ACTING BY SARFRAZ
PRIVACY POLICY
This Privacy Policy describes how VR1 Inc., a corporation incorporated under the laws of the Province of Ontario, operating as “Acting by Sarfraz” (the “Company”), collects, uses, discloses, stores, and protects personal information of individuals (“Student” or “Users”) who access, enroll in, or use the Company’s services.
1. INFORMATION WE COLLECT
The Company may collect the following categories of personal information:
a. Personal Identification Information
Full name
Email address
Phone number
Date of birth (where required for age verification)
b. Payment & Transaction Information
Billing information
Payment confirmations
Transaction records
Payment processing may be handled through third-party payment service providers.
c. Course & Participation Data
Attendance records
Assignments, self-tapes, and submitted performances
Course progress and participation records
Student communications and support requests
d. Technical Information
IP address
Device and browser information
Website usage and analytics data
Access times and session activity
2. HOW WE USE PERSONAL INFORMATION
The Company may use personal information to:
Process enrollment and payments
Provide access to courses, sessions, and materials
Communicate regarding schedules, support, and administration
Improve course delivery, website functionality, and user experience
Maintain records and manage accounts
Comply with legal, regulatory, or contractual obligations
Send promotional or informational communications where permitted by law and, where consent is required, where consent has been obtained
3. PRIVACY LAW COMPLIANCE
The Company collects, uses, discloses, stores, safeguards, and retains personal information in accordance with applicable privacy laws, including applicable Canadian privacy laws.
The Company limits collection, use, disclosure, and retention of personal information to purposes reasonably necessary to provide services, comply with legal obligations, and support legitimate business operations.
4. MEDIA & CONTENT USAGE
Use of recordings, student performances, assignments, self-tapes, and submitted content is governed separately by the Media Release and Participation Agreement.
Nothing in this Privacy Policy limits or overrides rights granted under that agreement.
5. SHARING AND DISCLOSURE
The Company does not sell personal information.
The Company may disclose personal information to:
Payment processors
Technology and platform providers
Marketing, operational, or service partners
Legal or regulatory authorities where required by law
Such disclosures shall be limited to what is reasonably necessary to provide services or comply with legal obligations.
6. THIRD-PARTY SERVICE PROVIDERS
Where personal information is processed by third-party service providers, the Company uses contractual or other reasonable measures to require a comparable level of protection for such information.
However, the Company is not responsible for the independent privacy or security practices of third-party providers.
7. DATA STORAGE AND SECURITY
The Company implements reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, misuse, loss, disclosure, or alteration.
However, the Student acknowledges that:
No internet transmission or electronic storage system is completely secure;
The Company cannot guarantee absolute security.
8. DATA RETENTION
The Company retains personal information:
For as long as reasonably necessary to provide services;
For legitimate business purposes;
To comply with legal, regulatory, or contractual obligations.
The Company may retain anonymized or aggregated data indefinitely.
9. INTERNATIONAL DATA TRANSFERS
The Student acknowledges that personal information may be processed, stored, or transferred outside of Canada through third-party service providers.
By accessing or using the Company’s services, the Student consents to such transfers.
10. COOKIES AND TRACKING TECHNOLOGIES
The Company may use cookies, pixels, analytics tools, and similar technologies to:
Improve website functionality
Analyze usage and performance
Support marketing and advertising efforts
By using the website, the Student consents to such technologies.
11. THIRD-PARTY LINKS
The Company’s website or services may contain links to third-party websites or platforms.
The Company is not responsible for the privacy practices, policies, or content of such third parties.
12. STUDENT RIGHTS
Subject to applicable law, Students may request:
Access to personal information
Correction of inaccurate information
Deletion of personal information where applicable
Privacy requests may be submitted to the Company using the contact information below.
13. MINORS
If the Student is under eighteen (18) years of age:
Personal information may only be provided with parental or legal guardian consent;
The parent or guardian accepts responsibility for such information and its use.
14. LIMITATION OF LIABILITY
To the fullest extent permitted by applicable law, the Company disclaims liability for unauthorized access, security incidents, or third-party misuse of personal information beyond the Company’s reasonable control.
15. CHANGES TO THIS POLICY
The Company reserves the right to modify or update this Privacy Policy at any time.
Continued use of the Company’s services constitutes acceptance of any revised Privacy Policy.
16. PRIVACY CONTACT & COMPLIANCE
The Company is responsible for personal information under its control and maintains policies and procedures designed to support compliance with applicable privacy laws.
Privacy-related requests, questions, complaints, or concerns may be directed to:
Emails: [email protected] OR [email protected]
17. ELECTRONIC COMMUNICATIONS (CASL COMPLIANCE)
The Company may send Students electronic communications relating to:
Course administration, enrollment, scheduling, and service-related updates; and
Promotional, marketing, or newsletter communications, where permitted by applicable law.
Where required by applicable law, including Canada’s Anti-Spam Legislation (CASL), the Company will obtain consent before sending commercial electronic messages and will provide recipients with the ability to withdraw consent or unsubscribe.
Students may unsubscribe from promotional communications at any time by using the unsubscribe mechanism provided in such communications or by contacting the Company.
Withdrawal of consent to receive promotional communications does not affect the Company’s ability to send communications necessary to provide services, administer enrollment, enforce agreements, or comply with legal obligations.
18. CONSENT
By accessing, enrolling in, or using the Company’s services, the Student:
Acknowledges they have read and understood this Privacy Policy;
Consents to the collection, use, disclosure, and retention of personal information as described herein.
19. REQUIRED AGREEMENTS AND OPTIONAL CONSENTS
At enrollment, Students are required to affirm acceptance of the following:
Required:
Acceptance of this Privacy Policy
Acceptance of the Course Enrollment & Participation Agreement
Optional (Separate Consent):
Students may separately choose whether to consent to:
Acceptance of the Media Release and Participation Agreement; and/or
Receive newsletters, promotions, or other marketing communications from the Company.
Consent to the Media Release and Participation Agreement and consent to receive marketing communications are separate and optional, may be withdrawn in accordance with their applicable terms or applicable law, and declining such consent does not affect enrollment or access to services, except that the Company may be limited in its ability to use recordings, submitted content, testimonials, or promotional materials where media consent has not been granted.
Where required by applicable law, including Canada’s Anti-Spam Legislation (CASL), promotional or commercial electronic messages will be sent only where the required consent has been obtained or another lawful basis applies.