Privacy notice

Who is responsible for it

Symbiotic Design, Deflectiespoelstraat 6, 5651 HP Eindhoven, The Netherlands. Chamber of Commerce number 96731222.

Write through the contact page on this site and your message reaches the person who decides what happens with your data.

What the Academy keeps, and why

Your account: your name, your email address, your password in a form nobody can read back, and whatever else you choose to add, such as a photograph, a line about yourself, a country, a time zone or a link to your own site. This is kept so that the account can exist at all, which is what you asked for when you made it.

Your learning: which courses you are in, which lessons you have opened, your answers to quizzes, the work you hand in, the marks it is given and the certificates you earn. This is the service itself, and without it nothing could be shown back to you.

Your purchases: what you bought, what you paid, and for a printed book the name, address, postcode, country and telephone number the parcel travels under. The telephone number is there because the carrier may need to call about the delivery. The money side of this is also kept because Dutch tax law requires a business to keep its records.

When you write to us: your name, your email address and your message, kept so that we can answer and so that we can find the thread again if you write twice.

The newsletter: your name, your email address and the language you read in, kept only while you want it and on nothing but your own say so. Every letter carries a way out.

What happens in your account: a short line each time something is done, such as an enrolment, a payment or a certificate being issued, kept so that the Academy can answer you when something looks wrong and can see if an account is being misused.

How visitors find the Academy and move through it: the page someone arrived from, such as a social network, a search engine, an advert or the newsletter, the pages they then read and in what order, whether they use a phone or a computer, and the country the visit comes from. Visits from the same browser are linked to each other for up to ninety days by a random code, so the Academy can see that someone came back and what they read before deciding. Nobody is named by this.

When you join the newsletter or make an account: where you first came from, and where you came from most recently, are kept with it. From then on, while you are signed in, the pages you read are kept with your account. When you make an account, the pages read in the same browser in the ninety days before are joined to it.

When you buy: where you came from, first and most recently, is kept with the order, together with your answer to "How did you find us?" if you choose to give one.

Why: the Academy has a legitimate interest in knowing how people find its courses and what helps them, and it does this in the lightest way that answers the question. You can object at any time. The link "Do not count my visits" at the foot of every page stops it at once, and the site treats your browser's "do not track" and "Global Privacy Control" settings the same way.

What the Academy does not keep: your IP address and your browser's fingerprint. The country of a visit is read at the moment it happens and only the country is kept. All of this stays with the Academy. No analytics company, no advertising service and nothing that follows you anywhere else is part of this site.

Cookies, and what is kept in your browser

A few small things, all listed here. One of them helps the Academy see how people find their way around this site. None of them follows you anywhere else.

A sign-in cookie, which is what keeps you signed in for thirty days and which your browser will not let any page read. A second, readable one that says only that somebody is signed in, so the page knows to show the account menu. One that remembers whether you read in English or Spanish. And, inside the Academy's own administration, one that lives for sixty seconds when staff reset a password. When you create an account, or sign in before confirming it, one that lasts three days, so that opening the confirmation link signs you in only in the browser you used.

And one that lasts ninety days from your last visit and holds nothing but a random code, so that visits from the same browser can be linked as described above. If you choose "Do not count my visits", the code is removed and your browser keeps only that choice.

Your browser also keeps your answer about moving images, so the site does not ask twice and does not start the motion again when you have said no. And, once you have read it, the note about the voice that reads pages aloud on the Learning Experience page, so it is not shown again.

Because none of these follows you anywhere else, none is for advertising, and nothing they record leaves the Academy, the site does not put a banner in your way asking you to accept anything.

Who else sees it

Five companies do work the Academy cannot do by itself. They act on the Academy's instructions and for nothing else.

Vercel runs the site and holds the files. Supabase holds the database, on servers in Frankfurt. Stripe takes the payments, and your card details go straight to them and never touch this site. Lulu prints the books and gives the parcel to the carrier, so it receives the name, address and telephone number a parcel travels under. Resend sends the letters the Academy writes to you.

If a page carries a video, it plays from Vimeo, Loom or YouTube, so your browser speaks to that service when you play it, as it would on any site.

Nobody buys, rents or is given your details for their own purposes. There is nothing to sell here and it would not be sold.

When your data leaves Europe

The database sits in Frankfurt, inside the European Union. Some of the companies above are American, and where they hold data outside the European Union the transfer rests on the standard contractual clauses the European Commission wrote for exactly that, or on an adequacy decision where one applies. Their own published agreements say so, and the Academy holds them to it.

How long it is kept

Your account and your learning, for as long as you have an account. Ask for it to go and it goes.

An account whose email is never confirmed is removed after fourteen days, with everything given when it was made.

What you paid and what it was for, seven years. That is not the Academy's choice: Dutch tax law requires a business to keep the records of its trade for that long.

Your certificates stay, so that anyone you show one to can still check it is real. That is the whole point of a certificate, and it is why they outlive the account. If you would rather yours were removed as well, say so and it is removed.

The newsletter, until you leave it. Messages you send us, as long as it takes to settle the matter and a reasonable while after, in case it comes up again.

The random code that links visits: ninety days in your browser from your last visit. On the Academy's side, the pages of a visitor without an account stay linked by that code for ninety days after the last visit. After that the code is removed and only a record of pages read remains, with nobody behind it.

Where you came from is kept with your newsletter subscription, your account or your order, for as long as each of those is kept. The pages you read while signed in are kept for as long as you have an account, and go with it.

What you can ask for, at any time

A copy of everything the Academy holds about you. A correction of anything wrong. The removal of what does not have to be kept. A pause on the use of it while something is in dispute. Your own data handed to you in a form you can take elsewhere. An objection to a particular use of it. And, where you once said yes to something, the freedom to say no from now on, which costs you nothing and changes nothing else.

Write through the contact page. You will hear back within a month, and usually a great deal sooner.

Nothing here is decided about you by a machine on its own, and nothing you do is scored. What the Academy keeps of your reading is used to see which pages and courses work. It does not change what you are shown or what you are charged.

If you are not happy with the answer

Tell us first, because most things are a misunderstanding and can be put right the same day.

You also have the right to complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens, or to the equivalent authority in the country you live in. Doing so takes nothing away from anything else you may do.

Children

The Academy teaches professional practice and its courses are written for adults. It is not aimed at children and does not knowingly hold an account for one.

Changes to this notice

When it changes, the date at the foot of this page changes with it. If a change matters to you, for instance a new company doing work on the Academy's behalf, you will be told and not left to notice.