Privacy,
without surprises.

1. Data controller

2. What data do we use?

• Account details, such as your name, email address, language, account status and creation date.
• Purchase and access details, such as the selected product, payment status, validity period and Stripe customer number.
• Learning activity, such as parts viewed, started, completed or deliberately skipped, and your latest activity.
• Practice history, such as the number of repetitions, context and date of the latest session.
• Reflection answers that you choose to save in your personal learning environment.
• Support requests and administrative changes.
• A one-time acknowledgement of the safety notice and its timestamp, linked to your account. No health information is requested for this acknowledgement.

3. What do we use this data for?

To fulfil your agreement, secure your account, show your personal content progress, provide customer service and billing, and meet statutory record-keeping obligations.

4. Who do we share data with?

We use specialist providers for hosting, account management and payment. They process data only for their agreed task. These include Cloudflare/Sites for the application, Supabase for accounts and personal progress, and Stripe for payment and billing. We do not sell your data.

5. Retention periods

We retain account and learning data while your account is active, and afterwards only for as long as needed for recovery, disputes or legal obligations. Financial data follows the tax retention period.

6. Security

Personal areas are protected. Progress, sessions and Reflection are linked to one user ID and protected by access rules, so participants can access only their own personal data.

7. Your rights

You can request access, correction, deletion, restriction or transfer, or raise an objection, to the extent that the law provides that right. Submit a request through Support. You can also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

8. Changes

If there is a material change, we display a new version date and inform existing members when reasonably necessary.

Product insights

We use completion statuses, access validity and active weeks to understand how Academy is used. Admins see aggregated counts, not Reflection answers or health interpretations. From Insights V1, a first-party browser identifier records the first public landing page, referrer domain and the four campaign codes utm_source, utm_medium, utm_campaign and utm_content. Getting Started records video starts and ends. When you sign in in the same browser, that first visit can be linked to your existing account ID. We retain this visit data and cookie for up to 90 days. Campaign links must not contain names or email addresses.

Website Insights also counts public pageviews and groups activity into visits ending after 30 minutes without a recorded event, using that same cookie. We retain only the first three distinct consecutive pages, the last page, source/campaign and Getting Started/account-page indicators for each visit, plus aggregated page and transition counts, for up to 90 days. From 18 October 2026 we also keep one record per visit, fixed button category, page category and placement (for example menu or top of page). For live checkout starts, we retain the checkout reference and product reference for up to 90 days and read payment status from our existing orders. Where possible, a checkout is linked to the last public visit in the same browser within 30 days. Missing links remain unattributed. No full clickstream, recordings, IP identifiers or fingerprinting. Signed-in owner/admin activity and recognised bots are excluded. Anonymous visits are not unique people. Random, unlinked event receipts are retained for 24 hours to prevent retry duplicates.

Server performance is stored for up to 90 days as route categories, time bands, duration bands and error counts, without user IDs, IP addresses, tokens or page content. These measurements use our existing infrastructure, do not send data to external analytics or advertising services, and do not imply marketing consent. Your rights described above also apply to these records.

TRPS Loyalty

For automatic member benefits we process eligibility, points entries, milestones, active weeks, completion references, claims and reasoned admin corrections. We do not read Reflection answers for Loyalty. These records remain linked to your account to preserve earned benefits after ordinary cancellation and to check the twelve-month claim limit. They are retained while needed for these purposes, resolving disputes or legal obligations; account and deletion rights remain available through Support. Loyalty does not imply marketing consent.