Privacy Policy

1) Data Controller

Vto AS is the data controller for the processing activities described in this policy.

Vto AS
Keizersgracht 520
1017 EK Amsterdam
Netherlands

Email: [email protected]

Phone: +31 20 808 1234

2) Personal Data We Collect

• Contact details: name, email address, telephone number.
• Enrollment and course preferences: selected course, preferred learning format, schedule interests.
• Communications: messages, support requests, and correspondence records.
• Learning records: participation notes, assignment submissions, completion status, certificates where applicable.
• Technical data: IP address, device and browser information, pages viewed, and general usage data collected via cookies or similar technologies (see the Cookie Policy).
• Payment-related information: we use secure payment service providers to process transactions. We do not store complete card numbers on our systems.
• Anti-spam signals: basic signals to protect forms from automated abuse.

3) Sources of Personal Data

• Directly from you when you fill forms, send email, or participate in courses.
• Automatically through cookies and similar technologies when you use our website.
• From service providers that support our platform (for example, hosting, email, analytics, or payment processors), in accordance with applicable contracts and law.

4) Purposes and Legal Bases

• Responding to enquiries and providing information about our programs (consent or legitimate interests).
• Creating and administering enrollments, delivering online courses, issuing completion confirmations (performance of a contract or steps prior to entering into a contract).
• Operating, maintaining, and improving our website and services (legitimate interests, with analytics subject to consent where required).
• Sending educational updates and optional newsletters (consent; you may withdraw at any time).
• Ensuring security, preventing fraud and abuse, and enforcing acceptable use (legitimate interests).
• Complying with legal and tax obligations applicable in the Netherlands (legal obligation).

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.

5) Cookies and Similar Technologies

We use cookies that are necessary for site functionality and security, as well as optional cookies for preferences and analytics. Where required, we request your consent before setting non-essential cookies. For details, please see our Cookie Policy.

6) Disclosures and Recipients

We do not sell personal data. We share data only as necessary with:

• Service providers acting on our instructions (for example, hosting, email delivery, analytics, payment processing, customer support).
• Professional advisers and auditors bound by confidentiality obligations.
• Authorities, regulators, or law enforcement when required by applicable law.

All recipients are bound by appropriate contractual and legal obligations to protect personal data.

7) International Transfers

Data may be processed in the Netherlands, the European Economic Area (EEA), and Canada. Where transfers occur to countries outside the EEA, we implement appropriate safeguards such as the European Commission’s Standard Contractual Clauses or rely on adequacy decisions where applicable. You may request a summary of relevant safeguards by contacting us.

8) Retention

• Enquiry records: up to 24 months after our last interaction.
• Enrollment and learning records: for the duration of the course and up to 6 years thereafter to meet legal and tax obligations in the Netherlands.
• Cookie data: as specified in our Cookie Policy.
• If legal claims arise, we may retain data as necessary to establish, exercise, or defend those claims.

9) Your Rights (EEA/GDPR)

If you are in the EEA, you have the following rights under the GDPR, subject to conditions and exemptions:

• Access your personal data and obtain a copy.
• Rectify inaccurate or incomplete data.
• Erase data in specific circumstances.
• Restrict processing in specific circumstances.
• Data portability, where technically feasible.
• Object to processing based on legitimate interests, including objection to direct marketing.
• Withdraw consent where processing is based on consent.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). We encourage you to contact us first so we can address your concerns.

10) How to Exercise Your Rights

To make a request, contact us at [email protected]. We may ask you to verify your identity before responding. We will respond without undue delay and within the timelines required by law.

11) Security

We apply technical and organizational measures designed to protect personal data, including encryption in transit (HTTPS), access controls, least-privilege practices, staff guidance, and regular review of our security posture. No online service can be entirely risk-free, but we work to reduce risks to a reasonable level.

12) Children’s Privacy

Our services are suitable for teenagers and adults. Where required by law, enrollment of minors must be completed by or with the verifiable consent of a parent or legal guardian. If you believe a child provided personal data without appropriate consent, please contact us so we can take appropriate action.

13) Automated Decision-Making

We do not use automated decision-making, including profiling, that produces legal or similarly significant effects concerning individuals.

14) Third-Party Websites

Our website may reference third-party resources. If you follow links to third-party websites, their privacy practices apply. We encourage you to review their privacy information before providing personal data.

15) Changes to This Policy

We may update this Privacy Policy to reflect changes to our practices, legal requirements, or services. The “Last updated” date will be revised accordingly. Material changes will be communicated through our website.

16) Contact

For privacy questions or requests, please contact:

Vto AS — Privacy
Keizersgracht 520, 1017 EK Amsterdam, Netherlands
Email: [email protected]
Phone: +31 20 808 1234