1. Introduction

This Cookie Policy explains how TCM Learning (“TCM”, “we”, “us”, or “our”) uses cookies and similar technologies when you visit or use our website and learning platform (the “Services”).

This Policy should be read together with our Privacy Policy.

Where required by law, we obtain your consent before placing non-essential cookies on your device.

2. What Are Cookies?

Cookies are small text files placed on your device (computer, mobile phone, tablet) when you visit a website.

They allow websites to:

• Recognize your device
• Store user preferences
• Maintain secure sessions
• Improve performance
• Measure usage

Cookies may be first-party cookies (set by TCM) or third-party cookies (set by service providers). They may also be session cookies (deleted when browser closes) or persistent cookies (stored for a defined period).

3. Categories of Cookies We Use

3.1 Essential Cookies (Always Active)

These cookies are strictly necessary for the operation of the Services.

Legal basis (EU): Legitimate interest (Art. 6(1)(f) GDPR). Consent is not required.

• Authentication session tokens (Firebase)
• Security tokens
• Load balancing cookies
• Payment session cookies (Stripe)
• Consent storage cookie (tcm_consent_v1)

3.2 Functional Cookies (Consent Required in EU/UK)

These cookies enhance usability and security but are not strictly required.

Legal basis (EU): Consent (Art. 6(1)(a) GDPR).

• reCAPTCHA or Turnstile cookies (bot prevention)
• Language preference cookies
• UI preference cookies

3.3 Analytics Cookies (If Enabled)

These cookies measure traffic and usage patterns to improve the Services. Activated only where legally permitted and based on consent where required.

3.4 Marketing Cookies

TCM Learning does not use advertising or behavioral profiling cookies. If this changes, we will update this Policy and request explicit consent.

4. Cookies We Currently Use

Actual cookies may vary depending on browser and configuration.

5. How We Obtain and Manage Consent

• Non-essential cookies are blocked by default where required by law.
• You must opt-in before they are activated.
• You may withdraw consent at any time via the “Privacy Settings” link in the footer.

Consent status is stored for up to 12 months. If purposes or providers materially change, we will request renewed consent.

6. Global Privacy Control (GPC)

Where supported, we recognize browser-based opt-out signals such as Global Privacy Control (GPC) and automatically apply relevant restrictions.

7. How to Control Cookies

• Use our Privacy Settings panel
• Adjust browser settings
• Clear stored cookies in device settings

Disabling essential cookies may prevent parts of the platform from functioning.

8. Third-Party Services

Infrastructure & Authentication

Google Cloud Platform / Firebase (Google LLC)
Used for secure hosting, authentication, database services, and infrastructure operations.
Acts as a data processor under applicable data protection laws.
Privacy Policy

Payments

Stripe, Inc.
Used for secure payment processing and fraud prevention.
Acts as an independent data controller for payment information.
Privacy Policy

Bot Protection

Google reCAPTCHA
Used for abuse prevention and automated bot detection on forms.
May process device and interaction data for security purposes.
Privacy Policy

9. International Data Transfers

Cookie-related data may be processed in the European Union or United States. Where required, we rely on Standard Contractual Clauses (SCCs) or other lawful safeguards.

10. Data Retention

• Session cookies: deleted when browser closes
• Consent cookie: up to 12 months
• Payment/security cookies: retained as required for fraud prevention and compliance

Personal data associated with inactive accounts may be anonymized or deleted after 24 months of inactivity.

11. Your Rights

Depending on your location, you may have rights including access, deletion, restriction, objection, data portability, and withdrawal of consent.

EEA residents may lodge a complaint with their local Data Protection Authority.

In Cyprus: Office of the Commissioner for Personal Data Protection.

12. Updates to This Policy

We may update this Cookie Policy from time to time. Continued use after changes constitutes acceptance where permitted by law.

13. Contact Information

G.L TCM Consulting LTD
Arch. Makariou III, 82 GABRIEL BUILDING,
3rd Floor, Flat/Office 302,
1077 Nicosia, Cyprus

Email: info@tcm-solutions.com