1. Who we are

EM Academy is a trading name of Pinkmanta Consulting Ltd (registration number HE 444980), a company registered in Cyprus with its registered office at Spyrou Kyprianou 10, Office 22, Mesa Geitonia, 4001 Limassol, Cyprus.

Pinkmanta Consulting Ltd is the data controller for the personal data described in this policy. If you have questions about this policy or your data, email us at [email protected].

2. The data we collect

Depending on how you use EM Academy, we may collect:

• Account and purchase details: your name, email address, phone number and payment details when you buy a course, a mentorship or a community membership. Card payments are handled by Stripe; we never store your full card details.
• Community connection details: when you link your account to our community (the "Connect Discord" step), we collect your name, email address, Discord user ID and your Discord roles in our server. We refresh your roles regularly so your membership status and perks stay correct.
• Consent records: when you give consent (for example on the connection page), we record that you agreed and when, so we can show what you chose.
• Usage and technical data: cookies and similar technologies collect information such as your browser, your device, how you use our websites and which ad, if any, you came from (see section 7).

3. Why we use your data, and our legal basis

• To give you the course, mentorship and community you signed up for. Legal basis: performance of a contract.
• To link and keep up your membership across our tools (community access, member perks, and Novametrics member perks such as a discount or a longer trial, depending on your role) and to keep your Discord roles in sync. Legal basis: your consent.
• To share your details with our bookkeeping partner Ecom Konsult so you can get partner perks. Legal basis: your consent (see section 4).
• To protect our services and prevent misuse. Legal basis: our legitimate interest.
• To send you member offers and information. Legal basis: your consent, which you can withdraw at any time.
• To measure which of our ads lead to purchases, so we spend our ad budget on the right ads (see section 7). Legal basis: our legitimate interest.

4. Who we share your data with

We share personal data only with service providers that help us run EM Academy, and with the partner below. They may only use your data on our instructions.

Service providers (processors):

• HighLevel / LeadConnector: website, funnels and contact records
• Supabase: the database that stores your membership connection details
• Discord: the community platform (provides your Discord ID and roles)
• Stripe: payments
• Teachable: course hosting and enrolment
• Google (Workspace): email and internal operations
• Novametrics / Vercel: the analytics tool offered to members at a member discount or with a longer trial

Partner:

• Ecom Konsult: our bookkeeping partner. We share your name and email address with Ecom Konsult only after you have agreed on the connection page, so you can get your member perk. If your membership ends, we update or delete your details with Ecom Konsult for this purpose. You can withdraw this consent at any time by contacting us.

Ad platforms: Meta (Facebook and Instagram), TikTok and Google receive the data described in section 7, so we can measure our ads.

We do not sell your personal data.

5. Transfers outside the EEA

Some of our service providers (for example those based in the US) may process your data outside the European Economic Area (EEA). When they do, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, to protect your data.

6. How long we keep your data

• Course and purchase details: up to three (3) years after the course ends, and longer where the law requires it (for example tax and accounting rules).
• Community connection details (name, email, Discord ID and roles): for as long as you are a member and a reasonable period after that, then they are deleted or anonymised.
• Consent records: for as long as we need them to show compliance.
• Email marketing data: until you unsubscribe.

7. Cookies and ad measurement

Our websites (emacademy.se, emacademy.app and related pages) use cookies and similar technologies so the pages work, to understand how they are used and to measure our ads. This includes the Meta Pixel, the TikTok Pixel and Google tags (Google Analytics and Google Ads), loaded through Google Tag Manager.

When you go on to checkout, we keep the ad and analytics identifiers in your browser together with your purchase, for example the click ID that came with an ad. When the payment goes through (for a trial, only when the first real payment is taken), our server sends the purchase to Meta, TikTok and Google: the product, the amount, those identifiers and a hashed version of your email address, phone number and name. Hashed means turned into a code that can't be read back. This lets them match the purchase to the right ad.

We only send the purchase itself, never membership renewals and never anything about how you use the course or the community. We delete the identifiers once the purchase has been reported, at the latest after 180 days.

You can block or delete cookies in your browser settings, use an ad blocker, or manage ad personalisation in your Meta, TikTok and Google accounts. If you don't want your purchases used for ad measurement, email [email protected].

8. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have incorrect data corrected;
• have your data deleted;
• restrict or object to how we use your data;
• data portability;
• withdraw your consent at any time (this does not affect anything we did with your data before you withdrew it).

To use any of these rights, email [email protected].

You also have the right to complain to the Cyprus data protection authority, the Office of the Commissioner for Personal Data Protection (dataprotection.gov.cy), or to the data protection authority in the country where you live.

9. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top shows when it last changed. Where it makes sense, we tell members about significant changes.