsApp Business — where you contact us, or consent to be contacted, on WhatsApp.
- Instructors and training partners — only the attendee details needed to deliver a session.
- Your employer, where it enrolled and paid for you: attendance and completion status, and assessment results only where this was disclosed to you at enrollment.
- Professional advisers, auditors and authorities — where required by law, court order or a lawful regulatory request.
6. Cookies, the Meta Pixel and other tracking
We use:
- Essential cookies — needed for the Site, your account, login and checkout to work. These cannot be switched off.
- Meta Pixel and Conversions API — measure which ads lead to inquiries and enrollments, and support retargeting. Data is shared with Meta Platforms, Inc.
- LinkedIn Insight Tag — measures our LinkedIn activity and supports audience building. Data is shared with LinkedIn Corporation.
- Analytics cookies — [Google Analytics / other], to understand how visitors use the Site.
Non-essential cookies are set only after you accept them in our cookie banner. You can change or withdraw that choice at any time through [Cookie Settings] in the footer, block cookies in your browser, or control ad personalization in your Facebook, Instagram, and LinkedIn settings.
7. Transfers of data outside Egypt
Some providers above — our learning platform, hosting, email, and advertising partners — store or process data outside Egypt, including in the United States and the European Union. Where we transfer personal data abroad, we do so in line with the PDPL: on the basis of your consent, with the approvals required from the Personal Data Protection Centre, and under contractual safeguards requiring protection at least equivalent to Egypt’s.
8. Your rights
Under the PDPL, you have the right to:
- be informed about the data we hold about you and how we use it;
- access your data and get a copy;
- correct data that is wrong, incomplete or out of date;
- erase your data where we no longer have a lawful reason to keep it;
- restrict or object to processing in certain circumstances;
- withdraw consent at any time where consent is our basis;
- object to direct electronic marketing at any time, free of charge; and
- complain to the Personal Data Protection Centre if you believe we handled your data unlawfully.
To exercise any of these, email from the address on your account or write to us at the address in section 1. We may ask you to verify your identity first, and we respond within the period the PDPL requires. There is no charge unless a request is clearly excessive or repetitive.
9. Security
We apply measures appropriate to the risk: encryption in transit, encrypted password storage, role-based access limiting who can see learner data, access logging, and contractual security obligations on our providers. No system is completely secure. If a breach occurs, we will notify the Personal Data Protection Centre within 72 hours of becoming aware of it and affected individuals within three working days of that notification, as the PDPL requires. Please use a strong, unique password and never share your login.
10. Children
The Site and our Programs are intended for adults aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has given us personal data, email us and we will delete it.
11. Changes to this policy
We may update this policy as our services, providers or legal obligations change. The current version is always on this page with its “Last updated” date. Where a change materially affects how we use your data, we will notify you by email and, where the law requires, ask for your consent again.
12. Contact us
[Virtual CHRO] — VCXO Academy · [ADDRESS] · Email: [academy@vcxo-group.com] · Phone / WhatsApp: [+201225390594]. If you are not satisfied with our response, you may complain to the Personal Data Protection Centre (PDPC), Ministry of Communications and Information Technology, Arab Republic of Egypt.