Privacy Policy

Effective Date: May 28, 2025

1. Introduction and Who We Are

This Privacy Policy explains how SolutionCraft s.r.o. ("we," "us," or "our") collects, uses, shares, and protects your personal data when you use our services. This includes our educational platform, SkillCraft Academy (hosted on Thinkific), and our website, DrawDownDiary.com, which features the RiskPilot tool.

We are committed to protecting your privacy and handling your data openly and transparently, in compliance with the General Data Protection Regulation (GDPR) and applicable Slovak data protection laws.

Our Details (Data Controller):

2. What Personal Data We Collect

We collect personal data in the following ways:

A. Data You Provide Directly to Us:

• When you enroll in SkillCraft Academy courses (via Thinkific): To manage your enrollment, we receive necessary information from our course platform provider, Thinkific, such as your name, email address, and course progress. Payment information is processed by Thinkific and their payment processors (e.g., Stripe, PayPal); we only receive confirmation of payment and details necessary for invoicing, not your full credit card details. Please refer to Thinkific’s Privacy Policy for their specific data handling practices.
• When you sign up for the Drawdown Diary / RiskPilot tool: We collect your email address to send you your personalized Drawdown Diary and our informational email series.
• When you use the RiskPilot tool: The financial inputs you provide (e.g., equity, monthly savings) are processed exclusively to generate your personalized diary. This input data is used ephemerally and is not stored by us linked to your email address after the diary is generated and sent.
• When you contact us: If you contact us for support or inquiries via email, we will collect your name, email address, and any other information you provide in your communication.

B. Data We Collect Automatically (Cookies and Usage Data):

• Cookies and Tracking Technologies: When you visit DrawDownDiary.com, we use cookies and similar tracking technologies. For detailed information, please see Section 10: "Cookie Usage" below.
• Usage Data: We may automatically collect information about your device and how you interact with our Site, such as your IP address, browser type, operating system, and pages visited. This is typically collected through server logs or analytics tools like Google Analytics.

3. How We Use Your Personal Data (Purpose of Processing)

We use your personal data for the following purposes, based on a specific legal basis:

• To manage and deliver our courses: To manage your enrollment, provide access to SkillCraft Academy courses via Thinkific, and track your progress. (Legal Basis: Contractual Necessity)
• To process transactions: To facilitate and confirm your course purchases and for our own accounting. (Legal Basis: Contractual Necessity and Legal Obligation)
• To provide our free tools: To operate DrawDownDiary.com, generate and deliver your personalized Drawdown Diary PDF, and send our related email series via Resend.com. (Legal Basis: Contractual Necessity for delivery; Consent for the email series)
• To communicate with you: To respond to your inquiries and provide customer support. (Legal Basis: Legitimate Interest)
• For marketing and informational updates: To send you communications about our services (such as new courses or tool updates), where you have provided consent or where permitted by law. You can opt-out at any time. (Legal Basis: Consent or Legitimate Interest)
• For security and improvement: To maintain the security of our services and to analyze usage data to improve our offerings. (Legal Basis: Legitimate Interest)
• To meet legal requirements: To comply with our legal obligations, such as for tax and accounting purposes. (Legal Basis: Legal Obligation)

4. Legal Basis for Processing Your Personal Data (GDPR)

We process your personal data based on the grounds listed alongside each purpose in Section 3, which include:

• Consent: Where you have given us explicit consent (e.g., for marketing emails, non-essential cookies). You can withdraw consent at any time.
• Contractual Necessity: Where processing is necessary to perform a contract with you (e.g., to provide access to a course you've purchased).
• Legal Obligation: Where processing is necessary to comply with the law (e.g., maintaining financial records).
• Legitimate Interests: Where processing is necessary for our legitimate interests (e.g., improving our services, security), provided they are not overridden by your rights.

5. Data Sharing and Third Parties

We do not sell your personal data. We share it only with trusted third-party service providers who assist us in operating our business. These include:

• Course Platform Provider: Thinkific Labs Inc. (for hosting SkillCraft Academy, processing enrollments and payments).
• Payment Processors: Stripe, PayPal, as integrated with Thinkific to process course payments.
• Email Service Provider: Resend.com (for sending the Drawdown Diary and email series).
• Analytics Providers: Google Analytics (to understand how our Site is used). We have a Data Processing Addendum in place with Google.
• Advertising Platforms: Google Ads and Meta (Facebook) to display remarketing advertisements after you consent to advertising cookies.
• Website Hosting Provider: websupport.sk (for hosting DrawDownDiary.com).
• Virtual Office Provider: sroonline.sk (for mail handling).
• Legal and Professional Advisors: Our lawyers, accountants, and auditors.

6. International Data Transfers

Some of our service providers are located outside the European Economic Area (EEA). We ensure data protection is maintained through legally recognized mechanisms. For transfers to Canada (Thinkific), we rely on an EU adequacy decision. For transfers to the U.S. (Resend.com, Google, Meta), we rely on Standard Contractual Clauses or the EU-U.S. Data Privacy Framework.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements.

• Data related to course purchases (invoices, etc.) will be kept for 10 years as required by Slovak accounting law.
• Email addresses for our newsletter are kept until you unsubscribe.
• Other data is retained based on the specific purpose and any overriding legal requirements.

8. Data Security

We have implemented appropriate technical and organizational measures to protect your data, including SSL encryption, secure hosting, and access controls. However, no method of transmission over the Internet is 100% secure. If a data breach occurs that is likely to result in a high risk to your rights, we will notify you and the Slovak data-protection authority as required by law.

9. Your Rights Under GDPR

You have rights over your personal data, including the right to access, rectify, erase, restrict processing of, and port your data. You also have the right to object to processing and withdraw consent. To exercise any of these rights, please contact us at [email protected].

You have the right to lodge a complaint with the Slovak data protection authority: Úrad na ochranu osobných údajov Slovenskej republiky.

10. Cookie Usage

This section explains our use of cookies on our website, `DrawDownDiary.com`. Please note that our course platform, Thinkific, has its own cookie policy which also applies when you use SkillCraft Academy.

What are Cookies? Small text files placed on your device to make websites work and provide information to site owners.

Types of Cookies We Use:

• Strictly Necessary Cookies: Essential for the website to function.
• Performance/Analytical Cookies: Help us understand how you use the site so we can improve it (e.g., Google Analytics).
• Targeting/Advertising Cookies: Used to show you relevant ads on other websites (e.g., Google Ads, Meta Pixel). These are only used with your explicit consent.

Your Consent: We will ask for your consent via a cookie banner before placing any non-essential cookies on your device. You can manage your preferences at any time.

11. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children.

12. Changes to This Privacy Policy

We may update this policy from time to time. We will notify you of any significant changes by posting the new policy on this page and updating the "Effective Date."

13. Contact Information

If you have questions about this Privacy Policy, please contact us: