Privacy Policy
GDPR & Irish Data Protection Act CompliantAt xerbolinaqev, we take your privacy seriously. This policy explains how we collect, use, store, and protect your personal information when you use our budget education services. We're committed to transparency and your right to control your data. If you're based in Ireland or the EU, you're protected by strong data rights under GDPR and the Irish Data Protection Act 2018.
Who We Are
xerbolinaqev operates as a budget education platform registered in Ireland. We provide educational resources, courses, and tools to help individuals better understand personal finance and budgeting strategies.
Data Controller: xerbolinaqev
Registered Address: Ulysses House, Foley St, Mountjoy, Dublin 1, Ireland
Contact: +353 91 568 707 | info@xerbolinaqev.com
What Information We Collect
We collect different types of information depending on how you interact with our services. Here's what we gather and why:
Account Information
Name, email address, phone number, and password when you register for courses or create an account.
Payment Details
Billing information and transaction records when you purchase courses. We don't store full card details — our payment processors handle that securely.
Learning Activity
Course progress, quiz results, completion certificates, and engagement with educational materials to personalize your experience.
Technical Data
IP address, browser type, device information, and usage patterns to improve platform performance and security.
Information You Provide Directly
- Registration and profile details when signing up
- Communication preferences for newsletters and updates
- Feedback, questions, or support requests you send us
- Responses to surveys or questionnaires about your learning goals
- Comments or posts in community forums (if applicable)
Information Collected Automatically
When you use our platform, we automatically collect certain technical information through cookies and similar technologies. This includes page views, time spent on content, navigation paths, and interaction with course materials. We use this data to understand how people learn and where we can improve the experience.
How We Use Your Information
We use your data for specific, legitimate purposes that directly relate to providing and improving our educational services:
- Delivering course content and tracking your learning progress
- Processing payments and maintaining transaction records
- Sending important updates about courses you've enrolled in
- Responding to your questions and providing customer support
- Improving course quality based on how students engage with materials
- Personalizing recommendations for relevant educational content
- Maintaining platform security and preventing fraud
- Complying with legal obligations and protecting our rights
- Sending marketing emails (only if you've opted in)
We won't use your information for purposes beyond what's described here without getting your explicit consent first.
Legal Basis for Processing (GDPR)
Under GDPR, we must have a lawful reason to process your personal data. Here's what applies to different types of processing:
- Contractual Necessity: Processing needed to deliver courses you've purchased and manage your account
- Legitimate Interest: Improving our services, personalizing content, and maintaining security
- Consent: Marketing communications and optional features you've agreed to
- Legal Obligation: Tax records, fraud prevention, and compliance with Irish and EU law
Who We Share Your Data With
We don't sell your personal information. Ever. But we do share data with certain trusted partners who help us run our business:
Service Providers
We work with companies that provide essential services like payment processing, email delivery, hosting, and analytics. These providers only access data necessary for their specific function and are contractually required to protect it.
Legal Requirements
We may disclose information if required by Irish or EU law, court orders, or government requests. We'll notify you unless legally prohibited from doing so.
Business Transfers
If xerbolinaqev is acquired or merges with another company, your data may transfer to the new owner. We'll notify you before this happens and inform you of any changes to how your data is handled.
We don't share data with third parties for their marketing purposes without your explicit permission.
International Data Transfers
While xerbolinaqev operates in Ireland, some of our service providers may process data outside the European Economic Area (EEA). When this happens, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses approved by the European Commission
- Transfers to countries with adequacy decisions
- Privacy Shield certification (where applicable)
- Additional security measures to protect your rights
We carefully vet any international providers to ensure they meet EU data protection standards.
Your Data Protection Rights
Under Irish and EU law, you have significant rights over your personal information. These aren't just theoretical — we're committed to honoring them promptly.
Your Rights Include:
- Right of Access: Request a copy of all personal data we hold about you
- Right to Rectification: Correct inaccurate or incomplete information
- Right to Erasure: Delete your data when there's no compelling reason to keep it
- Right to Restrict Processing: Limit how we use your data in certain situations
- Right to Data Portability: Receive your data in a structured, commonly used format
- Right to Object: Stop processing based on legitimate interests or for marketing
- Right to Withdraw Consent: Remove consent at any time (doesn't affect previous processing)
- Right to Lodge a Complaint: Contact the Data Protection Commission if you're unhappy
How to Exercise Your Rights
Send requests to info@xerbolinaqev.com with "Data Rights Request" in the subject line. Include your full name and registered email address. We'll respond within one month (may extend to two months for complex requests). There's no charge for most requests, though we may apply a reasonable fee for excessive or repetitive requests.
Data Security Measures
We take security seriously and invest in multiple layers of protection to keep your information safe from unauthorized access, loss, or misuse.
Encryption
Data encrypted in transit (TLS/SSL) and at rest using industry-standard protocols.
Access Controls
Strict authentication, role-based permissions, and regular access reviews.
Monitoring
Continuous security monitoring, intrusion detection, and incident response procedures.
Backups
Regular encrypted backups stored securely with tested recovery processes.
Staff Training
Regular security awareness training and strict confidentiality agreements.
Audits
Regular security assessments and compliance reviews by independent auditors.
No system is 100% secure, but we continuously update our defenses and follow best practices to minimize risks.
How Long We Keep Your Data
We only retain personal information as long as necessary for the purposes we collected it. Retention periods depend on the type of data and legal requirements:
| Data Type | Retention Period | Reason |
|---|---|---|
| Account Information | Active account + 2 years after closure | Service delivery and legal obligations |
| Course Progress Data | Active account + 3 years | Certificate verification and records |
| Payment Records | 7 years from transaction | Irish tax and accounting requirements |
| Marketing Consents | Until withdrawn or 3 years inactive | Marketing regulations and preferences |
| Support Communications | 3 years from last contact | Service quality and issue resolution |
| Technical Logs | 90 days | Security monitoring and troubleshooting |
When data is no longer needed, we securely delete or anonymize it. You can request earlier deletion if there's no legal reason for us to keep it.
Cookies and Tracking Technologies
We use cookies and similar technologies to make our platform work properly and understand how people use it. You can control most cookies through your browser settings.
Types of Cookies We Use
- Essential Cookies: Required for basic functions like login and security (can't be disabled)
- Performance Cookies: Help us understand usage patterns and improve the platform
- Functional Cookies: Remember your preferences and settings
- Marketing Cookies: Track effectiveness of campaigns (only with your consent)
You'll see a cookie notice on your first visit where you can accept or reject non-essential cookies. You can change your mind anytime through your account settings.
Children's Privacy
Our services are designed for adults aged 18 and over. We don't knowingly collect information from children under 16 without parental consent. If you believe we've accidentally collected data from a child, contact us immediately and we'll delete it.
Changes to This Policy
We may update this privacy policy occasionally to reflect changes in our practices, services, or legal requirements. When we make significant changes, we'll notify you by email and display a prominent notice on our platform.
The "Last Updated" date at the top shows when changes were made. Continued use of our services after changes take effect means you accept the updated policy.
Complaints and Regulatory Contact
If you're not satisfied with how we've handled your data or responded to your rights requests, you can lodge a complaint with Ireland's data protection authority:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28
Ireland
Phone: +353 57 868 4800
Email: info@dataprotection.ie
We'd prefer to resolve concerns directly, so please contact us first before escalating to the regulator.
Questions About Privacy?
If you have questions about this policy or how we handle your data, we're here to help. Our team aims to respond to privacy inquiries within 48 hours.