Privacy Policy

Data Controller

Comfort Service B.V. is the data controller responsible for your personal information. If you have any questions about this Privacy Policy or our data practices, you can contact us at:

Personal Information We Collect

We collect various types of personal information depending on how you interact with our services:

Information You Provide Directly

• Contact Information: Full name, email address, phone number, postal address
• Enrollment Information: Course selections, educational background, professional interests
• Communication Data: Messages, inquiries, feedback, and comments you send to us
• Payment Information: Billing address and payment details (processed securely through third-party payment processors)
• Account Information: Username, password, and preferences if you create an account

Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device information
• Usage Data: Pages visited, time spent on pages, navigation paths, click data
• Cookie Data: Information collected through cookies and similar technologies (see our Cookie Policy)
• Location Data: Approximate geographic location based on IP address

How We Use Your Personal Information

We use your personal information for the following purposes, based on legitimate legal grounds:

To Provide Educational Services

• Processing enrollment requests and managing course registrations
• Delivering educational content and materials
• Providing access to online learning platforms
• Communicating about your courses and program updates
• Issuing certificates or credentials upon course completion

To Communicate With You

• Responding to your inquiries and requests
• Sending administrative information about our services
• Providing customer support and assistance
• Notifying you about changes to our policies or services

For Marketing Purposes (With Your Consent)

• Sending newsletters and promotional materials about our courses
• Informing you about new programs and educational opportunities
• Conducting surveys to improve our services

To Improve Our Services

• Analyzing website usage and user behavior
• Conducting research and development
• Testing new features and functionalities
• Optimizing user experience and educational content

For Legal and Security Purposes

• Complying with legal obligations and regulatory requirements
• Protecting against fraud, unauthorized access, and security threats
• Enforcing our terms and conditions
• Resolving disputes and investigating complaints

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contract with you when you enroll in our courses
• Consent: You have given explicit consent for specific processing activities, such as marketing communications
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving services and ensuring security
• Legal Obligation: Processing is required to comply with applicable laws and regulations

How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

Service Providers

We work with trusted third-party service providers who assist us in operating our website and delivering our services, including:

• Web hosting and cloud storage providers
• Email communication platforms
• Payment processors
• Learning management system providers
• Analytics and marketing tools

These service providers are bound by contractual obligations to protect your data and use it only for the purposes we specify.

Educational Partners

We may share information with invited specialists and educational experts who contribute to our programs, but only to the extent necessary for course delivery and educational purposes.

Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, such as court orders or government agencies.

Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change and the choices you may have regarding your information.

International Data Transfers

As we operate from the Netherlands and serve customers in Canada, your personal information may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the European Commission
• Privacy Shield certification (where applicable)
• Adequacy decisions by the European Commission
• Other legally approved transfer mechanisms

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Enrollment and Course Data: Retained for the duration of your participation plus 7 years for record-keeping and legal compliance
• Communication Records: Retained for 3 years after the last communication
• Marketing Consent: Retained until you withdraw consent or 2 years of inactivity
• Financial Records: Retained for 7 years as required by tax and accounting regulations
• Website Usage Data: Retained for 2 years for analytics purposes

After the retention period expires, we securely delete or anonymize your personal information.

Your Rights Under GDPR

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

Right of Access

You have the right to request a copy of the personal information we hold about you and information about how we use it.

Right to Rectification

You can request that we correct inaccurate or incomplete personal information about you.

Right to Erasure

You can request deletion of your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

Right to Restriction of Processing

You can request that we limit the processing of your personal information in certain situations.

Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller.

Right to Object

You can object to processing of your personal information based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent

Where we rely on consent to process your personal information, you have the right to withdraw that consent at any time.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state where you reside, work, or where an alleged infringement occurred.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month, though this may be extended in complex cases.

Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• SSL/TLS encryption for data transmission
• Secure server infrastructure and data storage
• Access controls and authentication mechanisms
• Regular security assessments and updates
• Employee training on data protection practices
• Incident response procedures

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and improve your experience on our website. For detailed information about our use of cookies, please refer to our Cookie Policy.

You can control cookie preferences through your browser settings and our cookie consent tool available on the website.

Third-Party Links

Our website may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to such third-party sites. We are not responsible for the privacy practices of these external sites and encourage you to review their privacy policies before providing any personal information.

Children's Privacy

Our services are intended for individuals who are at least 16 years of age. We do not knowingly collect personal information from children under 16 without parental consent. If we become aware that we have collected personal information from a child under 16 without verification of parental consent, we will take steps to delete that information.

If you believe we have collected information from a child under 16, please contact us immediately at [email protected].

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make significant changes, we will notify you by:

• Posting the updated policy on our website with a revised effective date
• Sending an email notification to registered users
• Displaying a prominent notice on our website

We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes are posted constitutes your acceptance of the updated policy.

Marketing Communications

If you have consented to receive marketing communications from us, we may send you information about our courses, programs, and educational opportunities via email or other channels.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email
• Contacting us at [email protected]
• Adjusting your communication preferences in your account settings

Please note that even if you opt out of marketing communications, we will still send you essential service-related messages, such as enrollment confirmations and administrative updates.

Data Protection Officer

For questions or concerns about our data protection practices, you can contact our data protection team at:

Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the Netherlands. Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Netherlands.

For data subjects in the European Union, this does not affect your rights under GDPR or your right to lodge a complaint with your local supervisory authority.

Contact Information

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