Privacy and cookie statement Winc Academy B.V.

Last updated: February 2025

Your privacy is very important to Winc Academy B.V. (hereafter: Winc Academy). In this statement you can read how we collect, process, secure and store your data in accordance with the General Data Protection Regulation (AVG). This means that:

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• Clearly define our purposes before we process your personal data, through this privacy statement;
• Store as little personal data as possible and only the data necessary for our purposes;
• Explicitly request permission to process your personal data, should consent be required;
• Take necessary security measures to protect your personal data. We also impose these obligations on parties who process personal data for us;
• Respect your rights, such as the right to access, correct or delete your personal data processed with us.

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Good to know is that Winc Academy does not use automated decision making. And that in no case is special and/or sensitive personal data requested. 

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For what purposes do we use your personal data?

Winc Academy processes personal data for the following purposes:

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• Enrollment and Guidance: Processing enrollments and providing personalized guidance during training.
• Accessing the online learning environment: Managing accounts and progress information.
• Certification: sharing achieved results with the certification partner for issuance and verification of certificates.
• Administration and billing: Processing payments, purchases, study periods, progress and any data exchange with grant partners (if applicable and so agreed).
• Quality improvement: analyzing data to improve the learning experience and service. Where possible, we anonymize this process.
• Marketing and Communications: Sending personalized messages after consent, such as follow-ups on webinars, updates on training and other relevant information.
• Legal obligations: Sharing progress or other relevant data with grant partners, such as UWV or municipalities, if contractually or legally required.

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If you have any questions about the processing of your data, please feel free to contact us using the contact information at the bottom of this statement.

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Application for or orientation to training

Through our website www.wincacademy.nl you can sign up for one of our courses, more information, orientation tests or events, such as a free webinar. 

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For this purpose, depending on your interaction with us, we process the following data:

• NAW data
• Phone number
• Email address
• Correspondence
• Data and results from any testing
• Company name

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This information helps us to offer you the right training and prepare for a possible agreement. Contact information will only be used for further follow-up if you have given permission to receive marketing communications.

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Participate in training

When you participate in one of our training programs, we process the following personal data:

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• The information you provided when you applied for the program
• Training progress and study activity (such as login details and results obtained)
• Payment and billing information
• Details of your employer or grant provider (if applicable)
• Any correspondence between you and Winc Academy via email or Slack, for example.

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We process this data to execute the agreement we enter into with you. With the data from your registration we create an account in our online learning environment (LearnAMP). This account is needed to access study materials, keep track of your progress and submit assignments. In addition, we use the data to guarantee your well-deserved certificate.

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Your account

After you register, you can log in to your personal account in our online learning environment, where you can access course materials for your course(s), track your study progress and activity, and find the various options for tutoring.

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For this purpose, we process the following personal data:

• Account information
• First and last name
• Email address
• Language
• Time zone
• Training progress and study activity
• Documents uploaded by you (such as assignments and projects)
• Our feedback on your assignments and final projects
• Any profile picture you upload yourself
• Any information you fill in yourself as the content of your bio
• Any information you enter yourself as the content of a message

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We process this data to be able to execute the agreement we enter into with you and to optimally support your learning process. We keep your personal data until you indicate that you want it removed. We do this to ensure that your certificates, if any, remain valid, your progress remains available in case of reactivation, and you can consult old material should you take further courses at Winc Academy.

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By creating an account and participating in our learning environment, you agree to LearnAmp's terms and conditions. You can find these terms and conditions here

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Marketing Communications

We send newsletters and marketing emails only if you have given your consent (opt-in). In these mails you will find news, tips and information about our products, services or offers. We do this based on the legitimate interest we have in informing you about offers and new products or services.

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You can unsubscribe at any time using the unsubscribe link in each email. If you unsubscribe from marketing, we will retain your information only for administrative purposes or to ensure that you do not receive further messages while you are still studying with us. 

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Provision of personal data to third parties

We share your personal data with third parties only when permitted by law. We have entered into agreements with these third parties so that they maintain the same high standards of security and confidentiality as we do.

We may share your information with third parties for the following reasons:

• When necessary to perform the agreement with you
• When you have given explicit permission to do so
• When we have a legitimate interest
• When required by law (for example, in the case of a request from the police in connection with a criminal investigation)

The categories of parties with whom we may share personal data are:

• IT vendors and hosting parties
• Grant or funding partners (if applicable).
• Independent, hired teachers
• Your employer (if applicable)
• Cookie service providers

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Deletion of data

We follow the following rules for retention and deletion of personal data:

• Students and alumni: data will be kept for as long as you are or have been attending a course with us. This allows us to validate certificates, support former students in further education and, upon request, reactivate an account in our learning environment without losing important data.
• Inactive accounts: If you are not or have not taken a course with us and are not signed up for our marketing activities, your data will be automatically deleted 5 years after the last activity.

Deletion upon request: You can request complete deletion of your data at any time by sending an email to welkom@wincacademy.nl. Please note that certain data, such as invoices and payment information, may not be deleted immediately due to legal retention periods.

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Data processing outside the EEA

In order to provide our services, we use external systems and service providers. This may involve processing or storing personal data outside the European Economic Area (EEA). We only do this if there is an adequate level of protection, for example through European Commission model contractual clauses (such as with the UK) or other legally approved safeguards.

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We are familiar with the EU Court of Justice ruling of July 16, 2020 (Schrems II) and take additional measures where necessary to protect your data. Do you have any questions? Feel free to contact us using the contact information at the bottom of this statement.

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Data breaches

For data breaches that pose risks to you, we report this to the Personal Data Authority and inform data subjects if necessary.

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Cookies

At Winc Academy we use cookies and similar technologies to make our website work, improve it and offer personalized content. Cookies are small text files placed on your device to store data about your website visit.

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What types of cookies we use:

• Necessary cookies: Essential for the operation of our website.
• Analytical cookies: For the collection of statistics to improve the usability of the website (e.g. via Google Analytics and Typeform).
• Functional cookies: To improve functionality, such as live chats and social media integrations.
• Marketing Cookies: For personalized advertising and measuring the effectiveness of campaigns (e.g. through HubSpot, Facebook and Google Ads).

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Permission and management

During your first visit to our website, we explicitly ask for your permission to use non-essential cookies. You can set your preferences for each type of cookie. You can also manage or delete cookies at any time through your browser settings.

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Sharing data with third parties

Certain cookies share data with third parties, including:

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• Google LLC (Google Analytics, Google Ads, DoubleClick)
• HubSpot (website analytics and marketing)
• Facebook Pixel (marketing and conversion tracking)
• LinkedIn (marketing and social interactions)
• Typeform (forms and usage analytics)
• Vimeo (for embedded videos)

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Social Media Integrations

Our website may contain buttons that allow you to share content or follow us on social media. These buttons may set tracking cookies. Please review the privacy statements of the respective platforms for more information

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Retention periods and deletion of cookies

Most cookies have an expiration date and are deleted automatically after a certain period of time. You can also delete cookies manually through your browser settings.

Your rights

You are entitled to:

• Inspection, correction or deletion of your data
• Limitation of processing
• Data portability
• Objection to data processing

Send a request to welkom@wincacademy.nl and we will respond within 30 days. Please note that we may ask you to answer additional verification questions.

The 30-day period may be extended for reasons related to the specific rights of data subjects or the complexity of the request. If we extend this deadline, we will notify you in a timely manner. If we are unable to comply with your data, for example due to a legal retention obligation, we will also inform you in a timely manner.

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‍Filing a complaint

At Winc Academy, we strive to provide the best learning experience for everyone. Nevertheless, it may happen that you are not satisfied. In that case, you can file a complaint according to the procedure below.

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1. Filing a complaint

Send an e-mail to welkom@wincacademy.nl clearly describing your complaint.

• You will receive an acknowledgement of receipt within 2 weeks.
• Within 4 weeks of receiving the complaint, you will receive a substantive response.

2. Deferral of treatment

If we need more time to deal with your complaint, you will receive a notice with an explanation and the expected time for resolution.

3. Confidentiality and independent review
   
   • Your complaint will be handled confidentially.
   • The complaint will be handled within 6 weeks by an independent employee of Winc Academy.
4. Disagree with the outcome?
   
   • If you feel that your complaint has not been handled properly, you may contact the NRTO's Disputes Committee at www.degeschillencommissie.nl.
   • In cases that are privacy-related, you can contact the Personal Data Authority (AP) at www.autoriteitpersoonsgegevens.nl.

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More information about complaint procedures can be found in our terms and conditions.

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‍Modifications to this privacy statement

Winc Academy reserves the right to modify this privacy statement. It is advisable to regularly consult the most recent version via our website to keep yourself informed of any changes. When significant changes occur, we actively inform data subjects through the contact information they provide or other appropriate means.

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Contact details

Winc Academy B.V.

Arnhemsestraatweg 33

6881 ND, Velp

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Email address: welkom@wincacademy.nl

Phone number: +31 (0)88 16 60 316

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Chamber of Commerce number: 73031178

VAT number: VAT 8593.27.401