PRIVACY POLICY

Last Updated: December 15, 2025

 

1. INTRODUCTION
   Doder Limited (“Company”, “we”, “us”, or “our”), a company incorporated under the laws of Cyprus, having registration number HE 462273, with its registered office at Aglantzias 21b, 2nd floor/office 1, Aglantzia, 2108 Nicosia, Cyprus, respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website Simple Academy (the “Site”) or purchase our educational courses.

2. INFORMATION WE COLLECT
   We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

2.1. Information You Provide to Us:

• Name, email address, password.
• Billing address, transaction history, and partial credit card information (last 4 digits). Note: We do not store full credit card numbers. All payment processing is handled securely by a third party provider.
• Information you provide when contacting support or participating in community forums.

2.2. Information Collected Automatically (Cookies & Tracking):

• IP address, browser type, operating system, device model (mobile/desktop).
• Pages viewed, time spent on lessons, course progress, quiz results.
• We use cookies, web beacons, and similar technologies (including Meta Pixel and Google Analytics) to track your activity on our Site and hold certain information.

3. HOW WE USE YOUR INFORMATION
   We use your personal data for the following business purposes:

• To create your account, provide access to courses, track your learning progress, and issue certificates.
• To process payments and prevent fraud.
• To send you transactional emails (receipts, password resets) and updates about the Service.
• To send you promotional offers and to display relevant advertisements to you on third-party platforms (such as Facebook/Instagram) using the Meta Pixel.
• To analyze user behavior and improve our website functionality and course content.

4. SHARING YOUR INFORMATION
   We do not sell your personal data in the traditional sense. However, we may share information with the following categories of third parties for business purposes:

• Service Providers:
• Payment service providers — for payment processing.
• Hosting & Cloud Services — to host our platform and database.
• Email Services — to send automated emails.
• We share data (such as hashed emails or cookie IDs) with advertising networks like Meta (Facebook) and Google to measure ad performance and create lookalike audiences. Under California law (CCPA), this may be considered "sharing" for cross-context behavioral advertising.
• If required by law, court order, or government regulation (Cyprus or US authorities).
• If Doder Limited is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.

5. INTERNATIONAL DATA TRANSFERS
   Doder Limited is based in Cyprus. By accessing the Service from the United States or other regions, you acknowledge that your personal data will be transferred to, stored, and processed in Cyprus and other jurisdictions where our service providers (e.g., Cloud servers) operate.

• We rely on legal bases such as the European Commission's Standard Contractual Clauses (SCCs) and GDPR adequacy decisions to ensure your data is protected during transfer.

6. DATA RETENTION
   We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it:

• Account Data — retained as long as your account is active.
• Transaction Data — retained for at least 7 years to comply with tax and accounting laws in Cyprus and the EU.
• Marketing Data — retained until you opt-out (unsubscribe).

7. YOUR PRIVACY RIGHTS
   Depending on your location, you may have the following rights regarding your personal data:

• The right to request a copy of your data and correct inaccuracies.
• The right to request that we delete your personal data (subject to legal retention requirements, such as tax laws).
• The right to restrict the processing of your data.
• Please contact us at [email protected]. We will respond to verified requests within 30 days.

8. NOTICE TO CALIFORNIA RESIDENTS (CCPA/CPRA)
   This section applies solely to visitors, users, and others who reside in the State of California.

• 8.1. We do not sell your personal information for monetary value. However, we use tracking technologies (like the Meta Pixel) which may constitute "sharing" or "selling" under the definition of California law for the purpose of cross-context behavioral advertising.
• 8.2. Your California Rights:
• You can request that we disclose the categories and specific pieces of personal information we have collected about you over the past 12 months.
• You can request that we delete your personal information, subject to certain exceptions.
• You have the right to opt-out of the "sale" or "sharing" of your personal information. You may do this by contacting us or adjusting your browser's cookie settings.
• We will not discriminate against you for exercising any of your CCPA rights (e.g., we will not deny you goods or charge you different prices).
• 8.3. California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

9. SECURITY OF DATA
   We use administrative, technical, and physical security measures to help protect your personal information (including HTTPS encryption). However, no electronic transmission or storage is 100% secure. We cannot guarantee absolute security.
10. CHILDREN'S PRIVACY
    Our Service is intended for adults (18+). We do not knowingly collect personal identifiable information from children under 13 (or under 16 depending on jurisdiction). If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers.
11. CONTACT US
    If you have questions or comments about this Privacy Policy, please contact us:

• Company Name: Doder Limited
• Registration Number: HE 462273
• Address: Aglantzias 21b, 2nd floor/office 1, Aglantzia, 2108 Nicosia, Cyprus.
• Email: [email protected]