Privacy Policy

Effective date: [INSERT DATE]

Last updated: [INSERT DATE]

This Privacy Policy explains how Reconnective Academy International SAGL
(“Reconnective Academy International”, “we”, “us”, “our”) collects, uses,
stores, shares and otherwise processes personal data in connection with
www.reconnectiveacademy.com, related websites, landing pages,
registration forms, events, courses, newsletters, digital products, bookings,
communications and associated services (collectively, the “Services”).

We are committed to processing personal data in accordance with applicable
Swiss data protection law, including the revised Swiss Federal Act on Data Protection
(“FADP”), and, where applicable, the EU General Data Protection Regulation (“GDPR”).

1. Data Controller

The controller responsible for the processing of personal data described in this Privacy Policy is:

Reconnective Academy International SAGL
Viale Serfontana 2/A6834 Morbio Inferiore, Switzerland
Email: info@reconnectiveacademy.com
Phone: +393401784206
Company registration / UID number: CHE-478.564.555

If we are required to appoint an EU representative under Article 27 GDPR,
its details will be published here:

EU Representative (if applicable):
GUGLIELMO POLI / VIALE SERFONTANA 2/A MORBIO INFERIORE – SWITZERLAND / GUGLIELMO@RECONNECTIEVACADEMY.COM

2. Categories of Personal Data We Collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

Identity data, such as first name, last name, title and language preferences;
Contact data, such as email address, telephone number, postal address and billing address;
Account, registration and booking data, such as course registrations, attendance records, purchased services, invoices and payment status;
Communication data, such as messages sent through contact forms, email correspondence, customer support requests and event inquiries;
Technical and usage data, such as IP address, browser type, device information, operating system, referring URLs, pages viewed, access times, logs and basic interaction data;
Cookie and tracking data, where applicable, including information collected through cookies, pixels, tags or similar technologies;
Marketing and newsletter data, such as subscription status, consent records, campaign engagement, email opens and clicks where lawfully tracked;
Transaction data, such as order details, purchased products or services, currency, taxes, payment method metadata and billing information;
Event and participation data, such as registrations for courses, webinars, trainings, retreats, online events or in-person events;
Media or content you voluntarily provide, such as testimonials, profile images, comments, recordings or user-submitted content;
Sensitive data or special category data only where you voluntarily choose to provide it and where processing is lawful, necessary and appropriate, for example information disclosed by you in connection with support requests, accessibility needs, or personal inquiries. We ask that you do not send health-related or otherwise sensitive personal data unless it is strictly necessary.

3. How We Collect Personal Data

We may collect personal data in the following ways:

directly from you when you fill in forms, register for courses, subscribe to newsletters, make purchases, request information or contact us;
automatically when you browse our website or use our Services;
from service providers that support our website, analytics, communications, payments, bookings or customer management;
from publicly available sources or social media pages when relevant to a legitimate inquiry or business relationship;
from third parties acting at your request or with your authorization.

4. Purposes of Processing

We process personal data for the following purposes:

to operate, maintain and secure our website and Services;
to respond to inquiries, requests and communications;
to process registrations, bookings, purchases and payments;
to deliver courses, events, webinars, sessions, digital products and related services;
to provide administrative communications, confirmations, invoices, service messages and updates;
to manage customer relationships and provide support;
to send newsletters, marketing communications and promotional content where permitted by law or based on your consent;
to improve our website, offerings, user experience and business operations;
to perform analytics, reporting and audience measurement;
to prevent fraud, misuse, unauthorized access and other unlawful activity;
to comply with legal, regulatory, tax, accounting and contractual obligations;
to establish, exercise or defend legal claims.

5. Legal Bases for Processing

Where the GDPR applies, we process personal data on one or more of the following legal bases:

Performance of a contract or steps prior to entering into a contract, for example when processing bookings, registrations, purchases or service requests;
Consent, for example where you subscribe to marketing communications or consent to non-essential cookies;
Legitimate interests, for example to operate and improve our Services, ensure security, communicate with customers, analyze performance and protect our business;
Compliance with legal obligations, for example accounting, record-keeping, tax, anti-fraud or regulatory obligations;
Establishment, exercise or defense of legal claims.

Where Swiss law applies, we process personal data for the purposes described in this Privacy Policy
in accordance with the FADP and any other applicable legal basis or justification recognized under Swiss law.

6. Cookies and Similar Technologies

We may use cookies, pixels, tags, scripts and similar technologies to ensure website functionality,
remember preferences, measure traffic, understand user behavior, improve performance and, where applicable,
support marketing or advertising activities.

Cookies may include:

Strictly necessary cookies, required for the functioning, security and core operation of the website;
Preferences or functional cookies, used to remember settings and improve user experience;
Analytics cookies, used to understand website usage and improve services;
Marketing cookies, used to measure campaigns or personalize communications where applicable.

Non-essential cookies and similar technologies will be used only in accordance with applicable law and,
where required, on the basis of your prior consent. You can manage your cookie preferences through our cookie banner
and, to a certain extent, through your browser settings.

For more detailed information, please see our Cookie Policy
or cookie settings tool, if available.

7. Contact Forms, Email and Communications

When you contact us through a contact form, email, event registration form, application form or similar tool,
we process the information you provide in order to respond to your request, manage the relationship,
provide the requested services and keep records of the communication.

The data processed may include your name, email address, phone number, country, language,
event of interest and any information contained in your message.

8. Newsletter and Marketing Communications

If you subscribe to our newsletter or otherwise consent to receive promotional communications,
we may process your contact data and communication preferences in order to send you updates,
educational content, event invitations, offers and news about our activities.

You can withdraw your consent or unsubscribe at any time by using the unsubscribe link included in our emails
or by contacting us at info@reconnectiveacademy.com.

We may use email service providers and customer relationship management tools to manage subscriber lists,
campaigns, segmentation and delivery.

9. Payments, Orders and Bookings

If you purchase products or services, register for a course or event, or submit a booking request,
we process the personal data necessary to manage the transaction, issue invoices, administer the booking,
verify payment status and provide the requested service.

Payments may be processed by third-party payment service providers. We do not store full payment card numbers
on our own servers unless expressly stated otherwise. Payment providers process payment data under their own legal responsibilities and privacy terms.

Relevant providers may include, where used: [Stripe], [PayPal], [banking/payment partners],
[event or checkout platforms].

10. Analytics, Embedded Content and Third-Party Services

We may use third-party services to host content, measure traffic, embed media, manage events,
process payments, send communications, schedule bookings, or improve website performance.

Depending on the actual tools used on the website, such services may include:

website hosting and CDN providers;
analytics providers such as [Google Analytics / GA4];
video and embedded content providers such as [YouTube / Vimeo];
maps providers such as [Google Maps];
email marketing and CRM providers such as [Brevo / Mailchimp / other];
form, automation or scheduling providers;
social media plugins, integrations or links;
event and ticketing platforms.

Such third parties may process technical data, usage data, identifiers and other information
in accordance with their own privacy notices and contractual arrangements with us.

11. Recipients and Categories of Recipients

We may disclose personal data to the following categories of recipients where necessary and lawful:

internal personnel and authorized collaborators on a need-to-know basis;
IT, hosting, maintenance and cybersecurity providers;
payment processors, banks and accounting providers;
newsletter, CRM, automation and marketing service providers;
event, course, webinar and booking platform providers;
professional advisers, such as lawyers, accountants, auditors and consultants;
public authorities, courts, regulators or law-enforcement bodies where disclosure is required by law or necessary to protect rights and interests;
potential successors, buyers or counterparties in the context of a corporate transaction, subject to appropriate safeguards.

12. International Data Transfers

Personal data may be processed in Switzerland, the European Economic Area (“EEA”) and, where applicable,
in other countries in which our service providers or their subcontractors operate.

If personal data is transferred to a country that does not provide an adequate level of protection
under applicable Swiss or EU data protection law, we will implement appropriate safeguards,
such as standard contractual clauses, supplementary measures where necessary, or another lawful transfer mechanism.

13. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected,
including for the performance of services, contractual administration, support, accounting, legal compliance,
dispute resolution and the defense of legal claims.

Retention periods may vary depending on the type of data and applicable legal requirements.
In general:

contact requests are retained for as long as necessary to manage the request and any follow-up relationship;
customer, booking and transactional records are retained for the duration of the contractual relationship and thereafter as required by tax, accounting and legal obligations;
newsletter data is retained until you unsubscribe or withdraw consent, subject to records necessary to demonstrate compliance;
technical logs are retained for a limited period, unless needed for security or legal reasons.

14. Data Security

We implement appropriate technical and organizational measures designed to protect personal data
against unauthorized access, loss, misuse, alteration, disclosure or destruction.

However, no website, transmission method or storage system can be guaranteed to be completely secure.
You should therefore also take appropriate precautions when using online services.

15. Your Rights

Subject to the conditions and limitations set by applicable law, you may have the right to:

request information about whether we process your personal data;
access your personal data;
request correction of inaccurate or incomplete personal data;
request deletion of personal data;
request restriction of processing;
object to certain processing, particularly processing based on legitimate interests or direct marketing;
withdraw consent at any time where processing is based on consent;
receive your personal data in a portable format where applicable under the GDPR;
lodge a complaint with a competent supervisory authority.

To exercise your rights, please contact us at
info@reconnectiveacademy.com.
We may request reasonable evidence of identity before responding to a request.

16. Complaints

If you believe that your personal data has been processed unlawfully, you may contact us first
so that we can try to address your concern.

You may also have the right to lodge a complaint with the competent data protection authority,
including, where applicable:

the Swiss Federal Data Protection and Information Commissioner (FDPIC);
an EU/EEA supervisory authority in your place of residence, work, or the place of the alleged infringement.

17. Children’s Data

Our website and Services are not directed to children who are below the age at which they can validly
consent under applicable law. We do not knowingly collect personal data from children without the required
legal basis or authorization. If you believe that a child has provided personal data unlawfully,
please contact us so that we can take appropriate action.

18. Social Media Pages and Public Content

We may maintain social media pages or public profiles on third-party platforms.
If you interact with us on such platforms, the relevant platform provider may process your personal data
under its own privacy terms. We may also process information you publicly share with us or tag us in,
where appropriate for communication, moderation or community management purposes.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, operational or organizational changes.
The updated version will be published on this page with a revised “Last updated” date.

Where required by law, we will take additional steps to inform you of material changes.

20. Contact

If you have any questions about this Privacy Policy or our data processing practices, please contact:

Reconnective Academy International SAGL
Email: info@reconnectiveacademy.com
Address: Viale Serfontana 2/A 6834 Morbio Inferiore
Phone: +393401784206