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Privacy Policy
Last Updated: March 12, 2026
1. Introduction & Controller Identity
This Privacy Policy explains how steglvarx (“we”, “us”, “our”) collects, uses, and protects personal data when you visit this website and when you submit information through our registration or contact forms. The site promotes an online course that teaches how to source, market, and sell cosplay accessories and costume-related products. This policy applies to visitors, prospective learners, and anyone who communicates with us via the site.
Data Controller: Steglvarx Education Ltd, Neklanova 145/14, Vyšehrad, 128 00 Praha 2, Czechia. You can contact us about privacy at [email protected] or by phone at +420 224 210 496.
Effective Date: March 12, 2026. If we materially change how we handle personal data, we will update this page and, where appropriate, provide additional notice on the website.
2. Personal Data We Collect
We collect only the data we need to operate this website, respond to requests, and improve the course information we provide. The categories below may apply depending on how you use the site:
- Identity and contact information: such as your name (if provided), email address, and any details you include in a message.
- Form content: information you submit in free-text fields (for example, product categories, sourcing constraints, target price ranges, or where you plan to sell).
- Technical data: IP address, browser type and version, device type, operating system, language settings, and approximate location derived from IP (country/city level).
- Usage data: pages visited, time spent on pages, referral source, and click paths (for example, whether a visitor read the curriculum page after pricing).
- Cookies and identifiers: values stored in your browser for session continuity and consent choices, plus third-party cookie identifiers when you opt into analytics or marketing cookies.
- Conversion events: event signals such as form submissions, which help us understand whether the site is functioning and which content is useful.
We do not intentionally collect special-category data (such as health data, religious or political beliefs), financial account details, or government identification numbers through this site. Please do not include sensitive personal information in message fields.
3. Why We Process Personal Data & Legal Basis (GDPR Art. 6)
We process personal data for specific purposes and rely on a legal basis under GDPR/UK GDPR where applicable:
- Contact and registration requests: We use your details to respond and provide course access or scheduling information. Legal basis: Art. 6(1)(b) (steps at your request prior to entering a contract) and Art. 6(1)(a) (consent) where required by local law for certain communications.
- Analytics: To understand how the site is used and improve content and performance. Legal basis: Art. 6(1)(a) consent.
- Marketing/remarketing: To measure advertising performance and show relevant promotions to people who opted in. Legal basis: Art. 6(1)(a) consent.
- Security and fraud prevention: To protect the site, prevent abuse, and maintain availability. Legal basis: Art. 6(1)(f) legitimate interests.
- Legal compliance: To comply with applicable laws and respond to lawful requests. Legal basis: Art. 6(1)(c) legal obligation.
Automated decision-making (Art. 22): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects. Any advertising audiences are used for measurement and relevance, not eligibility decisions.
4. Cookies & Tracking Technologies
Cookies are small text files stored on your device. We also use similar technologies such as pixel tags. You can learn more in our Cookie Policy. On this site we organize cookies into three categories:
Essential (always active)
Essential cookies are required for core functionality, such as maintaining basic session continuity and storing your cookie consent choice. These cookies do not require consent under many privacy frameworks because the site cannot operate properly without them. Retention ranges from session-only to 12 months depending on the cookie.
Analytics (consent)
If you opt in, we may use Google Analytics 4 to understand general usage patterns (for example, which pages are read most, and whether users find the curriculum section before registering). Where available, IP anonymization is used. Analytics cookie retention is typically up to 2 years for identifiers, with analytics data retention set to 14 months.
Marketing (consent)
If you opt in, marketing cookies help measure ad performance and support remarketing. This can include Google Ads conversion measurement and Meta Pixel identifiers. These technologies may record that a browser visited a page or completed a form, and may support building audiences such as “site visitors” for future promotions.
Beyond cookies, some providers use signals such as IP address and User-Agent to understand device characteristics. Where server-side tracking is used in the future (for example, Meta Conversion API or server-side tag management), identifiers may be hashed before transmission when appropriate.
5. Consent (EEA/UK)
Users in the EEA and UK receive a consent notice under GDPR/UK GDPR. Analytics and marketing cookies activate only after explicit, informed, freely given consent (Art. 6(1)(a)). Your choice is recorded in the cookie_consent browser cookie (up to 12 months). You can withdraw consent at any time by using “Manage cookie preferences” in the footer or by clearing your browser cookies.
Withdrawal of consent does not affect the lawfulness of processing based on consent before it was withdrawn.
6. Sharing With Advertising & Service Partners
We use a small set of service providers to operate and improve this website. Depending on your cookie choices and your interactions, we may share limited data with:
- Google LLC (Google Analytics 4, Google Ads, Google Tag Manager, remarketing): cookie IDs, usage data, and conversion events. Privacy: https://policies.google.com/privacy
- Meta Platforms, Inc. (Meta Pixel, Custom/Lookalike Audiences, Conversion API where enabled): page views, conversions, and cookie identifiers when you consent. Privacy: https://www.facebook.com/privacy/policy
- Cloudflare (CDN and security): IP-based threat detection and performance optimization. Privacy: https://www.cloudflare.com/privacypolicy/
We do not sell personal data. These providers act as service providers/processors and are not permitted to use site data for their own independent commercial purposes outside the services they provide to us.
7. International Transfers
Some providers may process data outside the EEA/UK, including in the United States. Where applicable, transfers rely on the EU–US Data Privacy Framework (DPF) and the UK Extension to the DPF (and the Swiss–US DPF where relevant). If a transfer cannot rely on the DPF, we use Standard Contractual Clauses (EU 2021/914) and UK International Data Transfer Agreement (IDTA) as fallback mechanisms.
We also apply practical safeguards such as limiting what we share, enabling privacy settings where available, and using consent-based activation for analytics and marketing technologies.
8. Data Retention
We retain personal data only as long as needed for the purposes described above:
- Contact and registration submissions: up to 2 years from last interaction, unless you request deletion earlier or legal obligations apply.
- Analytics data: 14 months (settings-based), with cookie lifetimes as described in the cookie sections.
- Marketing cookies: retained according to cookie lifetimes (often 90 days) unless cleared sooner.
- Email correspondence: for the duration of a relationship plus up to 1 year for continuity and record-keeping.
- Server logs: typically up to 90 days for security and diagnostics.
- Cookie consent record: up to 3 years for audit and compliance evidence.
- Legal and tax records: retained as required by law (often 6–10 years for invoicing records where applicable).
9. Your Rights (GDPR & UK GDPR)
Depending on your location, you may have rights regarding your personal data, including:
- Right of access (Art. 15)
- Right to rectification (Art. 16)
- Right to erasure (Art. 17)
- Right to restriction of processing (Art. 18)
- Right to data portability (Art. 20)
- Right to object (Art. 21)
- Right to withdraw consent at any time (Art. 7(3))
- Right to lodge a complaint with a supervisory authority (Art. 77)
To exercise your rights, email [email protected]. We respond within 30 days, with an extension of up to 60 additional days for complex requests. We may ask for reasonable verification to protect your data.
Supervisory authority references: EU guidance via https://edpb.europa.eu. UK authority: https://ico.org.uk. France: https://www.cnil.fr. Germany: https://www.bfdi.bund.de. Spain: https://www.aepd.es. Poland: https://uodo.gov.pl.
10. Children
This site is not directed at individuals under 16. We do not knowingly collect personal data from minors. If you believe a child under 16 has provided personal data without verifiable parental consent, please contact us and we will delete the information promptly.
11. Do Not Track
This website does not respond to “Do Not Track” (DNT) browser signals. Third-party providers may have their own handling of DNT or similar preferences, which is governed by their policies.
12. Data Deletion Requests
You can request deletion of your data by emailing us with the subject line “Data Deletion Request” at [email protected]. We will complete deletion within 30 days after we verify your identity and locate your records. Some data may be retained where required by law or to establish, exercise, or defend legal claims.
13. Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal data may be transferred to a successor entity as part of that transaction. If the transfer materially changes how personal data is used, we will provide notice through the website.
14. California (CCPA/CPRA)
This section describes disclosures for California residents. In the past 12 months, we may have collected the following categories: Identifiers (such as name, email, IP address, and device IDs), Internet or network activity (such as browsing and interactions), and inferences (such as interests based on pages viewed). We may share these categories with service providers and advertising partners for analytics, advertising measurement, and cross-context behavioral advertising where you opt in.
We do not sell personal information as defined by CCPA. We may share information for cross-context behavioral advertising, and California residents may opt out by using our cookie preferences panel available via “Manage cookie preferences” in the footer.
California rights may include: right to know, delete, correct, opt out of sale/sharing, and non-discrimination. To submit a request, email [email protected] with the subject “California Privacy Request.” We may verify your request before completing it. Authorized agents must provide written proof of authorization.
15. Virginia (VCDPA)
Virginia residents may have rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising. To submit a request, email [email protected] with the subject “Virginia Privacy Request.” We do not sell personal data and we do not engage in profiling that produces legal or similarly significant effects.
If we refuse to act on a request, you may appeal by emailing with the subject “Appeal of Refusal — Privacy Request.” We will respond within 60 days. If the appeal is denied, you may contact the Virginia Attorney General.
16. Nevada
Nevada residents may submit a verified opt-out request by emailing [email protected] with the subject “Nevada Do Not Sell Request.” We do not currently sell personal information under Nevada Revised Statutes Chapter 603A.
17. Changes to This Policy
We may update this Privacy Policy from time to time. If changes are material, we will post a prominent notice on the website at least 14 days before the change takes effect. The “Last Updated” date at the top reflects the most recent revision.
18. Contact
For privacy questions, requests, or complaints, contact:
Steglvarx Education Ltd
Neklanova 145/14
Vyšehrad, 128 00 Praha 2, Czechia
Email: [email protected]
Phone: +420 224 210 496