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Privacy Policy

Last Updated: March 12, 2026

1. Introduction & Controller Identity

This Privacy Policy explains how Elyvorax School (“we”, “us”, “our”) collects, uses, and protects your personal data when you visit this website (the “Site”) and when you contact us about our online courses, live webinars, and educational programs.

The data controller responsible for processing your personal data is:

We have not appointed a Data Protection Officer (DPO). If you have questions about this policy or your rights, contact us using the details in Section 18.

Effective Date: March 12, 2026.

2. Personal Data We Collect

We collect personal data that you provide directly and data that is collected automatically when you use the Site. The exact data depends on how you interact with the Site (for example, reading pages vs. sending a course inquiry).

  • Identity and contact data: name, email address, phone number (if provided), and any contact details included in a message.
  • Form submission content: the text you enter in our forms, such as learning interests (languages, AI, programming, digital skills), preferred format (course, webinar, intensive, masterclass), availability windows, and other details you choose to share.
  • Technical data: IP address, browser type and version, device type, operating system, language settings, and approximate location inferred from IP (city/region level).
  • Usage data: pages viewed, time on page, referrer URL, click paths, scroll events, and basic interaction events.
  • Cookies and identifiers: cookie values and similar identifiers as described in Section 4 (for example, a session cookie and your cookie consent choice).
  • Conversion events: events related to contacting us (for example, a successful form submission) that may be used for measurement when you have consented to analytics or marketing cookies.

We do not intentionally collect special-category data (such as health information, biometric data, religious beliefs, political opinions), financial account information, or government identification numbers through this Site. Please do not include sensitive personal data in free-text fields.

3. Why We Process Your Data & Legal Basis (GDPR Article 6)

We process personal data only when we have a lawful basis under GDPR (and UK GDPR where applicable). The main purposes and legal bases are:

  • Responding to inquiries and enrollment requests: to reply to your message, provide schedules, share program details, and coordinate next steps. Legal basis: Article 6(1)(b) (contract steps) and Article 6(1)(a) (consent) where your submission includes consent to be contacted.
  • Analytics and site improvement: to understand how the Site is used and to improve content and navigation. Legal basis: Article 6(1)(a) (consent) for analytics cookies.
  • Marketing and measurement: to measure advertising performance and, where enabled, build remarketing or lookalike audiences. Legal basis: Article 6(1)(a) (consent) for marketing cookies.
  • Security and fraud prevention: to protect the Site and users, detect automated abuse, and prevent malicious activity. Legal basis: Article 6(1)(f) (legitimate interests). Our legitimate interest is keeping the Site secure and reliable.
  • Legal compliance: to comply with legal obligations, respond to lawful requests, and keep records required by law. Legal basis: Article 6(1)(c) (legal obligation).

Automated Decision-Making (GDPR Article 22): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on you.

4. Cookies & Tracking

Cookies are small text files stored on your device. We also use similar technologies, such as pixel tags, and may use server-side measurement depending on your consent choices. Cookies and tracking are grouped into three categories that match our Cookie Policy.

4.1 Essential (Always Active)

Essential cookies are required for core site functionality and security. These cookies do not require consent in most jurisdictions because the Site cannot work properly without them.

  • Examples: _site_session (session continuity), cookie_consent (stores your cookie preference).
  • Typical retention: session to 12 months (depending on the cookie).

4.2 Analytics (Consent Required)

When you consent to analytics cookies, we may use Google Analytics 4 (GA4) with IP anonymization to understand aggregate usage patterns (for example, which pages are visited most often and how users navigate through the Site).

  • Examples: _ga (2 years), _ga_XXXXXXXXXX (2 years; GA4 identifier).
  • Data retention: 14 months for analytics data (typical configuration).

4.3 Marketing (Consent Required)

When you consent to marketing cookies, we may enable advertising measurement and remarketing technologies. This helps us understand which ads lead to visits and inquiries, and it can be used to build audiences for relevant ad delivery.

  • Examples: _gcl_au (Google Ads, 90 days), _fbp (Meta Pixel, 90 days), _fbc (90 days when a click ID is present).
  • Use cases: remarketing, custom audiences, lookalike audiences, and conversion attribution.

Beyond cookies, some measurement may be performed via pixel tags and, in some setups, server-side measurement using hashed identifiers (for example, hashing an email address for matching). Where applicable, such processing is activated only after your consent.

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 (Article 6(1)(a)). Your consent choice is recorded in the cookie_consent browser cookie (typically 12 months).

You may 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 carried out before the withdrawal.

6. Sharing With Advertising & Service Partners

We share personal data only as needed to operate the Site and deliver our educational services. Depending on your consent choices and how you use the Site, we may share limited data with:

  • Google LLC (Google Analytics 4, Google Ads, tag management, remarketing): cookie identifiers, usage data, and conversion events.
  • Meta Platforms (Pixel, custom audiences, conversion measurement): page view and conversion signals, audience membership signals, and hashed identifiers where configured.
  • Cloudflare (CDN and security): IP-based threat detection, performance, and security logs.

We do not sell personal data. These providers act as processors or separate controllers depending on the service and configuration. We do not permit them to use site data for their own independent commercial purposes beyond what is necessary to provide the contracted services.

7. International Transfers

Some service providers may process data outside the EEA/UK (including in the United States). Where international transfers occur, we rely on appropriate safeguards, which may include:

  • EU–US Data Privacy Framework (primary basis where applicable, since July 2023).
  • UK Extension to the EU–US Data Privacy Framework and Swiss–US Data Privacy Framework where relevant.
  • Standard Contractual Clauses (EU 2021/914) as a fallback safeguard.
  • UK International Data Transfer Addendum (IDTA) as a fallback safeguard.

8. Retention

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

  • Contact submissions: up to 2 years from the last interaction.
  • Analytics data: 14 months (typical configuration).
  • Marketing cookies: per cookie lifetime (often 90 days for key identifiers).
  • Email correspondence: for the duration of our relationship, plus up to 1 year.
  • Server/security logs: typically up to 90 days.
  • Cookie consent record: up to 3 years for audit and compliance.
  • Legal and tax records: as required by law (often 6–10 years for invoices and accounting records).

9. Your Rights (GDPR & UK GDPR)

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

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

To exercise your rights, email [email protected]. We aim to respond within 30 days. This may be extended by up to 60 days for complex requests. We may request additional information to verify your identity before responding.

Supervisory authorities include (non-exhaustive):

10. Children

This Site is not directed at individuals under 16. We do not knowingly collect personal data from minors. If we learn that we have collected data from a child under 16 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 approaches to DNT.

12. Data Deletion Requests

To request deletion of personal data, email [email protected] with the subject line “Data Deletion Request”. We aim to complete deletion within 30 days after verifying your identity. Some information may be retained where required by law or where it is necessary for establishing, exercising, or defending legal claims.

13. Business Transfers

If we are involved in a merger, acquisition, restructuring, asset sale, financing, or insolvency, personal data may be transferred to a successor or affiliate as part of that transaction. If the transfer materially changes how personal data is used, we will provide notice on the Site.

14. California (CCPA/CPRA)

This section applies if you are a California resident and the CCPA/CPRA applies. In the past 12 months, we may have collected the following categories of personal information:

  • Identifiers: name, email, IP address, cookie/device identifiers. Shared with service providers and advertising partners where enabled by consent.
  • Internet/network activity: interactions with the Site. Shared with analytics and advertising providers where enabled by consent.
  • Inferences: preferences and interests derived from usage to improve content and advertising relevance where enabled by consent.

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

Rights may include: the right to know, delete, correct, opt out of sale/sharing, and non-discrimination. To submit a request, email [email protected] with the subject line “California Privacy Request”. We may need to verify your identity. Authorized agents may submit requests with written permission.

15. Virginia (VCDPA)

If you are a Virginia resident and the VCDPA applies, you may have rights to access, correct, delete, obtain a copy of, and opt out of certain processing (including targeted advertising). We do not sell personal data and we do not engage in profiling that produces legal or similarly significant effects.

To submit a request, email [email protected] with the subject line “Virginia Privacy Request”. If we decline a request, you may appeal by emailing “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 line “Nevada Do Not Sell Request”. We do not currently sell personal information under Nevada Revised Statutes Chapter 603A.

17. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide a notice on the Site at least 14 days before the changes take effect. The “Last Updated” date at the top of this page reflects the most recent revision.

18. Contact

For privacy questions, requests, or complaints, contact:

Cookie choices

You can review or change your cookie preferences at any time by using “Manage cookie preferences” in the footer. Essential cookies are always active; analytics and marketing cookies require consent.