Toedur Privacy Policy

1. Introduction

This Privacy Policy applies to the services provided by Toedur through our platform and website. By using our services, you agree to the collection, processing, and use of your personal data as outlined in this policy. It is important that you read and understand this policy before committing to the processing of your data. We will update this Privacy Policy from time to time, so please regularly check for updates.

2. What is Personal Data?

Personal data refers to any information that can identify you directly or indirectly. Examples include your name, email, phone number, and other contact information. Processing refers to various actions such as collecting, storing, and using that data. Personal data can also include online identifiers, such as your IP address, cookies, and device information.

3. Lawful Basis for Processing

Toedur processes personal data under several legal grounds:

• Consent: When you subscribe to newsletters, create an account, or accept cookies we have consent based, you explicitly consent to the processing of your data for specific purposes such as receiving updates, personalized services, or tracking user behavior for analytics.
• Contractual Obligation: When you use our services, we process your data to fulfill our contractual commitments, such as providing consultation services.
• Legitimate Interest: Toedur may process your data for purposes such as improving the platform, ensuring compliance with regulations, fraud prevention, and business analysis.

4. Data We Collect

The type of personal data collected depends on how you interact with Toedur:

• Account Information: Name, email, and login details are required to create an account. Optional information includes phone numbers or profile pictures.
• Usage Information: We collect information such as device type, IP address, browser type, and language preferences through cookies and tracking technologies. This data helps us enhance user experience and improve our services.
• Payment Information: We collect payment details, such as credit card or PayPal information, to process transactions through secure third-party services like Stripe.
• Cookies: We use cookies to track user behavior, store preferences, and improve the platform. You can manage your cookie preferences through the cookie consent banner or your browser settings:
  • Essential Cookies: Necessary for the core functions of the website.
  • Performance/Analytics Cookies: Used to measure how the site is used, through Google Analytics and Microsoft Clarity (session recordings), and to remember for 30 days which site or campaign first brought you here (our own toedur_attribution cookie). Set only with your consent.
  • Marketing Cookies: Used to deliver personalized ads through third-party services like Facebook Pixel and Google Ads.

5. How We Use Your Data

Toedur uses your personal data for various purposes, including:

• Service Provision: To create and manage your account, facilitate consultations, and process payments.
• Marketing: With your consent, we may send promotional or informational material about Toedur services. You can opt out at any time.
• Personalization: To tailor the content and services we provide based on your preferences and behavior.
• Analytics: To understand how the site is used and improve it, through Google Analytics and Microsoft Clarity (session recordings in which typed text and messages are masked). Only with your consent.
• How you found us: When you register, join the waitlist or book a free intro call, we store with your entry the page you first landed on, the site that referred you and any campaign codes in the address (utm parameters, ad click ids). For the intro call, the campaign codes travel in the booking link to Calendly, our scheduling provider, and are stored with your booking — only if you have accepted performance cookies. Legal basis: our legitimate interest in knowing which channels bring students to Toedur (GDPR Art. 6(1)(f), KVKK Art. 5(2)(f)). It is deleted together with your account, waitlist entry or booking record and is not used for profiling.

6. How We Share Your Data

We share your data with third parties only under the following circumstances:

• Payment Processors: Data is shared with third-party payment providers (e.g., PayPal, Stripe) to facilitate secure transactions.
• Marketing and Analytics: To track user behavior and improve our services, we may share anonymized data with platforms like Google Analytics, Facebook Pixel, and LinkedIn Insight Tag.
• Legal Compliance: We may disclose personal data if required by law. In the event of a legal investigation or to comply with data protection regulations.
• Third-Party Cookies and Data Sharing: We may share your anonymized or personal data with third-party service providers for analytics, advertising, and personalization purposes. These services include:
  • Google Tag Manager: Loads and controls the services listed here. It runs nothing until you have given consent.
  • Google Analytics: For tracking user behavior and performance metrics. Event-level data is deleted automatically 14 months after it is collected; aggregated reports that do not identify you may be kept longer.
  • Microsoft Clarity: Session recordings and heatmaps showing how pages are used. Typed text and messages are masked before anything leaves your browser. Only with your performance/analytics consent, Clarity sets two first-party cookies on our site, toedur.com: _clck, which keeps a random visitor ID so that your visits can be grouped together (up to 1 year), and _clsk, which joins your page views into one session recording (1 day). It sets no advertising identifier and is given no account identifier, so a recording is not linked to your account. Clarity could previously also leave an advertising cookie from Microsoft (MUID) on Microsoft’s own domain, clarity.ms; we have since blocked this. If you accepted these cookies before the block, that cookie may still be in your browser, and we cannot delete a cookie on another company’s domain: until it expires (at most one year after it was set), some browsers may send it along with Clarity recordings. You can remove it yourself by deleting the cookies for clarity.ms in your browser settings. Microsoft keeps recordings for 30 days (a small random sample for up to 9 months). Processed by Microsoft in the USA under Standard Contractual Clauses.
  • Facebook Pixel: For personalized advertising on Facebook and Instagram.
  • International Transfers: If your data is transferred outside the European Economic Area (EEA), we ensure compliance with GDPR through Standard Contractual Clauses (SCCs) or other safeguards.

7. Data Retention

Your personal data will be retained for as long as necessary to fulfill the purposes for which it was collected. Account data is stored until you choose to delete your account. Afterward, we retain necessary data only to comply with legal obligations or resolve disputes.

Cookie Retention: Session cookies expire when you close your browser, while persistent cookies (e.g., for marketing or analytics) may remain active for up to two years unless manually deleted.

8. Your Rights

As a user, you have the following rights:

• Access: Request access to your personal data and how it is processed.
• Rectification: Request correction of any incorrect or outdated data.
• Erasure: Request the deletion of your personal data ("right to be forgotten").
• Portability: Request your data in a structured, commonly used format for transfer to another provider.
• Object: Object to certain types of data processing.

To exercise these rights, contact us at support@toedur.com.

9. Cookies and Tracking

We use cookies to track user behavior on our website and improve the user experience. You can manage your cookie preferences through the cookie consent banner when you first visit the website, or adjust them at any time via the cookie settings page or your browser settings.

Types of Cookies We Use:

• Essential Cookies: Required for the website to function properly.
• Performance Cookies: Used for tracking user behavior through Google Analytics and similar tools.
• Marketing Cookies: Used for personalized ads through services like Facebook Pixel and Google Ads.

10. Security

We implement robust technical and organizational measures to ensure the security of your data. All sensitive data, including payment information, is encrypted and stored securely.

11. Children's Privacy

Toedur's services are not directed at children under the age of 16. If we become aware that we have inadvertently collected personal data from a child under the age of 16 without verified parental consent, we will delete that information immediately.

12. Updates to This Policy

We may update this policy occasionally. Any changes will be posted on our website, and we will notify you via email if they are substantial.

13. Contact Us

For questions regarding this Privacy Policy, your data, or exercising your rights, please contact our Data Protection Officer at support@toedur.com.