Privacy Policy

1. Data Controller

Business Name: Learn with Lucas

Legal Entity: Eenmanszaak (One-man business)

Owner: Jaïr Lucas Zacharias Potjer

KVK Number: 95488731

Address: Wenneker 14, 7152 HA Eibergen, Netherlands

Email: english@learnwithlucas.com

Phone: +31 6 1182 8410

2. What Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when you:

• Create an account: Name, email address
• Subscribe to services: Payment information (processed by Stripe/Xendit), billing address
• Join Discord communities: Discord username, profile information
• Contact us: Name, email address, message content
• Download free content: Email address
• Book private lessons: Name, email, language learning goals, availability

2.2 Information Collected Automatically

When you use our website or services, we automatically collect:

• Usage data: Pages visited, time spent, features used
• Device information: Browser type, operating system, IP address
• Cookies: See Section 8 for cookie policy details

2.3 Information from Third Parties

• Payment processors: Stripe and Xendit provide transaction confirmation and payment status
• Discord: Basic profile information when you join our communities
• Email service providers: Email delivery status and engagement metrics
• Instagram/Meta: When you comment on our Instagram posts with specific keywords, our automated system may send you a direct message with a relevant link. We collect your Instagram user ID temporarily to deliver this message. No comment data or user IDs are stored permanently after the message is sent.

3. How We Use Your Information

3.1 To Provide Services

• Process subscriptions and deliver digital content
• Manage your account and access to premium features
• Send monthly stories, practice guides, and lesson materials
• Facilitate Discord community access and group sessions
• Schedule and conduct private lessons

3.2 To Communicate With You

• Send service-related emails (subscription confirmations, renewal reminders)
• Respond to your inquiries and support requests
• Send weekly lesson announcements and free content (with your consent)
• Notify you of important changes to our services or policies
• Send automated Instagram direct messages in response to keyword comments, delivering links you have implicitly requested by commenting

3.3 To Improve Our Services

• Analyze usage patterns to improve content and features
• Understand which lessons and materials are most helpful
• Troubleshoot technical issues
• Develop new educational content based on user needs

3.4 Legal Basis for Processing (GDPR)

We process your data based on:

• Contract performance: Processing payments, delivering subscriptions
• Consent: Marketing emails, optional community features
• Legitimate interests: Service improvement, fraud prevention, security, and responding to Instagram comments with relevant links
• Legal obligations: Tax compliance, financial record-keeping

4. How We Share Your Information

4.1 We Never Sell Your Data

We do not sell, rent, or trade your personal information to third parties for marketing purposes. Your data is yours.

4.2 Service Providers We Use

We share limited data with trusted service providers who help us operate our business:

• Payment processing: Stripe and Xendit (payment details, transaction information)
• Email delivery: Email service providers (email addresses, engagement data)
• Website hosting: Hosting providers (usage data, technical information)
• Community platform: Discord (username, profile information)
• Meta/Instagram: We use the Instagram Graph API to read comments on our posts and send automated replies. This data is processed solely to deliver the requested link and is not shared further.

All service providers are contractually required to protect your data and use it only for specified purposes.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government regulation, or to protect our rights, property, or safety.

5. Data Retention

5.1 Active Accounts

We retain your personal data for as long as your account is active or as needed to provide services.

5.2 After Account Closure

After you close your account or unsubscribe, we retain:

• Financial records: 7 years (Dutch tax law requirement)
• Email addresses (unsubscribed): Indefinitely to honor unsubscribe requests
• Other personal data: Deleted within 30 days unless legally required to retain

5.3 Backup Systems

Data in backup systems may persist for up to 90 days before automatic deletion.

6. Your Rights Under GDPR

As an EU/EEA resident, you have the following rights:

6.1 Right to Access

Request a copy of all personal data we hold about you.

6.2 Right to Rectification

Request correction of inaccurate or incomplete personal data.

6.3 Right to Erasure ("Right to Be Forgotten")

Request deletion of your personal data, except where we have legal obligations to retain it (e.g., financial records).

6.4 Right to Restriction of Processing

Request that we limit how we use your data in certain circumstances.

6.5 Right to Data Portability

Request a copy of your data in a structured, machine-readable format to transfer to another service.

6.6 Right to Object

Object to processing based on legitimate interests, including direct marketing.

6.7 Right to Withdraw Consent

Withdraw consent for marketing emails or optional features at any time (does not affect lawfulness of prior processing).

6.8 How to Exercise Your Rights

To exercise any of these rights, email english@learnwithlucas.com with your request. We will respond within 30 days.

7. Data Security

7.1 How We Protect Your Data

• Encryption: All payment data is encrypted via SSL/TLS
• Secure servers: Data stored on secure, access-controlled servers
• Limited access: Only authorized personnel can access personal data
• Regular updates: Security measures reviewed and updated regularly

7.2 Your Responsibility

You are responsible for keeping your account credentials confidential. Do not share your password or account access with others.

7.3 Data Breach Notification

In the event of a data breach affecting your personal information, we will notify you and relevant authorities within 72 hours as required by GDPR.

8. Cookies and Tracking

8.1 What Cookies We Use

Our website uses cookies for:

• Essential cookies: Required for basic website functionality (login, shopping cart)
• Analytics cookies: To understand how visitors use our site (anonymized data)
• Preference cookies: To remember your settings and preferences

8.2 Third-Party Cookies

We use:

• Google Analytics: Website traffic analysis (anonymized)
• Stripe/Xendit: Payment processing and fraud prevention

8.3 Managing Cookies

You can control cookies through your browser settings. Note that disabling essential cookies may affect website functionality.

9. Children's Privacy

Our services are intended for adults and learners aged 16 and older. We do not knowingly collect personal data from children under 16 without parental consent. If you believe we have collected data from a child under 16, please contact us immediately and we will delete it.

10. International Data Transfers

We are based in the Netherlands (EU). Some of our service providers (e.g., cloud hosting, email services) may process data outside the EU/EEA. When this occurs, we ensure adequate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Service providers certified under adequacy frameworks

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Material changes will be communicated via email to active subscribers at least 30 days before taking effect. The "Last updated" date at the top of this page indicates when the policy was last revised.

12. Contact Us About Privacy

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

Email: english@learnwithlucas.com
Phone: +31 6 1182 8410
Address: Wenneker 14, 7152 HA Eibergen, Netherlands