1. Introduction

At Towers Method Academy, we are committed to protecting your privacy and handling your personal data with care and transparency. This Privacy Policy explains how we collect, receive, use, store, share, and protect personal data in connection with our Website and Services, including when you visit the Website, create an account, purchase a course, access learning materials, or communicate with us.

Towers Method Academy is owned and operated by MCM GRUP DOOEL uvoz-izvoz Skopje. This Privacy Policy applies to personal data we process in connection with operating the Website and providing our Services.

Course purchases are handled by PayPro Global as our Merchant of Record. PayPro Global's Privacy Policy (https://docs.payproglobal.com/documents/legal/privacyPolicy.pdf) also applies to the personal data it processes in connection with those purchases.

2. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

"Account" means a User's profile on the learning platform, including relevant personal information, login credentials, course enrolment, access information, and related details used to access the Website and Services.

"Content" means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Website.

"Cookie" means a small text file that may be placed on a User's computer or device by the Website or a third-party service provider to support functions such as login, security, remembering preferences, and, where applicable, analytics.

"Data" means collectively any personal data or other information submitted by Users, collected automatically through the Website or learning platform, received from third-party service providers where applicable, or processed in connection with the Website, Services, Accounts, communications, course access, payments, cookies, analytics, or technical operation of the Website.

"Data Controller" means any person or organization that determines the purposes and means of processing personal data.

"Data Processor" means any person or organization that processes personal data on behalf of a Data Controller and in accordance with the Data Controller's instructions, where applicable.

"Merchant of Record" means PayPro Global, the independent reseller that handles customer purchases of our digital courses in its own name, including payment processing, applicable taxes, invoices or receipts, and payment-related matters such as refunds and chargebacks, and pays the applicable sales proceeds to MCM GRUP DOOEL uvoz-izvoz Skopje in accordance with the Reseller Agreement.

"Service" means collectively any online facilities, tools, services or information that Towers Method Academy makes available through the Website either now or in the future.

"Third-Party Service Provider" means any external provider used to help operate the Website, deliver the Services, host content, provide the learning platform, process payments, send communications, provide analytics, support security, or perform related technical, legal, financial, or operational functions.

"User" or "Users" means any third party that accesses the Website and is not employed by MCM GRUP DOOEL uvoz-izvoz Skopje acting in the course of their employment.

"Website" means the website at www.towersmethodacademy.com and any associated subdomains unless expressly excluded by their own terms and conditions.

3. Who We Are

Towers Method Academy is operated by MCM GRUP DOOEL uvoz-izvoz Skopje, a company registered in North Macedonia.

Registered company name: MCM GRUP DOOEL uvoz-izvoz Skopje

Business address: Nikola Tesla Street, No. 9A, 1000 Skopje, North Macedonia

Contact email: info@towersmethodacademy.com

Company Registration Number: 6973272

VAT Identification Number: 4002014537543

As the operator of Towers Method Academy, MCM GRUP DOOEL uvoz-izvoz Skopje acts as a Data Controller only where it determines the purposes and means of processing personal data in connection with operating Towers Method Academy, including operating the Website, providing the Services, managing User accounts and course access, communicating with Users, maintaining business records, complying with legal obligations, and protecting our rights.

We use third-party service providers, including LearnWorlds as our learning platform provider, and may use other providers for hosting, communications, analytics, security, and technical support, where applicable. Where these providers process personal data on our behalf and in accordance with our instructions, they act as Data Processors.

PayPro Global acts as our independent Merchant of Record and handles customer purchases of our digital courses, including checkout, payment processing, applicable taxes, invoicing, refunds, and chargebacks. PayPro Global processes personal data for its own payment-related activities as an independent Data Controller, in accordance with its Privacy Policy and applicable legal obligations.

Other third-party providers may also act as independent Data Controllers for certain processing activities, depending on their services and legal responsibilities.

4. What Personal Data May Be Collected

When a User visits the Website, creates an Account, accesses a course, or communicates with us, personal data may be collected or processed by MCM GRUP DOOEL uvoz-izvoz Skopje / Towers Method Academy, directly or through LearnWorlds and other third-party service providers acting on our behalf.

When a User purchases a course through PayPro Global, our Merchant of Record, we may receive limited customer, order, and payment-confirmation information necessary to provide course access, customer support, and related Services. PayPro Global separately collects and processes personal data in connection with its checkout and payment-related activities in accordance with its own Privacy Policy.

Depending on how the Website and Services are used, the following categories of personal data may be collected or processed:

1. Name and surname;

2. Email address and other contact information;

3. Account registration, login-related, and profile information processed through our learning platform;

4. Limited order, purchase, billing, invoice, payment-status, and transaction-related information, where applicable and where made available to us by PayPro Global, our Merchant of Record;

5. Course access information, course progress, lesson activity, quiz or assessment activity;

6. Communications sent to us or through the Website or learning platform;

7. Technical data, such as IP address, browser type, and operating system, which may be collected automatically through the Website or learning platform;

8. Website and learning platform usage data, including log-ins, pages visited, and activity within the platform;

9. Cookie and analytics data, where applicable; and

10. Marketing preferences and consent records, where applicable.

We do not intentionally collect special categories of personal data, such as health data, political opinions, religious beliefs, biometric data, or similar sensitive information. Users should avoid submitting such information through the Website or Services.

5. How Your Personal Data Is Collected

Personal data may be collected by us directly, processed through third-party service providers acting on our behalf, or received from PayPro Global in connection with course purchases. This may occur when you:

1. Register for or use an Account through our Website or learning platform; 

2. Purchase a course through PayPro Global, our Merchant of Record, which may provide us with limited customer and order-related information; 

3. Contact us by email or through contact options available on our Website or learning platform; or 

4. Visit or use our Website or learning platform, where certain technical and usage data may be collected automatically, including through cookies and similar technologies, subject to applicable consent requirements.

6. How Personal Data Is Used

Personal data is used to operate the Website, provide the Services, manage course access, communicate with Users, maintain security, comply with legal obligations, and improve the Website and Services.

Depending on the context, personal data may be used by MCM GRUP DOOEL uvoz-izvoz Skopje / Towers Method Academy directly or processed through third-party service providers acting on our behalf. PayPro Global, our Merchant of Record, separately processes personal data in connection with its checkout, payment, and related activities as an independent Data Controller, in accordance with its own Privacy Policy and applicable legal obligations.

Your personal data is used to:

1. create and manage User accounts; 

2. verify purchase and payment confirmation information received from PayPro Global, manage course access rights, handle support requests, and assist with refund or access-related requests; 

3. provide access to courses and learning materials; 

4. track course progress and platform activity; 

5. communicate about purchases, access, technical issues, support requests, and service updates; 

6. provide customer support; 

7. improve the Website, Services, course materials, and user experience; 

8. maintain the security of our Website and Services, prevent misuse, identify suspected fraudulent or unauthorized activity affecting our operations, and protect our rights; 

9. comply with legal, accounting, tax, and regulatory obligations; and 

10. send marketing communications where consent has been given or where otherwise permitted by law.

We do not sell or rent personal data.

7. Legal Basis for Processing

Where we act as a Data Controller, we process personal data on the following legal bases, depending on the purpose of processing:

1. Contract: where necessary to fulfil our contractual obligations relating to your Account, course access, and use of our Services;

2. Legitimate interests: where necessary to operate and improve our Website and Services, maintain security, prevent misuse, and protect our rights, provided these interests are not overridden by your rights and freedoms;

3. Consent: where required, for example for marketing communications and non-essential cookies; and

4. Legal obligation: to comply with our legal obligations under applicable law.

8. Marketing Communications

We may send marketing communications about our courses, products, services, offers, or educational content where permitted by applicable law and, where required, with your consent. Users may withdraw consent or unsubscribe from marketing communications at any time by clicking the unsubscribe link in our emails or by contacting us at info@towersmethodacademy.com.

Unsubscribing from marketing communications does not affect service-related communications necessary to provide our Services, including Account information, course enrolment and access details, responses to support requests, technical notices, security notices, and important changes affecting your use of our Services.

9. How Personal Data May Be Shared or Processed by Third Parties 

We do not sell or rent personal data.

Personal data may be shared with, received from, or processed by third-party service providers where necessary to operate the Website, deliver the Services, provide course access, send service-related communications, host content, provide analytics where applicable, maintain security, support purchase and refund administration, comply with legal obligations, resolve disputes, or protect our rights.

These providers may include, depending on the tools used at the time:

1. learning platform providers, including LearnWorlds; 

2. hosting and cloud storage providers; 

3. PayPro Global, our Merchant of Record, and other payment-related providers involved in relevant transactions, where applicable; 

4. email delivery and communication service providers; 

5. analytics and cookie providers; 

6. video hosting or content delivery providers; 

7. customer support tools; 

8. legal, accounting, tax, and professional advisers. 

Personal data may also be disclosed to public authorities, courts, regulators, or law enforcement where required by applicable law or otherwise lawfully permitted.

Where third-party providers process personal data on our behalf, we take reasonable steps to ensure that appropriate data protection arrangements are in place, as required by applicable law.

PayPro Global, our Merchant of Record, and certain other third-party providers may process personal data as independent Data Controllers for their own activities, in accordance with their respective privacy policies and applicable legal obligations.

We do not use personal data under our control to train artificial intelligence or machine learning models. If any third-party service provider uses artificial intelligence features, such processing will be subject to that provider’s applicable terms, privacy policy, and data protection obligations.

10. Payment Data

Course purchases and payments are handled by PayPro Global, our independent Merchant of Record, through its checkout and payment-processing services.

Towers Method Academy does not store credit card or debit card details on its own systems.

PayPro Global and the payment providers it uses may collect and process payment information, billing details, fraud-prevention information, transaction data, and related personal data in accordance with their respective terms, privacy policies, and applicable legal obligations.

Where necessary, we may receive or access limited customer, order-related, and payment-confirmation information made available by PayPro Global, such as payment status, order reference, transaction reference, invoice or receipt reference, billing contact information where provided, refund status, and course purchased. We may use this information to provide course access, maintain business records, reconcile sales, comply with legal obligations, resolve access or support issues, and protect our rights.

11. Cookies

Our Website uses cookies and similar technologies to support its operation, security, and essential functions, such as login sessions and remembering preferences. Other cookies, including analytics cookies, may be used where applicable and subject to applicable consent requirements.

For more information about the cookies used on our Website, their purposes, and how you can manage your preferences, please refer to our Cookie Policy.

12. Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected, including to provide the Services, maintain access and business records, comply with legal, accounting, tax, consumer protection, and regulatory obligations, resolve disputes, enforce agreements, and protect our rights.

Where personal data is processed by LearnWorlds, PayPro Global, our Merchant of Record, or other third-party service providers, it may be retained in accordance with the relevant provider's terms, privacy policy, applicable data processing agreements, legal obligations, and retention procedures, depending on the provider's role and responsibilities. Specifically:

12. 1. Data retained by MCM GRUP DOOEL uvoz-izvoz Skopje / Towers Method Academy

Basic account and course access records retained by MCM GRUP DOOEL uvoz-izvoz Skopje and/or Towers Method Academy, such as the learner’s name, email address, course enrolment, access entitlement, account status, email marketing consent records, and related support or access history where applicable, are retained for the duration of the learner’s active account.

After the account is no longer active, such data may be retained only for as long as necessary for record-keeping, legal compliance, dispute resolution, enforcement of agreements, protection of our rights, or other legitimate business purposes, and in any event no longer than permitted or required by applicable law.

Where retention is necessary for the establishment, exercise, or defense of legal claims, certain limited records may be retained for the period necessary under applicable law, including relevant statutory limitation periods.

12. 2. Data retained by the Merchant of Record or payment provider

PayPro Global, our Merchant of Record, and its relevant payment service providers may collect, process, and retain payment information, billing details, tax-related information, customer transaction records, refund and chargeback information, and other payment-related personal data in accordance with their respective privacy policies, applicable legal obligations, and retention procedures.

Towers Method Academy does not collect or store customers' payment card details or bank account information submitted during checkout on its own systems.

Where necessary, Towers Method Academy may receive, access, and retain limited customer, order-related, and payment-confirmation information made available by PayPro Global, such as the customer's name, email address, course purchased, payment confirmation status, order reference, transaction reference, and refund status. Such information may be retained for the purposes of providing course access, customer support, maintaining business records, reconciling sales, handling access issues, resolving disputes, complying with legal obligations, and protecting our rights.

Towers Method Academy may also receive and retain payout, settlement, invoice, remittance, and sales-summary records from PayPro Global in connection with periodic payouts made to MCM GRUP DOOEL uvoz-izvoz Skopje. Such records are retained for as long as necessary to comply with applicable accounting, tax, legal, audit, and business record-keeping obligations.

12. 3. Data retained by LearnWorlds and other third-party processors

Personal data processed through LearnWorlds or other third-party service providers acting as our processors may include platform-based learner data, such as account access information, course enrolment data, course progress, activity data, technical logs, communications, and other data necessary to operate the Website and provide the Services.

Where LearnWorlds processes personal data on our behalf, such data is generally retained for as long as necessary to provide the Services, subject to applicable legal obligations, valid data deletion requests, contractual arrangements, and relevant technical and operational requirements.

Following the end of the relevant services, or when processing is no longer required, LearnWorlds may delete, dispose of, or return personal data in accordance with its Data Processing Agreement, applicable law, platform settings, and technical and operational retention procedures.

When personal data under our responsibility is no longer required, we take appropriate steps to delete or anonymize it, unless continued retention is required or permitted by applicable law.

13. Your Rights

Under the GDPR and other applicable data protection laws, you may exercise the following rights, subject to the conditions and exceptions provided by applicable law:

1. The right to access your personal data; 

2. The right to correct inaccurate or incomplete personal data; 

3. The right to request deletion of your personal data; 

4. The right to request restriction of processing; 

5. The right to object to certain processing activities; 

6. The right to data portability, where applicable; and 

7. The right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before its withdrawal.

We do not use your personal data for automated decision-making or profiling. To exercise your rights concerning personal data for which MCM GRUP DOOEL uvoz-izvoz Skopje acts as a Data Controller, please contact us at info@towersmethodacademy.com.

For personal data independently processed by PayPro Global, please refer to PayPro Global's Privacy Policy for information about exercising your rights directly with them.

Where a request concerns personal data processed by us on behalf of another Data Controller, we will handle or refer the request as required by applicable law and relevant contractual arrangements.

We will respond to requests within the timeframe required by applicable law. Where permitted by law, this period may be extended if the request is complex or if multiple requests have been submitted.

14. Your Right to Withhold Information

You may access certain areas of the Website without providing personal data directly. However, purchasing courses through PayPro Global, our Merchant of Record, requires providing the information necessary to complete the purchase. Accessing courses through our learning platform requires the Account and enrolment information necessary to provide our Services.

You may manage your cookie preferences through the available cookie settings or your internet browser. Please note that restricting certain cookies may affect the functionality of the Website. For more information, please refer to our Cookie Policy.

15. Data Security

We take reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

Where LearnWorlds or other third-party service providers process personal data on our behalf, they are responsible for implementing appropriate security measures for the systems they operate, in accordance with applicable law and relevant contractual arrangements. PayPro Global, our independent Merchant of Record, and other third-party providers that process personal data independently are responsible for implementing appropriate security measures for their own systems, in accordance with their respective legal and contractual obligations.

However, no method of transmission over the internet or electronic storage is completely secure, and absolute security cannot be guaranteed.

16. International Data Transfers

Personal data may be processed, stored, or transferred outside North Macedonia, including to countries within the European Union, the European Economic Area, or other jurisdictions, depending on the location of our service providers and their subprocessors. PayPro Global, our Merchant of Record, is established in Canada and independently processes personal data in connection with its checkout and payment-related activities.

Where we transfer personal data internationally, directly or through service providers acting on our behalf, we take steps to comply with applicable data protection laws and implement appropriate safeguards where required. These may include recognized adequacy decisions, Standard Contractual Clauses, or other lawful transfer mechanisms, depending on the circumstances.

We take reasonable steps to protect personal data transferred internationally under our responsibility, in accordance with applicable data protection laws. Independent third-party Data Controllers, including PayPro Global, are responsible for meeting their own legal obligations concerning international data transfers.

17. Changes of Business Ownership and Control

MCM GRUP DOOEL uvoz-izvoz Skopje, as the operator of Towers Method Academy, may from time to time expand, reduce, restructure, sell, transfer, merge, or otherwise change all or part of its business, operations, assets, or services.

Where such a change involves personal data for which MCM GRUP DOOEL uvoz-izvoz Skopje is responsible, that data may be transferred to the relevant new owner, successor, purchaser, merged entity, or other party involved in the transaction, where necessary and permitted by applicable law for the continuation of the Services, the management of the business, compliance with legal obligations, or another lawful purpose.

Any such transfer will be handled in accordance with applicable data protection laws. Where required by applicable law, Users will be informed of the transfer and of any rights available to them in relation to their personal data.

Any subsequent processing of transferred personal data by the receiving party will be subject to applicable data protection laws, including requirements concerning lawful processing, purpose limitation, and transparency.

18. Adult Learners Only

Our courses are designed exclusively for adult learners aged 18 and over. We do not knowingly solicit personal data from individuals under 18 for the purpose of registering for or participating in our courses. 

If you are under 18, please do not register for an Account, purchase, or access our courses. 

If we become aware that someone under 18 has registered for or purchased a course, or has otherwise provided personal data in connection with our Services, we will take appropriate steps to address the situation, including restricting course access and deleting or otherwise handling personal data under our responsibility, in accordance with applicable law. 

If you believe this has occurred, please contact us at info@towersmethodacademy.com.

19. Third Party Links

Our Website may contain links to third-party websites and services, including PayPro Global's checkout. These third parties may process personal data in accordance with their own privacy policies. We encourage you to review the relevant privacy policies before providing any personal data. We are not responsible for the independent privacy practices of third-party websites or services, except where applicable law provides otherwise.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated date.

If we make significant changes to how we process your personal data, we will notify you by email or through a prominent notice on our Website.

Where a new or changed processing activity requires consent under applicable law, we will obtain the necessary consent before carrying out that activity.

21. Contact

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

MCM GRUP DOOEL uvoz-izvoz Skopje

Nikola Tesla Street, No. 9A, 1000 Skopje, North Macedonia 

info@towersmethodacademy.com