Privacy Policy

1. Introduction & Controller Identity

This Privacy Policy explains how soplvirex (“we”, “us”, “our”) collects, uses, and protects your personal data when you visit our website and interact with our pages, including the registration form and the contact form. Our training is educational and focuses on electric scooter product knowledge and ethical sales communication. We treat privacy as part of that same ethics-first approach.

Data Controller: Soplvirex Training LLC, Nábřežní 78, 407 21 Česká Kamenice, Czechia. You can contact us about privacy matters by email at [email protected]. We do not currently appoint a Data Protection Officer because we do not carry out large-scale processing of sensitive (special-category) data.

Effective Date: March 18, 2026. If we change this Privacy Policy, we will update the “Last Updated” date and, where changes are material, we will provide a clear notice on the website before the changes take effect.

2. Personal Data We Collect

We collect only the information needed to run an educational website and respond to training-related requests. The exact data we collect depends on how you use the site. The categories below describe what we may collect.

• Identity and contact data: name and email address (for example, when you submit the registration form or contact form).
• Form content: any text you choose to send to us if a page includes an open message field in the future. On this site, the registration form requests only name and email.
• Technical data: IP address, browser type and version, device type, operating system, preferred language, and approximate location derived from IP (city/region level, not precise GPS).
• Usage data: pages visited, time spent, navigation paths, referral source, and clicks that help us understand what content is useful (for example, which curriculum topics visitors read most).
• Cookies and identifiers: small files and similar technologies described in Section 4 and our Cookie Policy.
• Conversion events: limited event data that indicates when a visitor completes an action such as submitting a form, which helps us measure whether our educational pages are clear.

We do not intentionally collect special-category data (such as health information, religious beliefs, political opinions), financial account details, or government identification numbers through this website. Please do not include sensitive information in free-text messages if you contact us by email.

3. Why We Process Personal Data & Legal Bases (GDPR Article 6)

We process personal data only when we have a lawful basis under the GDPR (and, where applicable, UK GDPR). The purposes and legal bases we rely on are listed below.

• Responding to registration and contact requests (name and email): we process this to take steps at your request prior to entering into an agreement for training access and scheduling (GDPR Article 6(1)(b)), and we also rely on consent where you provide it via the form checkbox (GDPR Article 6(1)(a)).
• Website analytics (usage patterns, page performance): we process analytics data only where you provide consent through our cookie preferences (GDPR Article 6(1)(a)).
• Marketing and advertising measurement (where enabled): we process marketing/remarketing data only where you provide consent through our cookie preferences (GDPR Article 6(1)(a)).
• Security and fraud prevention (log data, abuse detection): we process this to protect the website and maintain integrity (GDPR Article 6(1)(f) legitimate interests). Our legitimate interest is keeping the website stable and protecting it from automated abuse.
• Legal compliance: if we must retain information to meet legal requirements (GDPR Article 6(1)(c)).

Automated decision-making (GDPR Article 22): we do not engage in automated decision-making or profiling that produces legal or similarly significant effects. Any advertising audiences, if used, are intended for measurement and relevance, not for decisions about eligibility or employment.

4. Cookies & Tracking

We use cookies and similar technologies (including pixel tags and server-side event handling) to keep the website functional, to understand usage, and—only where you consent—to measure marketing performance. Cookies fall into three categories that match our Cookie Policy.

Essential cookies (always active)

These cookies are required for the site to function and cannot be switched off through the cookie preferences tool. They typically include:

• _site_session: helps keep the site consistent during a browsing session.
• cookie_consent: stores your cookie preferences selection so we can respect it.

Retention for essential cookies ranges from session-only to up to 12 months depending on the cookie. We may also use basic security-related mechanisms such as CSRF protection where needed.

Analytics cookies (consent required)

With your consent, we may use Google Analytics 4 (GA4) to understand aggregated site usage. Where configured, IP anonymization is used. Typical GA4 cookie examples include _ga and _ga_XXXXXXXXXX. Analytics data retention is typically set to 14 months. This helps us improve course pages by learning which modules and explanations are most read.

Marketing cookies (consent required)

With your consent, we may use marketing cookies and tags to measure advertising performance and to show more relevant educational messages. Examples include _gcl_au (Google Ads) and _fbp / _fbc (Meta). These cookies support functions such as conversion attribution, remarketing, and audience building. Marketing cookies have lifetimes that commonly range from 90 days to two years depending on the provider’s settings.

Beyond cookies: where enabled, tracking may also occur using pixel tags (for example, a Meta Pixel or Google tag) and/or server-side event forwarding (for example, Meta Conversion API or server-side Google Tag Manager). In those cases, identifiers may include cookie IDs and device signals derived from IP address and user-agent. We do not intentionally collect precise location data.

5. Consent for Analytics and Marketing (EEA/UK)

Users in the EEA and UK receive a cookie consent notice under GDPR/UK GDPR. Analytics and marketing cookies activate only after explicit, informed, freely given consent (GDPR Article 6(1)(a)). Your choice is recorded in the cookie_consent cookie (typically stored for 12 months).

You can withdraw consent at any time by using the “Manage cookie preferences” link in the footer, or by clearing cookies in your browser. Withdrawing consent does not affect processing that was lawful before the withdrawal.

6. Sharing With Advertising & Service Partners

We use certain service providers to operate the site and, with consent, to measure and improve marketing. We do not sell personal data. We share only what is needed for the purposes described in this Privacy Policy.

• Google LLC (Google Analytics 4, Google Ads, Google Tag Manager/remarketing where enabled): may receive cookie IDs, device data, usage data, and conversion events. Privacy information: https://policies.google.com/privacy.
• Meta Platforms, Inc. (Meta Pixel, Custom/Lookalike Audiences, Conversion API where enabled): may receive page views, conversion events, audience signals, and where configured, hashed identifiers. Privacy information: https://www.facebook.com/privacy/policy.
• Cloudflare, Inc. (content delivery and security): may process IP-based signals for performance and threat detection. Privacy information: https://www.cloudflare.com/privacypolicy/.

These providers act as processors or independent controllers depending on the specific tool and configuration. Where possible, we use settings that reduce unnecessary data collection (for example, IP anonymization in analytics where supported). We do not permit these providers to use site data for their own independent commercial purposes beyond what is described in their policies and the services they provide to us.

7. International Transfers

Some of our service providers may process personal data outside the EEA/UK, including in the United States. When transfers occur, we rely on recognized transfer mechanisms, including the EU-US Data Privacy Framework (and the UK Extension where applicable) when available, and Standard Contractual Clauses (EU 2021/914) as a fallback. For UK transfers, the UK International Data Transfer Agreement (IDTA) may also apply as a fallback.

8. Data Retention

We keep personal data only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required by law. Typical retention periods include:

• Registration and contact submissions: up to 2 years from the last interaction, so we can follow up on training requests and maintain a clean record of communications.
• Email correspondence: for the duration of the relationship plus 1 year, unless we need to keep it longer for legal reasons.
• Analytics data: typically 14 months (subject to tool settings and your consent choice).
• Marketing cookies: according to the cookie lifetime (commonly 90 days), unless you withdraw consent earlier.
• Server logs: typically up to 90 days for security and troubleshooting.
• Cookie consent records: up to 3 years for audit and compliance evidence.
• Legal and regulatory obligations: where applicable, we may retain certain records for 6–10 years depending on the nature of the record and relevant law.

9. Your Rights (GDPR & UK GDPR)

If you are in the EEA/UK, you may have the following rights under GDPR/UK GDPR, subject to certain conditions:

• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure (Article 17)
• Right to restriction of processing (Article 18)
• Right to data portability (Article 20)
• Right to object (Article 21)
• Right to withdraw consent at any time (Article 7(3))
• Right to lodge a complaint with a supervisory authority (Article 77)

To exercise your rights, email [email protected]. We aim to respond within 30 days. For complex requests, the period may be extended by up to 60 additional days as permitted by law.

Supervisory authorities: EU information is available via https://edpb.europa.eu. UK authority: https://ico.org.uk. Country-specific authorities include Germany (https://www.bfdi.bund.de), France (https://www.cnil.fr), Poland (https://uodo.gov.pl), and Spain (https://www.aepd.es).

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 to us without verifiable parental consent, contact [email protected] and we will take steps to delete it promptly.

11. Do Not Track Signals

This website does not respond to Do Not Track (DNT) browser signals. Third-party providers may have their own handling of DNT signals, which is described in their policies.

12. Requests for Deletion

You can request deletion of your personal data by emailing [email protected] with the subject line “Data Deletion Request”. We may ask for reasonable information to verify your identity before completing a deletion request. We aim to complete verified requests within 30 days, unless we must retain certain data to comply with legal obligations.

13. Business Transfers

If we are involved in a merger, acquisition, asset sale, financing, reorganization, bankruptcy, or similar event, personal data may be transferred to a successor or affiliated entity as part of that transaction. If such a transfer materially changes how personal data is used, we will provide notice on the website.

14. California Privacy Notice (CCPA/CPRA)

If you are a California resident, you may have rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA). In the past 12 months, we may have collected:

• Identifiers (such as name, email, IP address, cookie IDs) shared with service providers and advertising partners where enabled.
• Internet or other electronic network activity information (such as pages visited and interaction data) shared with analytics and advertising providers where enabled.
• Inferences (such as general interests based on page visits) used for advertising relevance where enabled.

We do not sell personal information as defined by CCPA. We may share personal information for cross-context behavioral advertising where you consent through cookie preferences. California residents may opt out of sharing for targeted advertising by rejecting marketing cookies in our cookie preferences panel.

You may have the right to know, delete, correct, and opt out of sale/sharing, and the right to non-discrimination. To submit a request, email [email protected] with the subject “California Privacy Request”. We will verify your identity before processing the request. Authorized agents may submit requests with written proof of authorization.

15. Virginia Privacy Notice (VCDPA)

If you are a Virginia resident, you may have rights under the Virginia Consumer Data Protection Act (VCDPA), including access, correction, deletion, portability, and opting out of targeted advertising. We do not sell personal data and we do not engage in profiling that produces legal or similarly significant effects.

To submit a request, email [email protected] with the subject “Virginia Privacy Request”. If we decline to act on a request, you may appeal by emailing with the subject “Appeal of Refusal — Privacy Request”. We will respond to appeals within 60 days as required by law.

16. Nevada Notice

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 Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the tools we use, or legal requirements. If we make material changes, we will provide a clear notice on the website at least 14 days before the changes take effect when feasible. The “Last Updated” date at the top of this page indicates when the most recent revision was published.

18. Contact

For questions about this Privacy Policy or our privacy practices, contact:

• Legal entity: Soplvirex Training LLC
• Address: Nábřežní 78, 407 21 Česká Kamenice, Czechia
• Email: [email protected]