1. Introduction

This Privacy Policy explains how TCM Learning ("TCM", "we", "us") collects, processes, stores, and protects personal data when you use our website, interactive coding platform, AI-assisted tools, and related services.

By using the Services, you agree to this Privacy Policy.

2. Data Controller

G.L TCM Consulting LTD, registered in Cyprus (EU), acts as the Data Controller under the General Data Protection Regulation (GDPR).

3. Information We Collect

3.1 Information You Provide

• Full name
• Email address
• Account credentials
• Course progress data
• Submitted code and exercises
• Support communications

We do not store full payment card numbers.

3.2 Automatically Collected Data

• IP address
• Browser and device information
• Usage statistics
• Error logs
• Approximate geographic location (IP-based)

4. AI-Assisted Features

When you use AI-assisted tools, portions of your prompts or code may be transmitted to trusted AI providers (e.g., OpenAI API or equivalent providers) solely for generating responses.

We contractually ensure that these providers do NOT use your data to train global or foundation models.

Your code and prompts are processed strictly for real-time educational assistance.

5. Ownership of Your Code

All code authored by you within our interactive environment remains your intellectual property.

We store and process your code solely to:

• Track progress
• Provide feedback
• Enable session continuity

6. Cookies & Tracking

We use essential first-party and third-party cookies necessary for secure authentication, session management, payment processing, and platform stability, including Firebase authentication cookies and Stripe security cookies.

Non-essential cookies (such as analytics or functional enhancement tools) are used only where legally permitted and, where required, based on user consent.

We do not use third-party advertising or behavioral profiling cookies.

7. How We Use Your Data

• Provide and maintain Services
• Process payments
• Deliver learning content
• Ensure security and fraud prevention
• Comply with legal obligations

We do not sell personal data.

8. Payments

Payments are securely processed by Stripe, Inc. We do not store full card details.

9. Sub-Processors

• Infrastructure & Authentication: Google Cloud Platform / Firebase (Google LLC, EU region) – Acts as a Data Processor under GDPR for hosting, authentication, and secure database services. Privacy Policy
• Payments: Stripe, Inc. – Acts as an independent Data Controller for payment processing and fraud prevention. Privacy Policy
• Email Services: PrivateEmail – Used for transactional and support communications.
• AI Services: OpenAI API – Acts as a Data Processor for AI-assisted educational responses. Privacy Policy

10. Data Security

• HTTPS encryption (TLS)
• Role-based access control
• Secure cloud hosting
• Monitoring and logging

11. Data Retention

Inactive accounts will be anonymized or deleted after 24 months of inactivity, unless legal obligations require longer retention.

12. Your Rights (GDPR & International)

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction
• Right to data portability
• Right to object

EEA residents may lodge a complaint with their local Data Protection Authority. In Cyprus: Office of the Commissioner for Personal Data Protection.

13. International Transfers

Data may be processed in the EU or United States under appropriate safeguards, including Standard Contractual Clauses (SCCs).

14. Children’s Privacy

Our Services are not intended for children under 16 without parental supervision. We do not knowingly collect data from children under 13.

15. Marketing Communications

You may unsubscribe from promotional emails at any time. Transactional communications cannot be opted out.

16. Changes to This Policy

We may update this Privacy Policy periodically. Continued use of the Services constitutes acceptance.

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