CATALYST ACADEMY™ PRIVACY POLICY
Effective date: 1 October 2026

Catalyst Commercial Advisory respects your privacy and is committed to protecting your personal data.This Privacy Policy explains how personal data is collected, used, stored and protected when you visit, register with, purchase from or use Catalyst Academy™, and explains the rights available to you under applicable data-protection law.
Catalyst Academy™ is operated by Rudi Carolina J De Koninck, trading as Catalyst Commercial Advisory, established as a self-employed professional (autónomo) in Spain.

1. DATA CONTROLLER

For the purposes of applicable data-protection legislation, the data controller is:
Rudi Carolina J De Koninck
Trading as: Catalyst Commercial Advisory
Address: Calle Canada Esparragona 1, 18720 Torrenueva Costa, Spain
Email: info@catalystcommercialadvisory.com
Telephone: +34 607 512 879
Catalyst Academy™ is the online learning platform operated by Catalyst Commercial Advisory.

2. PERSONAL DATA WE MAY COLLECT

Depending on how you interact with Catalyst Academy™, we may process personal data including:
- your name and contact information, including your email address;
- account and login information;
- billing information, including billing address, country and, where provided, business tax/VAT identification;
- purchase and transaction information;
- course enrolments, learning activity, progress, assessment results and certificates;
- communications and customer-support enquiries;
- marketing preferences and consent choices;
- information relating to your cookie and privacy preferences; and
- technical information such as IP address, browser, device and usage information where collected through the platform.
Payment-card transactions are handled through our payment service provider. Catalyst Commercial Advisory does not directly store your complete payment-card details.
We seek to collect only personal data that is relevant and necessary for the purposes for which it is processed, consistent with GDPR data-minimisation principles

3. HOW WE USE YOUR PERSONAL DATA

We may process personal data in order to:
- create and administer your Catalyst Academy™ account;
- process purchases and payments;
- provide access to purchased courses and learning materials;
- track learning progress and assessment results;
- issue course-completion certificates;
- provide transactional and operational communications;
- respond to enquiries and provide customer support;
- maintain financial, tax and business records;
- operate, secure and improve Catalyst Academy™;
- manage privacy and cookie preferences;
- send marketing communications where permitted; and
- comply with applicable legal and regulatory obligations.
We do not use personal data for purposes incompatible with those for which it was collected unless permitted by applicable law.

4. LEGAL BASES FOR PROCESSING

We process personal data only where there is an appropriate legal basis.Depending on the circumstances, this may include:
Performance of a contract — where processing is necessary to process your purchase, create or administer your account, provide course access or deliver services you have requested.
Legal obligation — where processing is necessary to comply with applicable accounting, taxation or other legal requirements.
Consent — where you have actively consented to a particular activity, such as certain marketing communications or non-essential cookies.
Legitimate interests — where processing is reasonably necessary to operate, protect or improve Catalyst Academy™ or Catalyst Commercial Advisory, provided those interests are not overridden by your rights and freedoms.
The AEPD confirms that processing must be supported by an appropriate legal basis and identifies consent, contractual necessity, legal obligations and legitimate interests among the bases provided by the GDPR.

5. PAYMENTS & BILLING

Payments for Catalyst Academy™ products are processed through Stripe.
Information required to process a payment may therefore be provided to Stripe and processed according to the applicable payment-processing arrangements and privacy requirements.
Catalyst Commercial Advisory may retain transaction, billing, invoice and tax information where required for accounting, taxation, customer-service and legal purposes.
We do not directly store complete payment-card numbers.

6. LEARNING PLATFORM

Catalyst Academy™ is delivered using LearnWorlds, which provides the technology used to operate the online learning environment.
Personal data may therefore be processed through LearnWorlds where necessary to provide services including account registration, course access, learning progress, assessments, certificates, communications and platform functionality.
Relevant service providers act according to their respective roles and contractual/data-protection arrangements.

7. SHARING OF PERSONAL DATA

We do not sell your personal data.
Personal data may be shared with service providers where necessary to operate Catalyst Academy™ and Catalyst Commercial Advisory, including providers supporting:
- learning-platform technology;
- payment processing;
- taxation and invoicing;
- hosting and technical infrastructure;
- email and communications;
- analytics and security; and
- professional accounting, legal or regulatory requirements.
We may also disclose personal data where required by law, regulation, court order or a competent public authority.
Service providers should receive only the personal data reasonably necessary for the relevant service.

8. INTERNATIONAL DATA TRANSFERS

Some technology and service providers used in operating Catalyst Academy™ may process personal data outside the European Economic Area.
Where personal data is transferred internationally, appropriate safeguards will be used where required by applicable data-protection law, such as an applicable adequacy decision or approved contractual safeguards.
The GDPR requires information concerning applicable third-country transfers and relevant safeguards to be provided where such transfers occur

9. DATA RETENTION

Personal data will be retained only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, accounting, tax, contractual and regulatory requirements.
Different categories of information may therefore be retained for different periods.
For example, information associated with purchases, invoices and taxation may need to be retained for legally required periods even after a learner stops using Catalyst Academy™.
Where personal data is no longer required, it will be deleted, anonymised or otherwise handled in accordance with applicable requirements.
GDPR requires organisations to specify the retention period or, where a fixed period cannot be given, the criteria used to determine it.

10. MARKETING COMMUNICATIONS

Where required, marketing communications will be sent only where an appropriate legal basis exists.
You may withdraw marketing consent or opt out of marketing communications at any time using the unsubscribe or preference options provided or by contacting:
info@catalystcommercialadvisory.com
Withdrawing marketing consent does not prevent us from sending necessary transactional or operational communications relating to purchases, accounts or courses.

11. COOKIES

Catalyst Academy™ may use cookies and similar technologies to provide essential platform functionality and, where permitted, analytics, preferences or other functionality.
Where consent is required for non-essential cookies, users will be provided with appropriate cookie choices.
Users can manage applicable cookie preferences through the privacy and cookie controls provided by Catalyst Academy™.
Further information is available in our Cookie Policy.

12. YOUR DATA-PROTECTION RIGHTS

Subject to applicable law and the circumstances of the processing, you may have rights including:
- the right to access your personal data;
- the right to correct inaccurate or incomplete personal data;
- the right to request deletion of personal data;
- the right to request restriction of processing;
- the right to object to certain processing;
- the right to data portability where applicable; and
- the right to withdraw consent where processing is based on consent.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
These rights are reflected in GDPR Articles 13 and related provisions. EUR-Lex
Requests concerning your personal data can be sent to:
info@catalystcommercialadvisory.com
We may need to verify your identity before fulfilling certain requests

13. RIGHT TO COMPLAIN

If you have concerns about how your personal data is handled, we encourage you to contact us first so that we can try to resolve the matter.
You also have the right to lodge a complaint with the competent data-protection supervisory authority.
In Spain, the supervisory authority is the Agencia Española de Protección de Datos (AEPD).

14. DATA SECURITY

We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, accidental loss, destruction or damage.
No online system can guarantee absolute security, but personal data will be handled in accordance with applicable data-protection requirements and appropriate security practices.

15. CHILDREN

Catalyst Academy™ is designed primarily for professional and commercial development and is not intentionally directed at children.
We do not knowingly seek to collect personal data from children for the purpose of providing Catalyst Academy™ professional learning services.

16. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in Catalyst Academy™, our processing activities, technology, service providers or applicable legal requirements.
The current version and effective date will be published on this page.
Where a change materially affects how personal data is processed, additional notice will be provided where required.

17. CONTACT US

Questions about this Privacy Policy or the handling of your personal data can be directed to:
Catalyst Commercial Advisory
Rudi Carolina J De Koninck
Calle Canada Esparragona 1
18720 Torrenueva Costa
Spain
Email: info@catalystcommercialadvisory.com
Telephone: +34 607 512 879
Effective date: 1 October 2026
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