Privacy Policy

Last Updated: 15th January 2026

Data Controller Information

tormasvile.top B.V. (registration number KvK25963741) is the data controller for personal information processed through our website and services. We are committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Data We Collect

The data we collect includes personal information that you provide directly to us and information that we collect automatically when you use our website. We collect the following types of personal data:

Information You Provide

• Contact information including name, email address, phone number, and organisation details when you fill out our contact forms
• Communication preferences and any other information you choose to provide when contacting us
• Newsletter subscription information including email address and preferences
• Technical support requests and related information

Information We Collect Automatically

• Website usage data including pages visited, time spent on pages, and navigation patterns
• Technical information including IP address, browser type, device information, and operating system
• Cookie and tracking technology data as described in our cookie policy
• Analytics data to understand how our website is used and to improve our services

How We Use Your Information

We use the personal data we collect for the following purposes, based on legitimate business interests, contractual necessity, or your consent:

Service Provision and Communication

How we use your data includes responding to your enquiries, providing information about our student engagement tracking systems, processing service requests, and maintaining ongoing communication about our educational analytics solutions.

• Responding to contact form submissions and enquiries
• Providing information about our services and solutions
• Processing service requests and providing customer support
• Sending newsletters and updates about our services (with your consent)
• Managing our business relationship with you

Website Improvement and Analytics

Use of your data also includes analysing website performance, understanding user behaviour patterns, improving our website functionality, and ensuring the security and proper operation of our digital platforms.

• Analysing website usage to improve user experience
• Understanding visitor behaviour and preferences
• Optimising our website performance and content
• Ensuring website security and preventing fraud

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use, their purposes, and how to manage them, please refer to our comprehensive cookie policy.

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Legitimate Interests: For business communications, website analytics, and service improvement
• Consent: For marketing communications, newsletters, and non-essential cookies
• Contractual Necessity: For providing services you have requested
• Legal Obligation: For compliance with applicable laws and regulations

Data Sharing and Third Parties

We do not sell your personal data to third parties. We may share your information in the following limited circumstances:

• With service providers who assist us in operating our website and providing our services
• With analytics providers such as Google Analytics to understand website usage
• When required by law or to protect our legal rights
• With professional advisers such as lawyers, accountants, and consultants
• In connection with a business transfer, merger, or acquisition

International Data Transfers

We are based in the Netherlands within the European Union. If we transfer your data outside the EU, we ensure appropriate safeguards are in place, including adequacy decisions or standard contractual clauses approved by the European Commission.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. Our data retention periods are as follows:

• Contact form submissions: 3 years from last contact
• Newsletter subscriptions: Until you unsubscribe
• Website analytics data: 26 months (Google Analytics default)
• Cookie consent records: 12 months
• Business correspondence: 7 years for legal and tax purposes

Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we process your data
• Right to Data Portability: Request transfer of your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for processing where applicable

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training on data protection.

Children's Privacy

Our website and services are not directed at children under 16 years of age. We do not knowingly collect personal information from children under 16. If you believe we have collected information from a child under 16, please contact us immediately.

Updates to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date.

Contact Information

If you have any questions about this privacy policy, wish to exercise your rights, or have concerns about how we handle your personal data, please contact us:

Supervisory Authority

You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we have not handled your personal data in accordance with applicable data protection laws.

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ Den Haag
Netherlands
Website: autoriteitpersoonsgegevens.nl