Privacy & cookie policy
We collect little, we don't track you across the web, and we don't sell anything to anyone. This page sets out the detail.
1. Who is responsible
J&D B.V. is the controller of the personal data described here.
- Address: Zuiddijk 416, 1505 HE Zaandam, Netherlands
- Privacy contact: [email protected]
- General contact: [email protected] · +31 75 303 4120
- Chamber of Commerce (KvK) number: [insert registered KvK number]
We are established in the Netherlands and process personal data in accordance with the EU General Data Protection Regulation (GDPR). Because most of our learners are in Canada, we also describe below how Canadian privacy expectations are met.
2. What we collect, and why
| What | Why | Legal basis (GDPR) |
|---|---|---|
| Enquiry details | To answer your enquiry and suggest a suitable module | Consent, and our legitimate interest in responding to enquiries |
| Enrolment details | To form and perform the contract, issue invoices and meet accounting obligations | Contract; legal obligation for tax records |
| Learning records | To teach you, give feedback and confirm completion | Contract |
| Session recordings | So learners who cannot attend can follow the module | Legitimate interest, with consent for any contribution of yours that is identifiable |
| Correspondence | To support you during a module and keep a record of what was agreed | Contract; legitimate interest |
| Server logs | Security, fault diagnosis and keeping the site running | Legitimate interest |
We do not ask for special categories of data, and we ask you not to send confidential or third-party data in exercise submissions.
3. Cookies
This website sets no cookies. There is no analytics package, no advertising pixel, no tracking script and no third-party embed on these pages. That is why you are not being asked to accept anything.
Two things sit outside the pages themselves and are worth knowing about:
- Fonts are requested from Google Fonts when a page loads, which means your IP address is visible to that service. If you would rather this did not happen, the fonts can be self-hosted — see the note at the end of this page.
- The video conferencing platform used for live sessions sets its own cookies when you join a session. That happens on their domain, under their policy, and we will tell you which platform and link to its policy at enrolment.
If we ever add analytics, we will ask for consent first and update this page before doing so.
4. Who else sees your data
We use a small number of service providers, each bound by a data processing agreement and each with access limited to what their function requires:
- a web hosting provider (site hosting and server logs), located in the EU;
- an email provider (correspondence and enrolment records);
- a video conferencing provider (live sessions and recordings);
- a payment processor and our accountant (invoicing and statutory records).
We do not sell personal data, do not share it for advertising, and do not pass learner details to employers, recruiters or any third party for their own purposes. We disclose data to authorities only where legally required.
5. International transfers
Our systems are hosted in the European Economic Area. Because you are in Canada, data you send us travels to the EEA, and material we send you travels back. Where a provider processes data outside the EEA, we rely on the European Commission's adequacy decision for Canada in respect of organisations subject to PIPEDA, or on standard contractual clauses, as applicable.
6. How long we keep things
- Enquiries that don't lead to enrolment: 12 months, then deleted.
- Learning records and feedback: 3 years after your last module, so that we can confirm completion or reissue a certificate.
- Session recordings: 8 weeks after the module ends, then deleted.
- Invoices and accounting records: 7 years, as required by Dutch tax law.
- Server logs: 30 days.
7. Your rights
Under the GDPR you may request access to your personal data, correction of inaccurate data, erasure, restriction of processing, portability of data you provided, and you may object to processing based on legitimate interests. Where processing rests on consent, you may withdraw it at any time; this does not affect processing already carried out.
Write to [email protected]. We reply within one month and will not charge you for a reasonable request. We may ask you to confirm your identity before acting on a request.
If you are unhappy with how we've handled your data, you may complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). Learners in Canada may also contact the Office of the Privacy Commissioner of Canada or their provincial privacy commissioner, and we will cooperate with any resulting enquiry.
8. Security
Access to learner records is limited to the five people who work here and is protected by unique accounts and multi-factor authentication. Data is transmitted over encrypted connections. Exercise files are stored in a single access-controlled workspace and are not copied to personal devices. No system is perfect; if a breach occurs that is likely to put you at risk, we will notify you and the supervisory authority as required.
9. Children
Our modules are intended for adults. We do not knowingly enrol anyone under 16 or collect their data. If you believe a child has provided us with personal data, write to us and we will delete it.
10. Changes to this policy
If this policy changes materially, we will update the date above and, for anyone currently enrolled, say so by email. Earlier versions are available on request.
Notes for the site owner: two items need action before this page goes live.
- Insert the KvK number, and name the actual hosting, email, conferencing and payment providers in section 4 — a named list is both more honest and easier to defend than a generic one.
- The Google Fonts reference in section 3 is accurate for this build. Self-hosting the four font files removes the third-party request entirely and makes the "no third-party requests" claim absolute; that is the recommended option, after which section 3 should be simplified.