Privacy policy


1. Introduction

This Privacy Policy explains how FCMO Academy B.V. (“FCMO Academy”, “the Company”, “we”, “our”, or “us”) collects, uses, and protects personal data obtained through our website www.fcmo.nl, the Thinkific learning platform, and related digital services.

We are committed to safeguarding your privacy and ensuring transparency about how your personal information is processed in compliance with the General Data Protection Regulation (GDPR).


2. Data Controller

FCMO Academy B.V.
Box E0314, Keurenplein 41, 1069 CD Amsterdam, The Netherlands
Chamber of Commerce (KvK): 98234161
Email: [email protected]


3. Personal Data We Collect

We may collect and process the following categories of personal data depending on your interaction with us:

  • Identity Data: first name, last name, company (if provided).
  • Contact Data: email address, phone number, address, country of residence.
  • Account Data: login credentials, Thinkific user ID, enrollment data, and course progress.
  • Payment Data: transaction details processed securely via Thinkific or its integrated payment processors (we do not store full credit card details).
  • Communication Data: messages or emails exchanged with our team.
  • Marketing Data: preferences for receiving newsletters, updates, and promotional materials.
  • Technical and Usage Data: IP address, device type, browser type, pages visited, and course engagement data (collected via cookies and analytics).

We do not collect special categories of data such as health information, religion, or political opinions.


4. How We Collect Data

We collect data through:

  • Direct interactions (e.g., registration forms, contact forms, or coaching bookings).
  • Automated technologies such as cookies or tracking scripts via Thinkific and Google Analytics 4.
  • Our email marketing and CRM system MailBlue (ActiveCampaign), used for communication, onboarding, and newsletters.
  • Third-party integrations related to payment, analytics, and customer support.


5. Legal Basis for Processing

We process your personal data only when we have a lawful basis under the GDPR. The legal grounds depend on the purpose of processing:

Purpose

Legal Basis

To deliver Courses and Services

Contractual necessity

To communicate with you about purchases or support requests

Contractual necessity / legitimate interest

To send marketing communications (e.g., newsletters)

Consent

To analyze website and course performance

Legitimate interest

To comply with legal or tax obligations

Legal obligation

You may withdraw your consent for marketing at any time by clicking “unsubscribe” in our emails or contacting us directly.


6. How We Use Your Data

We use collected personal data to:

  • Provide access to purchased Courses and Services.
  • Manage your Thinkific account and progress.
  • Deliver personalized learning experiences and support.
  • Send transactional emails (e.g., enrollment confirmations, invoices, updates).
  • Improve our Courses, platform, and user experience.
  • Send relevant marketing communications (if you have opted in).
  • Comply with financial and legal obligations.

7. Data Retention

We retain your data only for as long as necessary to fulfill the purposes described above:

Data Type

Retention Period

Course & account data

As long as your account remains active or until you request deletion

Financial & transaction records

7 years (legal obligation under Dutch tax law)

Marketing & newsletter data

Until you unsubscribe or withdraw consent

Technical & analytics data

Up to 14 months (as configured in Google Analytics)

After these periods, data is securely deleted or anonymized.


8. Sharing and Disclosure of Data

We do not sell or rent personal data.
However, we may share your data with trusted service providers (“processors”) that assist us in delivering our services, including:

  • Thinkific Labs Inc. (Canada) – online learning platform provider
  • MailBlue / ActiveCampaign (Netherlands & USA) – marketing automation and email communication
  • Google Analytics (Google Ireland Ltd.) – website and platform analytics
  • Cloud86 B.V. (Netherlands) – website hosting provider
  • Payment providers (Stripe, PayPal, or Thinkific Payments) – secure payment processing
  • IT and support providers – for maintenance and troubleshooting

Where data is transferred outside the European Economic Area (EEA), we ensure adequate protection under the EU Standard Contractual Clauses (SCCs) or equivalent safeguards.


9. Cookies and Tracking Technologies

Our website and platform use cookies and similar technologies to:

  • Remember user preferences and login sessions.
  • Analyze site and course usage (via Google Analytics).
  • Personalize marketing content and improve performance.

You can manage or disable cookies in your browser settings.
More detailed information is available in our Cookie Policy on www.fcmo.nl/cookie-policy


10. Data Security

We implement appropriate technical and organizational measures to protect personal data from unauthorized access, alteration, disclosure, or destruction.
These include encryption (SSL/TLS), secure backups, access control, and staff confidentiality agreements.

However, no system is completely secure, and we cannot guarantee absolute security of your data transmitted over the internet.


11. Your Rights (GDPR)

You have the following rights regarding your personal data:

  • Right of access – obtain a copy of your personal data.
  • Right to rectification – correct inaccurate or incomplete data.
  • Right to erasure (“right to be forgotten”) – request deletion of your data.
  • Right to restriction – limit how we process your data.
  • Right to data portability – receive a structured copy of your data.
  • Right to object – object to processing based on legitimate interests.
  • Right to withdraw consent – for marketing or other consent-based processing.

To exercise these rights, contact us at [email protected].
You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
www.autoriteitpersoonsgegevens.nl


12. International Data Transfers

As part of using global services (such as Thinkific, MailBlue/ActiveCampaign, and Google), your data may be processed or stored outside the European Union.
In all such cases, we ensure that data transfers comply with GDPR requirements, using Standard Contractual Clauses or equivalent legal mechanisms.

13. Updates to This Policy

We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes.
The latest version will always be available on our website and includes the effective date at the top of this document.


14. Contact

For questions, concerns, or requests regarding this Privacy Policy or your data, please contact:

FCMO Academy B.V.
Box E0314, Keurenplein 41, 1069 CD Amsterdam, The Netherlands
Email: [email protected]
Website: www.fcmo.nl