Privacy Policy

1. Information We Collect

Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

• Register for an account or enroll in courses
• Contact us through forms, email, or phone
• Subscribe to our newsletters or marketing communications
• Participate in surveys, feedback forms, or promotional activities
• Apply for employment or partnership opportunities

This information may include:

• Name, email address, phone number
• Postal address and billing information
• Educational background and professional experience
• Course preferences and learning objectives
• Payment information (processed securely by third-party providers)
• Communication records and support interactions

Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and usage patterns, including:

• IP address and geographic location
• Browser type, version, and operating system
• Pages visited, time spent, and navigation patterns
• Referring website and search terms used
• Device information and screen resolution

2. How We Use Your Information

We process your personal information for the following purposes based on legitimate legal grounds:

Service Provision (Contract Performance)

• Providing access to courses and learning materials
• Processing payments and managing your account
• Delivering customer support and technical assistance
• Issuing certificates and tracking learning progress

Communication (Legitimate Interest)

• Responding to inquiries and providing information
• Sending course updates and important notifications
• Providing educational content and learning resources

Marketing (Consent)

• Sending promotional emails about new courses and offers
• Personalising marketing content based on interests
• Conducting market research and surveys

Legal Compliance

• Maintaining records as required by law
• Preventing fraud and ensuring platform security
• Complying with tax and financial regulations

3. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Consent: For marketing communications and non-essential cookies
• Contract Performance: To provide our educational services
• Legitimate Interest: For website analytics, security, and business operations
• Legal Obligation: For compliance with applicable laws and regulations

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:

Service Providers

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

• Payment processors for secure transaction handling
• Email service providers for communication delivery
• Cloud hosting providers for data storage and website operation
• Analytics providers for website performance monitoring
• Customer support platforms for service delivery

Legal Requirements

We may disclose your information when required by law, court order, or governmental authority, or to protect our rights, property, or safety, or that of others.

Business Transfers

In the event of a merger, acquisition, or sale of assets, personal information may be transferred as part of the transaction, subject to appropriate confidentiality protections.

5. Data Security

We implement comprehensive security measures to protect your personal information:

• SSL encryption for data transmission
• Secure servers with regular security updates
• Access controls and authentication requirements
• Regular security audits and vulnerability assessments
• Employee training on data protection practices
• Incident response procedures for security breaches

6. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this policy:

• Account Information: Retained while your account is active and for 7 years after closure for legal compliance
• Course Records: Maintained for 10 years to support certification verification
• Communication Records: Kept for 3 years for customer service purposes
• Marketing Data: Retained until consent is withdrawn or for 2 years of inactivity
• Website Analytics: Aggregated data retained for 26 months

7. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access

You can request a copy of the personal information we hold about you, including details about how it's processed.

Right to Rectification

You can request correction of inaccurate or incomplete personal information.

Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal information in certain circumstances, such as when it's no longer necessary for the original purpose.

Right to Restrict Processing

You can request that we limit the processing of your personal information in specific situations.

Right to Data Portability

You can request a copy of your personal information in a structured, machine-readable format for transfer to another service provider.

Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of previous processing.

8. International Data Transfers

Our primary data processing occurs within the European Union. When we transfer personal information outside the EU, we ensure appropriate safeguards are in place:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses (SCCs) approved by the EU
• Binding Corporate Rules for multinational service providers
• Certification schemes and codes of conduct

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience. For detailed information about our cookie practices, please see our Cookie Policy.

You can manage your cookie preferences through our consent banner or by adjusting your browser settings. Please note that disabling certain cookies may affect website functionality.

10. Children's Privacy

Our services are intended for individuals aged 16 and above. We do not knowingly collect personal information from children under 16 without appropriate parental consent. If you believe we have collected information from a child under 16, please contact us immediately at privacy@orphanbwun.top.

11. Changes to This Privacy Policy

We may update this privacy policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes by:

• Posting the updated policy on our website with a new effective date
• Sending email notifications for material changes
• Displaying prominent notices on our platform

12. Complaints and Supervisory Authority

If you have concerns about our data processing practices, please contact us first at privacy@orphanbwun.top. We are committed to resolving any issues promptly and fairly.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority if you believe we have not addressed your concerns adequately.

13. Contact Information

If you have any questions, concerns, or requests regarding this privacy policy or our data processing practices, please contact us: