Privacy Policy
Last updated: 28 October 2026
This policy explains what personal data Teorei Academy collects, why it collects it, how long it keeps it and what rights you have. It applies to the website teorei.com, “My profile”, the TEOREI app, the online courses, the library, the certificates and the newsletter.
We write it in plain language. If anything is unclear, write to us at info@teorei.com.
1. Who we are
Data controller:
- Divine Touch, trading as Teorei Academy (Teorei Academy)
- KvK (Netherlands Chamber of Commerce): 80693474
- Address: Bos en Lommerplantsoen 5, Amsterdam, the Netherlands
- E-mail for personal data questions: info@teorei.com
Live trainings take place in Sofia, Bulgaria (in Bulgarian) and in Amsterdam (in English).
2. What data we collect and why
We collect only the data needed for a specific service. Each service is described separately below.
2.1. Visiting the website
| What | Why | Legal basis |
|---|---|---|
| Technical data: IP address, browser, pages visited | For the website to work, to protect it from abuse, anonymous visit statistics | Legitimate interest; for statistics – consent (see section 7 “Cookies”) |
The IP address is used temporarily to protect against too many requests and is deleted automatically after minutes.
2.2. “My profile” and the TEOREI app
| What | Why | Legal basis |
|---|---|---|
| E-mail, name, name in Latin letters | Login and profile; the name in Latin letters is for the certificate | Contract |
| Phone, photo (optional) | Only if you add them yourself | Consent |
| Password | Login. We store it only encrypted (hashed) – nobody, including us, can read it | Contract |
| Passwordless login key (passkey), if you turn it on | More secure login | Contract |
| When you last logged in, active sessions | Account security | Legitimate interest |
| Settings (notifications, text size, etc.) | To work the way you have chosen | Contract |
2.3. Certificates and register
| What | Why | Legal basis |
|---|---|---|
| Name (in Cyrillic and Latin letters), e-mail, training, level, date and city of the training, teacher, serial number, training hours | Issuing the certificate and entering it in the Academy’s register | Contract |
| Data from an old certificate (number, year, level) | Renewing an old certificate at your request | Your request (contract) |
Checking by QR code. Every certificate has a QR code. Anyone who scans the code sees: the holder’s name, the training, the level, the date, the hours and whether the homework has been completed. Your e-mail and other data are not shown. The aim is that anyone you show your certificate to can make sure it is genuine (legitimate interest of the Academy and of the holder).
Training lists. Before a live training we may ask you to fill in your certificate details in a short form. This data is used only for the certificate.
2.4. Homework after a training
After a live training you can keep your homework in “My profile”: days of practice, duration, how you felt (scale 1–10), sessions with other people, described cases, reflection, questions to the teacher and weekly check-ins.
| What | Why | Legal basis |
|---|---|---|
| The entries above | To follow your progress; for the Academy to review and accept the practice; accepted practice is shown when the certificate is checked | Contract (part of the training) |
Homework is personal. Therefore:
- only you and the Academy (the teacher who reviews it) can see it – it is not shared with anyone;
- for the people you practise with, write only initials (e.g. “M.P.”) – never a full name, phone number or health details;
- you can ask for them to be deleted at any time.
2.5. Online courses
| What | Why | Legal basis |
|---|---|---|
| Course enrolment, access period, lesson progress, homework, questions to the teacher, date of the distance attunement | For you to study the course and receive a certificate | Contract |
2.6. Purchases (online courses, library, teacher membership)
| What | Why | Legal basis |
|---|---|---|
| E-mail, name, product, amount, order number, payment status, date you accepted the terms | For you to receive the product and access to it | Contract |
| The same data after the purchase | Accounting and taxes | Legal obligation |
Your card details never reach us. Payment takes place on the secure page of SumUp, which processes them under its own rules.
When you buy digital content (an online course, materials) you agree that access starts immediately, and you therefore lose the 14-day right of withdrawal. We keep a record of when you agreed to this.
2.7. Newsletter and e-mail notifications
| What | Why | Legal basis |
|---|---|---|
| E-mail, name (optional), where you subscribed, topics (tags), text and date of consent | To send you news, invitations and useful practices | Consent |
| Which e-mails you received, whether you opened them and which links you clicked | To know which topics are useful and not to send unnecessary e-mails | Consent (the same) |
- When you subscribe on the website you receive a confirmation e-mail – without it we do not send you the newsletter.
- Every e-mail contains a one-click unsubscribe link. After unsubscribing we no longer send you the newsletter, even if your e-mail is also in your profile or on your certificate.
- E-mails about your certificate, login and e-mail confirmation are not newsletters – they are part of the service and are sent without a subscription.
2.8. “Notify me” (waiting list)
| What | Why | Legal basis |
|---|---|---|
| Name, e-mail, the training or product you ask about | To write to you when there is a date or the product becomes available | Consent |
2.9. Surveys after a training
| What | Why | Legal basis |
|---|---|---|
| Your answers, name (optional) | To improve the trainings | Consent |
Your review is published on the website only if you tick yourself, that you allow it, and only with the name you wrote.
2.10. Notifications on your phone or computer
| What | Why | Legal basis |
|---|---|---|
| Technical address of the device for notifications, browser type, which types of notifications you turned on | To send you the notifications you have chosen (e.g. a homework reminder) | Consent |
You can turn them off at any time in “My profile” → “Notifications” or in your phone settings.
2.11. Questions to the Academy and “Academy Assistant”
| What | Why | Legal basis |
|---|---|---|
| Your questions and the answers in “My profile” | To answer you | Contract |
2.12. Sharing a completed level
If you create a “Certified” picture to share it, it is stored on our server and has a public link. You can delete it from “My profile” at any time.
2.13. Teachers and practitioners of the Academy
| What | Why | Legal basis |
|---|---|---|
| Name, e-mail, phone, teacher certificates, membership and payments | Teacher membership and teacher portal | Contract |
| Name, photo, city, methods, short introduction – only if you choose to show them | Public profile on the website | Consent |
2.14. Music
Plays are counted anonymously (which recording, when), without knowing who is listening. The aim is to know which recordings are most useful.
2.15. Contact forms
When you write to us through the website form: your name, e-mail and message, so that we can answer you (legitimate interest / your request).
3. Who we share data with
We do not sell your data or give it to others for their advertising.
The data is processed by technical providers who work for us under contract and only on our instructions:
| Provider | Purpose | Where |
|---|---|---|
| Cloudflare | The system server, the database, the files (certificates, quick guides, photos) | EU and USA |
| Google (Gmail / Google Workspace) | Sending the e-mails from info@teorei.com | EU and USA |
| Tilda Publishing | The website pages, contact forms, visit statistics | EU and others |
| SumUp | Card payments | EU |
| Notification services of the browser (Google, Apple, Mozilla) | Delivering notifications to your device | EU and USA |
| YouTube (Google) | Videos embedded in the website | EU and USA |
| Google Maps | The map on the “Contact” page | EU and USA |
| Google Fonts | The website fonts | EU and USA |
The Academy’s entire system (profiles, certificate register, purchases, newsletter, files) runs on Cloudflare – we do not use other cloud storage services.
When data is transferred outside the EU (e.g. to the USA), this happens under protected rules: the EU–US Data Privacy Framework framework or the European Commission’s standard contractual clauses.
The Academy’s teachers. The teacher who led your training sees the data needed for the certificate (name, e-mail, training, level), and your homework when reviewing it.
By law. We may provide data to a public authority only if the law requires it.
4. How long we keep data
The general rule: we keep your data until you ask us to delete it (see section 5). The exceptions are below.
| Data | Retention |
|---|---|
| Certificate register | No time limit – so that your certificate can always be checked. It is deleted (anonymised) only at your request |
| Homework and statistics | No time limit, until you ask for deletion |
| “My profile” | As long as you use it. If you do not log in for 3 years, the profile is deleted automatically. Before that we write to you: after 1 year and after 2 years without logging in, and a final warning 30 days before deletion. Logging in once is enough to keep the profile. Certificates, homework and purchases remain and reappear if you later create a profile with the same e-mail |
| Purchases and payments | 7 years (obligation under Dutch tax law) – also after a deletion request, but without your name and e-mail |
| Newsletter | Until you unsubscribe |
| “Notify me” | Until you ask for deletion |
| Login sessions, login codes | Deleted automatically when they expire |
| Abuse protection (IP) | Minutes – deleted automatically |
| Device notifications | Until turned off, or when the device stops accepting them |
| System backups | Kept for 30 days, then deleted automatically. Deleted data also disappears from them within 30 days |
5. Your rights
You have the right:
- of access – to find out what data we keep about you;
- to rectification – you change most data yourself in “My profile”; for the name on the certificate, write to us;
- to erasure (“to be forgotten”) – the request is made from “My profile” → “Data” or by writing to us;
- to restriction of processing;
- to data portability – you download your data in a file yourself from “My profile” → “Data”;
- to object to processing based on legitimate interest;
- to withdraw your consent at any time – for example by unsubscribing from the newsletter or turning off notifications. This does not affect what was done before the withdrawal.
What happens on deletion at your request. We delete the profile (“My profile”, online courses, questions, photo, notifications), homework, newsletter, requests and e-mails waiting to be sent. Your name and e-mail are removed from the certificate register and from the system log.
- The certificate. The serial number stays in the register so that it cannot be given to someone else or forged. It is no longer linked to you: the QR check shows that the certificate exists, but without a name. Therefore, after deletion you cannot prove your certificate through us – think about this before asking for deletion.
- Purchases. They remain for accounting until the end of the legal period of 7 years, but without your name and e-mail.
Deletion is final and cannot be undone.
We answer your request within one month. Write to info@teorei.com.
Complaint. You can file a complaint with the Dutch supervisory authority Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl) or with the authority in the country where you live – in Bulgaria this is the Commission for Personal Data Protection (cpdp.bg).
6. Security
- All traffic is encrypted (HTTPS).
- Passwords are stored only hashed.
- Quick guides and other paid materials are private files with temporary links, available only to people with access.
- Access to the manager is only for the owner and for helpers with explicitly granted rights, each only to their own sections.
- Paid content in the app opens in a secure window.
7. Cookies and browser storage
| Type | Purpose | Consent needed? |
|---|---|---|
| Necessary | Login to “My profile” (kept in browser storage), form protection, remembering your cookie choice | No – the website does not work without them |
| Settings | Text size, music settings, closed messages | No – only for your convenience, they stay in your browser |
| Statistics | Anonymous visit statistics (Tilda) | Yes |
| Embedded content | YouTube videos, Google Maps map, fonts | These services may set their own cookies when they load |
You can change your choice at any time from the cookie banner or in your browser settings.
8. Children
The trainings, the profile and purchases are only for people over 18. We do not knowingly collect data from minors. If we learn that we hold such data, we delete it.
9. Automated decisions
We do not make automated decisions that have legal effects for you. The “Which training is right for me?” test only gives advice and does not keep your answers.
10. Changes to this policy
When we change the policy, we update the date at the top. For significant changes we will notify you by e-mail or in “My profile”.