Privacy Policy

1. Introduction & Controller Identity

This Privacy Policy explains how velcrwona (“we”, “us”, or “our”) collects, uses, and protects personal data when you visit this website (“Site”) and when you contact us through our registration form. The Site provides educational content about footwear retail management, including shoe merchandising routines, customer service communication, inventory organization, and sales communication skills.

Data Controller: velcrwona Education, Masarykovo náměstí 9, 686 01 Uherské Hradiště, Czechia. Contact email: [email protected].

Effective Date: March 19, 2026. We do not appoint a Data Protection Officer as a matter of routine, because we do not conduct large-scale processing of special-category data. If you have questions about privacy, you can contact us using the email above.

2. Personal Data We Collect

We collect personal data that you provide directly, as well as limited technical data that your browser shares when you visit a website. The categories below describe what may be collected depending on how you use the Site.

• Identity and contact data: first name, last name, and email address when you submit the registration form.
• Form content: learning goals and any details you choose to write (for example: store format, merchandising priorities, stockroom routines you want to improve, or coaching topics for a team).
• Technical data: IP address, browser type and version, device type, operating system, and language settings.
• Usage data: pages you view, time spent on pages, and referral sources (for example, whether you arrived from a search engine or another website).
• Cookies and identifiers: cookie preferences stored in your browser, and cookie identifiers used for essential functionality and (if you consent) analytics and marketing measurement.
• Conversion events: whether a form submission was completed, and basic information needed to attribute the event to a session or campaign (where applicable and only if you consent to marketing cookies).

We do not request special-category data (for example health information, religion, political views), financial account details, or government identification numbers through this Site. Please do not include such information in the learning goals field.

3. Why We Process Personal Data & Legal Basis

We process personal data only for clear, limited purposes connected to the educational services described on this Site. Where the GDPR or UK GDPR applies, we rely on the legal bases listed below.

• Registration form and enquiries: to reply with course details, learning-path recommendations, and scheduling information. Legal basis: Article 6(1)(b) (steps at your request prior to entering a contract) and Article 6(1)(a) (consent), where applicable.
• Analytics: to understand how visitors use the Site and improve content structure (for example: which course topics are most read). Legal basis: Article 6(1)(a) (consent), when analytics cookies are enabled.
• Marketing measurement and remarketing: to measure advertising performance and show relevant offers (for example: course overview reminders). Legal basis: Article 6(1)(a) (consent), when marketing cookies are enabled.
• Security and fraud prevention: to protect the Site against abuse, bots, and malicious activity. Legal basis: Article 6(1)(f) (legitimate interests), balancing our interest in security with your rights.
• Legal obligations: to comply with applicable laws, regulatory requests, and to establish or defend legal claims if needed. Legal basis: Article 6(1)(c) (legal obligation) and/or Article 6(1)(f) (legitimate interests).

Automated decision-making (GDPR Article 22): we do not engage in automated decision-making or profiling that produces legal or similarly significant effects.

4. Cookies & Tracking

Cookies are small text files stored on your device. We also refer to similar technologies such as pixel tags and server-side event sharing. We use three categories of cookies, aligned with the cookie preferences panel available through the footer.

Essential cookies (always active)

Essential cookies are required for the Site to function. They help with basic continuity and storing your privacy choices. These cookies do not require consent.

• _site_session: supports session continuity and basic site operation. Retention: session to 12 months depending on configuration.
• cookie_consent: stores your cookie preference choices. Retention: 12 months.

Analytics cookies (consent required)

If you enable analytics cookies, we may use Google Analytics 4 (GA4) with IP anonymization to understand how visitors use the Site (for example: which pages are visited, approximate location at a country/city level, and general device categories). Typical cookies include _ga and _ga_XXXXXXXXXX. Data retention is typically set to 14 months in GA4.

Marketing cookies (consent required)

If you enable marketing cookies, we may use Google Ads and Meta measurement tools (such as pixel tags and conversion APIs when implemented) to measure ad performance, limit repeated ads, and build audiences for remarketing and lookalike targeting. Typical cookies include _gcl_au, _fbp, and _fbc with typical retention around 90 days.

Note: this Site is designed to respect your choices. Analytics and marketing tracking features only activate after you provide consent in the cookie banner or preferences modal. You can change your choices at any time using the “Manage cookie preferences” link.

5. Consent (EEA/UK)

Users in the EEA and the United Kingdom receive a consent notice under GDPR/UK GDPR. Marketing and analytics cookies activate only after explicit, informed, freely given consent under Article 6(1)(a). Consent is recorded in the cookie_consent cookie for up to 12 months.

You may withdraw consent at any time using the cookie preferences controls available through the footer. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

6. Sharing With Advertising & Service Partners

We use reputable providers to operate and improve the Site. Depending on your cookie choices and your interaction with the Site, limited personal data may be shared with:

• Google LLC (Google Analytics 4, Google Ads, Tag Manager, remarketing): cookie identifiers, usage data, conversion events, and limited technical data. Privacy: https://policies.google.com/privacy.
• Meta Platforms (measurement, remarketing, custom/lookalike audiences): page events and conversions, and where configured, hashed identifiers (for example, hashed email). Privacy: https://www.facebook.com/privacy/policy.
• Cloudflare (content delivery and security): IP-based threat detection and performance optimization. Privacy: https://www.cloudflare.com/privacypolicy/.

We do not sell personal data. We use service providers to process data on our behalf and, where relevant, to measure advertising. These providers are not permitted to use Site data for their own independent commercial purposes.

7. International Transfers

Some providers may process data outside the EEA/UK, including in the United States. Where applicable, transfers may rely on the EU-US Data Privacy Framework (including the UK Extension and Swiss-US DPF where relevant). If a transfer cannot rely on that framework, we use Standard Contractual Clauses (EU 2021/914) and/or the UK International Data Transfer Agreement as fallback mechanisms, together with supplementary measures where appropriate.

8. Retention

We keep personal data only as long as needed for the purposes described in this Privacy Policy:

• Registration form submissions: up to 2 years from the last interaction, unless you request deletion sooner.
• Analytics data: typically 14 months in GA4 (when enabled by consent).
• Marketing cookies: retained according to cookie lifetimes (commonly around 90 days) and advertising platform settings (when enabled by consent).
• Email correspondence: for the duration of the relationship and up to 1 year after the last message, unless a longer period is needed for legal reasons.
• Server and security logs: typically up to 90 days, unless needed to investigate abuse or security incidents.
• Consent record: up to 3 years for audit purposes, where legally appropriate.
• Legal and tax: where applicable, we retain data as required by law (often 6–10 years for invoices and accounting records).

9. Your Rights (GDPR & UK GDPR)

If GDPR or UK GDPR applies, you may have the right to request access, rectification, erasure, restriction, portability, and to object to processing. You may also withdraw consent at any time (GDPR Article 7(3)). You can lodge a complaint with a supervisory authority (GDPR Article 77).

• Access (Article 15)
• Rectification (Article 16)
• Erasure (Article 17)
• Restriction (Article 18)
• Portability (Article 20)
• Objection (Article 21)
• Withdraw consent (Article 7(3))

To exercise your rights, email [email protected]. We aim to respond within 30 days, with extensions where permitted for complex requests.

Supervisory authority resources: EU overview at https://edpb.europa.eu; UK ICO at https://ico.org.uk.

10. Children

This Site is not directed at individuals under 16. We do not knowingly collect personal data from minors. If we learn that personal data from a child under 16 was collected without verifiable parental consent, we will delete it promptly.

11. Do Not Track

This website does not respond to “Do Not Track” (DNT) browser signals. Third-party providers may have their own approaches to DNT.

12. Data Deletion Requests

You can request deletion of your personal data by emailing [email protected] with the subject line “Data Deletion Request”. We may ask you to verify your identity before completing the request. In most cases, requests are completed within 30 days.

13. Business Transfers

In the event of a merger, acquisition, asset sale, financing, reorganization, or insolvency, personal data may be transferred to a successor entity as part of that transaction. If such a transfer materially changes how personal data is used, we will provide notice on the Site.

14. California (CCPA / CPRA)

If you are a California resident, you may have rights to know, delete, correct, and opt out of the sale or sharing of personal information. Over the past 12 months, we may have disclosed identifiers (such as name, email, IP address, and device identifiers) and internet/network activity (such as browsing events) to service providers and advertising partners for analytics and marketing purposes, where you have provided consent through cookie preferences.

We do not sell personal information as defined by CCPA. We may share personal information for cross-context behavioral advertising when marketing cookies are enabled. You can opt out by disabling marketing cookies in the cookie preferences panel.

To submit a request, email [email protected] with the subject line “California Privacy Request”. We will verify your identity before fulfilling the request. Authorized agents may submit requests with written authorization.

15. Virginia (VCDPA)

If you are a Virginia resident, you may have rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising. We do not sell personal data and we do not engage in profiling that produces legal or similarly significant effects.

To submit a request, email [email protected] with the subject line “Virginia Privacy Request”. If you wish to appeal a refusal, use the subject line “Appeal of Refusal — Privacy Request”. We respond to appeals within 60 days.

16. Nevada

Nevada residents may submit a verified opt-out request by emailing [email protected] with the subject line “Nevada Do Not Sell Request”. We do not currently sell personal information under Nevada Revised Statutes Chapter 603A.

17. Changes to This Policy

We may update this Privacy Policy to reflect changes in the Site, tracking tools, or legal requirements. Material changes will be announced via a notice on the homepage at least 14 days before taking effect, where appropriate. The “Last Updated” date at the top of this page will change with every revision.

18. Contact

For privacy questions or requests, contact:

• velcrwona Education
• Masarykovo náměstí 9, 686 01 Uherské Hradiště, Czechia
• Email: [email protected]