Svetlana handles the data. I do not know what data is. The following explains it. Apparently this is required.

Privacy Policy

Last updated: April 22, 2026

1. Introduction

This Privacy Policy explains how Roland Koronya E.V. (“we”, “us”, or “our”) collects, uses, stores, shares, and protects your personal data when you visit johnnyhogwash.com (the “Website”), create an account, purchase our online courses or other digital products, or otherwise interact with us.

For the purposes of applicable data protection law, we are the data controller of your personal data.

If you have any questions about this Privacy Policy or about how we handle your personal data, you can contact us at genious@johnnyhogwash.com.

2. The Personal Data We Collect

We may collect the following categories of personal data.

2.1 Information you provide directly

When you create an account, place an order, contact us, or otherwise interact with us, we may collect:

  • your name;
  • your email address;
  • your billing details;
  • your account login details;
  • your purchase history;
  • the content of messages or support enquiries you send us; and
  • any other information you choose to provide.

2.2 Payment information

Payments are processed by third-party payment providers such as Stripe and PayPal.

We do not store your full payment card details on our own servers. We may receive limited payment-related information such as payment status, transaction identifiers, and limited billing information necessary for order processing, record-keeping, refunds, and fraud prevention.

2.3 Information collected automatically

When you visit the Website, we and our service providers may collect certain information automatically, including:

  • your IP address;
  • browser type and version;
  • device type;
  • operating system;
  • pages viewed;
  • referring URLs;
  • on-site activity and interactions;
  • approximate location derived from IP or similar signals;
  • timestamps and session information; and
  • online identifiers associated with analytics, advertising, or similar technologies, where used.

2.4 Account and product access information

When you create an account or access Products, we may collect information relating to:

  • account creation;
  • login activity;
  • product enrolment or access;
  • downloads;
  • course progress or usage activity; and
  • technical events necessary to operate and secure your account.

3. How We Use Your Personal Data

We use your personal data for the following purposes.

3.1 To provide the Website, your account, and the Products

We use your data to:

  • create and manage your account;
  • process your orders;
  • provide access to purchased Products;
  • deliver digital materials;
  • handle refunds;
  • and provide customer support.

Lawful basis: performance of a contract.

3.2 To operate, secure, and improve the Website and Products

We use data to:

  • maintain the Website;
  • troubleshoot issues;
  • detect fraud, abuse, or unauthorised access;
  • understand how users interact with the Website and Products;
  • and improve content, functionality, and user experience.

Lawful basis: our legitimate interests, and where required by law, your consent for non-essential tracking technologies.

3.3 To send service communications

We use your data to send order confirmations, access instructions, password-related messages, product updates relevant to your purchase, refund communications, and support responses.

Lawful basis: performance of a contract, and where applicable, compliance with legal obligations.

3.4 To send marketing emails

We may send you marketing emails about our own products, services, updates, offers, or related content.

Where required, we will do so only with your consent. Where permitted under applicable law, we may rely on the soft opt-in in relation to customers who have purchased from us, provided that:

  • we obtained your contact details in the course of a sale or negotiations for a sale;
  • we market our own similar products or services; and
  • you were given a clear opportunity to opt out both when your details were collected and in every subsequent marketing email.

You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in any marketing email or by contacting us at genious@johnnyhogwash.com.

Lawful basis: consent, or our legitimate interests where the soft opt-in or other lawful route is available under applicable law.

3.5 To comply with legal, tax, accounting, and regulatory obligations

We may use and retain certain personal data where required to comply with applicable law, tax rules, accounting requirements, fraud prevention obligations, or lawful requests from authorities.

Lawful basis: legal obligation.

4. Email Marketing and MailerLite

We use MailerLite as our email marketing service provider.

MailerLite may process your personal data on our behalf to:

  • store subscriber and customer email details;
  • manage mailing lists and unsubscribe requests;
  • send email campaigns and automated emails;
  • and provide email performance statistics such as opens and clicks, where tracking is enabled and lawfully used.

If you unsubscribe from marketing emails, we may keep limited information necessary to ensure that we respect your unsubscribe request.

5. Cookies and Similar Technologies

We use cookies and similar technologies on the Website. These may include cookies, pixels, tags, scripts, and similar tools that store information on, or access information from, your device.

These technologies may be used for:

  • essential Website functionality;
  • account and session management;
  • analytics and performance measurement;
  • advertising measurement and attribution; and
  • improving the Website and user experience.

We may use the following services or categories of technologies:

  • Google Analytics 4
  • Meta Pixel
  • TikTok Pixel
  • essential Website and account/session cookies

Non-essential analytics and advertising technologies should be used only where you have given the required consent through our cookie consent tool.

You can withdraw or update your preferences at any time through the cookie settings mechanism made available on the Website once implemented.

6. Who We Share Personal Data With

We may share personal data with trusted service providers where necessary for the purposes described in this Privacy Policy, including:

  • payment providers, such as Stripe and PayPal;
  • email marketing providers, such as MailerLite;
  • analytics providers, such as Google;
  • advertising and measurement platforms, such as Meta and TikTok;
  • hosting, technical support, and infrastructure providers;
  • professional advisers, such as accountants, lawyers, or insurers, where necessary; and
  • authorities or regulators, where required by law or to protect our legal rights.

We do not sell your personal data.

7. International Transfers

Some of the service providers we use may process personal data outside the United Kingdom or outside the country in which you are located.

Where personal data is transferred internationally, we take steps intended to ensure an appropriate level of protection. Depending on the provider and the circumstances, this may include reliance on:

  • an adequacy decision;
  • approved standard contractual clauses or similar transfer safeguards;
  • the UK Addendum where relevant;
  • or other lawful transfer mechanisms recognised under applicable data protection law.

8. How Long We Keep Personal Data

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including for legal, tax, accounting, security, dispute-resolution, and record-keeping purposes.

As a general guide:

  • purchase and transaction records may be kept for up to 8 years or longer where required by law;
  • account information may be kept for as long as your account remains active and for a reasonable period afterwards;
  • customer support communications may be kept for as long as reasonably necessary to manage support issues and our business records;
  • marketing records may be kept until you unsubscribe or object, plus a reasonable period afterwards to maintain suppression records;
  • analytics and advertising data may be retained in accordance with the settings and retention periods of the relevant service provider and our own configuration choices.

9. Your Rights

Depending on applicable law, you may have the right to:

  • request access to the personal data we hold about you;
  • request correction of inaccurate or incomplete personal data;
  • request deletion of your personal data;
  • request restriction of processing;
  • object to certain processing;
  • request portability of data you provided to us;
  • and withdraw consent where processing is based on consent.

These rights are not absolute, and some exceptions may apply.

If you wish to exercise any of your rights, please contact us at genious@johnnyhogwash.com.

We will respond without undue delay and, in any event, within one month, unless a lawful extension applies.

If you are not satisfied with our response, you may have the right to complain to the relevant supervisory authority. For UK data protection matters, this is the Information Commissioner’s Office (ICO).

10. Data Security

We use reasonable technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access.

These measures may include access controls, encryption in transit, secure payment processing through third-party providers, and appropriate internal access restrictions.

However, no system or method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

11. Third-Party Websites and Services

The Website may contain links to third-party websites, platforms, or services.

We are not responsible for the privacy practices, content, or security of third-party websites or services that we do not control. You should review their own terms and privacy policies before interacting with them.

12. Children’s Privacy

The Website and Products are not directed at children under the age of 18, and we do not knowingly collect personal data from children.

If you believe a child has provided personal data to us, please contact us and we will take appropriate steps to investigate and, where appropriate, delete that information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, practices, technologies, or legal obligations.

When we do, we will post the updated version on the Website and update the “Last updated” date above.

14. Contact

If you have questions about this Privacy Policy or want to exercise your rights, please contact:

Roland Koronya E.V.
Email: genious@johnnyhogwash.com

 

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