Privacy Policy

2. Personal Data We Collect

We collect only the data needed to operate an educational course website, respond to enquiries, and keep the site secure. Depending on how you use the site, we may collect the following categories of personal data:

• Identity and contact data: your name and email address when you submit a registration or contact form.
• Form content: the information you type into a form (for example, questions about schedule, course format, or materials).
• Technical data: IP address, browser type, device information, operating system, language settings, and approximate location inferred from IP.
• Usage data: pages visited, time spent on pages, referral source, and click paths (only if analytics cookies are enabled via consent).
• Cookies and identifiers: browser cookies that store your cookie preferences and session continuity (details in Section 4).
• Conversion events: events such as successful form submissions and page interactions, where enabled by your cookie choices.

We do not intentionally collect special-category data (such as health information, religious beliefs, political opinions), financial account details, or government-issued identification numbers through our standard website forms.

3. Why We Process Personal Data & Legal Basis (GDPR Art. 6)

We process personal data for specific purposes and rely on the following legal bases under the GDPR and UK GDPR where applicable:

• Responding to registration and course enquiries: to reply to messages, confirm interest, and provide scheduling options. Legal basis: Art. 6(1)(b) (steps prior to entering into a contract) and Art. 6(1)(a) (consent) where required by the form.
• Website analytics (optional): to understand which pages are useful and improve content quality. Legal basis: Art. 6(1)(a) (consent).
• Marketing and remarketing (optional): to measure advertising performance and show relevant ads to interested audiences. Legal basis: Art. 6(1)(a) (consent).
• Security and fraud prevention: to protect the website, prevent abuse, and maintain availability. Legal basis: Art. 6(1)(f) (legitimate interests).
• Legal obligations: to comply with applicable laws, respond to lawful requests, and maintain records where required. Legal basis: Art. 6(1)(c) (legal obligation).

Automated decision-making (Art. 22): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.

4. Cookies & Tracking

Cookies are small text files stored on your device. Some cookies are essential for basic site functions (such as remembering consent). Others are optional and only used if you agree. In addition to cookies, some advertising and analytics tools may use pixel tags or server-side event delivery to measure conversions and improve campaign reporting.

Essential cookies (always active)

These cookies are required for the site to function and cannot be switched off in our preference panel. They include:

• _site_session for session continuity and basic stability.
• cookie_consent to store your cookie choices.

Retention typically ranges from the current browser session to up to 12 months, depending on the specific cookie.

Analytics cookies (consent required)

If you enable analytics cookies, we may use Google Analytics 4 to understand how visitors use the site. IP anonymization is enabled where supported. Analytics cookies help us measure which lessons, programme pages, and registration steps are most useful so we can improve the learning experience.

• Examples: _ga, _ga_XXXXXXXXXX.
• Data retention: 14 months for analytics data in typical reporting configurations.

Marketing cookies (consent required)

If you enable marketing cookies, we may use cookies from advertising partners to measure ad performance and to show more relevant educational offers. These cookies may be used for remarketing, custom audiences, lookalike audiences, and conversion attribution.

• Examples: _gcl_au (Google Ads), _fbp and _fbc (Meta).
• Typical retention: around 90 days depending on the cookie.

For more details about cookie categories and examples, read our Cookie Policy.

5. Consent (EEA/UK)

Users in the EEA and UK receive a consent notice under GDPR/UK GDPR. Analytics and marketing cookies activate only after explicit, informed, freely given consent (Art. 6(1)(a)). Your consent choice is recorded in the cookie_consent browser cookie for up to 12 months.

You can withdraw consent at any time by using “Manage cookie preferences” in the footer or by clearing cookies in your browser. Withdrawal does not affect the lawfulness of processing based on consent before it was withdrawn.

6. Sharing With Advertising & Service Partners

We use a small set of service providers to deliver and secure the website and, where you consent, to support analytics and advertising measurement. Depending on your cookie choices, we may share limited data such as cookie identifiers, usage data, and conversion events with:

• Google LLC (Google Analytics 4, Google Ads, Tag Manager, remarketing): policies.google.com/privacy
• Meta Platforms (Meta Pixel, Custom/Lookalike Audiences, Conversion API): facebook.com/privacy/policy
• Cloudflare (CDN and security): cloudflare.com/privacypolicy

We do not sell personal data. Where advertising and analytics providers are used, they act as service providers or processors for the purposes described above. We do not permit them to use site data for their own independent commercial purposes.

7. International Transfers

Some of our partners may process data outside the EEA/UK, including in the United States. When transfers occur, they are supported by appropriate safeguards such as:

• EU-US Data Privacy Framework (DPF) (primary safeguard where applicable, since July 2023)
• UK Extension to the DPF
• Swiss-US DPF where applicable
• Standard Contractual Clauses (EU 2021/914) as a fallback
• UK IDTA as a fallback

We also take practical steps to minimize the amount of personal data shared and to limit processing to what is necessary for course operations and measurement.

8. Retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Typical retention periods include:

• Contact and registration submissions: up to 2 years from the last interaction.
• Analytics data: 14 months (where enabled by consent).
• Marketing cookies: per cookie lifetime (often 90 days) when enabled by consent.
• Email correspondence: duration of the relationship plus 1 year for administrative follow-up.
• Server security logs: typically 90 days, unless needed for investigation.
• Cookie consent record: up to 3 years for audit purposes.
• Legal/tax: where applicable, typically 6–10 years for invoices and related records.

9. Your Rights (GDPR & UK GDPR)

If GDPR or UK GDPR applies to you, you may have the right to:

• Access your personal data (Art. 15)
• Rectify inaccurate personal data (Art. 16)
• Request deletion (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)
• Withdraw consent at any time (Art. 7(3))
• Lodge a complaint with a supervisory authority (Art. 77)

To exercise your rights, email [email protected]. We respond within 30 days, although this can be extended by up to 60 days for complex requests.

If you want to find your relevant supervisory authority, these resources may help:

• EU: edpb.europa.eu
• UK: ico.org.uk
• Germany: bfdi.bund.de
• France: cnil.fr
• Poland: uodo.gov.pl
• Spain: aepd.es

10. Children

This site is not directed at individuals under 16. We do not knowingly collect personal data from minors. If we learn that personal data from a child under 16 has been collected without verifiable parental consent, we will delete it promptly.

11. Do Not Track

This website does not respond to Do Not Track (DNT) browser signals. Third-party providers may have their own DNT handling and opt-out mechanisms.

12. Account & Data Deletion Requests

We do not provide user accounts on this website. If you want your personal data deleted, email us with the subject line “Data Deletion Request”. We may ask for limited information to verify identity and locate the relevant records (for example, the email address used to register). Requests are typically completed within 30 days, subject to legal retention requirements.

13. Business Transfers

In the event of a merger, acquisition, asset sale, financing, or insolvency, personal data may be transferred to a successor entity. If such a transfer materially changes how your personal data is used, we will provide notice via the website.

14. California (CCPA / CPRA)

If you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA) as amended by the CPRA. Over the past 12 months, the categories of personal information we may have collected include:

• Identifiers: name, email address, IP address, device identifiers (shared with service providers and, when enabled by consent, ad partners).
• Internet or network activity: interactions with pages and links (used for analytics and advertising measurement when enabled).
• Inferences: interests or preferences inferred from site activity (used for advertising audiences when enabled).

We do not sell personal information as defined by the CCPA. We do share information for cross-context behavioral advertising when marketing cookies are enabled. California residents may opt out via our cookie preferences panel.

To submit a request to know, delete, or correct, email [email protected] with the subject line “California Privacy Request”. We will verify your identity before completing a request. Authorized agents may submit requests with written proof of authorization.

15. Virginia (VCDPA)

Virginia residents may have rights to access, correct, delete, and obtain a copy of their personal data, and to opt out of targeted advertising. To submit a request, email [email protected] with the subject line “Virginia Privacy Request”.

We do not sell personal data or engage in profiling that produces legal or similarly significant effects. If we decline to act on a request, you may appeal by emailing us with the subject “Appeal of Refusal — Privacy Request”. We respond to appeals within 60 days. If an appeal is denied, you may contact the Virginia Attorney General.

16. Nevada

Nevada residents may submit a verified opt-out request by emailing [email protected] with the subject “Nevada Do Not Sell Request”. We do not currently sell personal information under Nevada Revised Statutes Chapter 603A.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the course offering, website features, or legal requirements. Material changes will be announced via a site notice at least 14 days before they take effect. The “Last Updated” date at the top of this page will be revised whenever changes are made.

18. Contact

For privacy questions or requests, contact:

• relatrakvo Education LLC
• Address: Draguš 93, 439 42 Postoloprty, Czechia
• Email: [email protected]