Privacy Policy

1. Who We Are

HerSale Academy is a women's sales training and certification programme operated by Avci Group LLC-FZ, a company registered in the UAE Free Zone.

Data controller: Avci Group LLC-FZ (HerSale Academy)
Contact: info@hersaleacademy.com
Website: hersaleacademy.com

We are committed to handling your personal data with care and in compliance with applicable privacy laws, including the EU General Data Protection Regulation (GDPR) and the UK GDPR, as relevant to our international student base.

2. Information We Collect

We collect personal data in the following categories:

Information you provide directly:

• Identity data: first name, last name.
• Contact data: email address, phone number, WhatsApp number.
• Application data: responses to application questions, including your current employment situation, income, and career goals.
• Payment data: billing information processed through our payment processors. We do not store full card numbers on our own systems.
• Programme data: session attendance records, assignment submissions, coaching notes, and certification progress.
• Communications: emails, messages, and other correspondence you send us.
• Testimonials and media: any written or recorded testimonials, photographs, or video content you share with us or provide consent to use.

Information collected automatically:

• Usage data: pages visited on our website, time spent, links clicked, device type, browser, and operating system.
• IP address and approximate location: collected when you visit our website or register for a programme.
• Cookie data: see Section 6 for full details.
• Advertising data: if you arrive via a paid advertisement, we may receive data from the advertising platform (such as Meta) indicating which ad or audience segment led to your visit.

3. How We Use Your Information

We use the data we collect for the following purposes:

• Programme delivery: to enrol you, give you access to materials, schedule coaching sessions, track certification progress, and manage your account.
• Communication: to send you programme-related emails, reminders, updates, and follow-ups. If you have registered for a free event, to send you information about that event and related HerSale Academy offerings.
• Payment processing: to collect and manage payments via our authorised payment processors.
• Customer support: to respond to your enquiries and resolve issues.
• Marketing: with your consent (or where a legitimate interest applies), to send you information about HerSale Academy programmes, events, and offers. You can opt out at any time.
• Advertising: to run targeted advertising campaigns on platforms including Meta (Facebook and Instagram). This may include creating Custom Audiences from your email address and using your data to serve relevant ads.
• Analytics and improvement: to understand how our website and programmes are performing and to make improvements.
• Legal compliance: to meet our legal and regulatory obligations.
• Community management: to administer community spaces and ensure they are used in line with our Code of Conduct.

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA) and the United Kingdom, we process personal data only where a lawful basis applies:

• Contract performance: processing necessary to deliver the programme you have purchased and to manage your enrolment.
• Legitimate interests: to operate and improve our business, prevent fraud, and send relevant marketing communications where we reasonably believe you would expect to receive them.
• Consent: where we rely on your explicit consent, such as for certain marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legal obligation: where processing is required to comply with applicable law.

5. Data Sharing & Third Parties

We do not sell your personal data. We share data only as necessary to operate our business, with the following categories of third parties:

• Payment processors: Stripe and/or other authorised payment providers to process your purchase securely. They have their own privacy policies and security obligations.
• Email service providers: platforms used to send transactional and marketing emails on our behalf (including Resend and GoHighLevel). These providers process your email address and name solely to deliver communications.
• Advertising platforms: Meta (Facebook/Instagram) and similar platforms, for the purposes of running targeted advertising. Data shared may include email addresses in hashed form to create Custom Audiences.
• Analytics providers: tools such as Google Analytics that help us understand website traffic and user behaviour. These providers may set cookies on your device.
• Calendar and scheduling tools: Calendly or similar platforms used to book coaching sessions. Your name and email are shared with these tools when you make a booking.
• CRM platforms: customer relationship management tools used to manage student records and communications.
• Video hosting platforms: providers used to host and stream programme content and live events (such as StreamYard or Zoom).
• Legal and compliance: we may disclose your data if required to do so by law, court order, or government authority.

All third-party service providers are contractually required to protect your data and use it only for the purposes for which we have shared it.

6. Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies. Cookies are small files stored on your device that help us operate the website and understand how it is used.

We use the following types of cookies:

• Essential cookies: required for the website to function (for example, to process form submissions). These cannot be disabled.
• Analytics cookies: help us understand how visitors interact with our website (pages visited, time spent, traffic sources). We use Google Analytics for this purpose. You can opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout.
• Advertising cookies: placed by platforms such as Meta to track conversions from our advertising campaigns and enable audience targeting. The Meta Pixel on our site sends event data (page views, registrations, purchases) to Meta.

7. Data Retention

We retain your personal data only as long as necessary for the purposes for which it was collected:

• Enrolled students: your account data is retained for the duration of your enrolment and for a period of up to 7 years thereafter, to comply with our contractual and legal obligations.
• Event registrants (non-students): contact data is retained for up to 24 months from the date of registration, or until you unsubscribe from communications.
• Applicants who did not enrol: application data is retained for up to 12 months from the date of application.
• Financial records: payment data is retained for 7 years to meet accounting and tax obligations.
• Marketing communications: email addresses are retained on our list until you unsubscribe or request deletion.

When data is no longer needed, it is securely deleted or anonymised.

8. Your Privacy Rights

Depending on where you are located, you may have the following rights regarding your personal data:

To exercise any of these rights, email info@hersaleacademy.com with your request. We will respond within 30 days. We may need to verify your identity before processing your request.

If you are located in the EEA or UK and believe we are processing your data unlawfully, you have the right to lodge a complaint with your local data protection authority.

9. International Data Transfers

HerSale Academy operates internationally and serves students across Europe, the Middle East, and beyond. Your data may be transferred to and processed in countries outside your country of residence, including the UAE and the United States (via our service providers).

Where data is transferred from the EEA or UK to countries that do not have an equivalent level of data protection, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission or the UK Information Commissioner's Office.

10. Children's Privacy

HerSale Academy's programmes are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected data from a minor without parental consent, we will delete it promptly. If you believe a minor has submitted data to us, please contact info@hersaleacademy.com.

11. Security

We take the security of your personal data seriously. We implement reasonable technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These include:

• Encrypted connections (HTTPS) on all web properties.
• Access controls limiting who can view personal data within our team.
• Use of reputable, security-certified third-party platforms for payment processing and data storage.

No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately at info@hersaleacademy.com.

12. Links to Other Websites

Our website and programme materials may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We encourage you to review the privacy policy of any website you visit via a link from our platforms.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The "Last Updated" date at the top of this page will always show when the most recent revision was made.

For significant changes that affect how we process your data, we will notify enrolled students by email. Your continued use of our website or services following any update constitutes your acceptance of the revised Policy.

14. Contact Us

For any privacy-related questions, data requests, or concerns, please get in touch:

HerSale Academy — Avci Group LLC-FZ
Email: info@hersaleacademy.com
Website: hersaleacademy.com

We aim to respond to all privacy enquiries within 30 days.