Privacy Policy

1. Introduction

spacklirin B.V. ("we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website spacklirin.top, use our services, or interact with us in any other way.

This policy applies to all personal data processing activities carried out by spacklirin B.V. in compliance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including:

• Contact information (name, email address, phone number, company details)
• Training enquiry details and preferences
• Communication preferences and feedback
• Payment and billing information for our services
• Training participation records and progress data

2.2 Information Collected Automatically

When you visit our website, we may automatically collect:

• IP address and device information
• Browser type and version
• Pages visited and time spent on our website
• Referral sources and website navigation patterns
• Cookies and similar tracking technologies (see our Cookie Policy)

3. How We Use Your Information

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

3.1 Service Delivery (Contractual Necessity)

• Providing training services and programmes
• Processing payments and managing billing
• Communicating about your training progress and schedules
• Issuing certificates and training documentation

3.2 Legitimate Business Interests

• Responding to enquiries and providing customer support
• Improving our website and services
• Conducting business analysis and research
• Protecting our business interests and preventing fraud

3.3 Consent-Based Processing

• Sending marketing communications (where consented)
• Using cookies for analytics and website optimisation
• Sharing testimonials or case studies (with explicit permission)

4. Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties except in the following circumstances:

4.1 Service Providers

We may share your information with trusted third-party service providers who assist us in:

• Website hosting and maintenance
• Payment processing
• Email communication services
• Analytics and website optimisation
• Training delivery platforms (for virtual sessions)

4.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal obligations
• Protect our rights and property
• Prevent fraud or security threats
• Protect the safety of our users and the public

5. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and staff training
• Secure data centres and hosting environments
• Regular backups and disaster recovery procedures

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to maintaining industry-standard protection measures.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy or as required by law:

• Training records: 7 years after completion (for certification purposes)
• Customer communications: 3 years after last contact
• Marketing data: Until consent is withdrawn or 2 years of inactivity
• Website analytics: 26 months maximum
• Financial records: 7 years (legal requirement)

When the retention period expires, we securely delete or anonymise your personal data unless longer retention is required by law.

7. Your Rights Under GDPR

As a data subject, you have the following rights regarding your personal data:

To exercise any of these rights, please contact us at privacy@spacklirin.top. We will respond to your request within one month.

8. International Data Transfers

As a Netherlands-based company, we primarily process data within the European Economic Area (EEA). When we transfer personal data outside the EEA, we ensure adequate protection through:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules where applicable
• Explicit consent for specific transfers

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and analyse website performance. For detailed information about our use of cookies, please refer to our Cookie Policy.

You can manage your cookie preferences through our cookie consent banner or your browser settings.

10. Children's Privacy

Our services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to remove that information from our servers.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by:

• Posting the updated policy on our website
• Updating the "Last updated" date at the top of this policy
• Sending email notifications for significant changes (where we have your consent)

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we have not handled your personal data in accordance with applicable law.