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, use, store, share, and protect personal data when you use our Website, create an account, purchase a course, access our Services, or communicate with us. By using our website or purchasing any of our courses, you agree to the terms of this Privacy Policy.

This Policy applies as between you, the User of this Website, and MCM GRUP DOOEL uvoz-izvoz Skopje, the owner and provider of this Website. This Policy applies to our use of any and all data collected by us in relation to your use of the Website and any Services or Systems therein.

2. Definitions and Interpretation

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

"Account" means the personal information, login credentials, course access information, payment confirmation information where applicable, and related details used by Users to access course materials and any communications systems on the Website.

"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 placed on your computer or device when you visit certain parts of this Website, used to identify recurring visitors and analyse browsing habits.

"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 MCM GRUP DOOEL uvoz-izvoz Skopje, the entity that determines the purposes and means of processing personal data under its control in connection with the Website and Services.

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

"Merchant of Record" means a third-party provider that may sell or resell our digital products or Services to customers, process customer payments, issue invoices or receipts, calculate and collect applicable taxes, handle payment-related compliance, manage chargebacks or disputes, and pay sales proceeds to MCM GRUP DOOEL uvoz-izvoz Skopje in accordance with its own terms, privacy policy, and legal obligations.

"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.

"System" means any online communications infrastructure made available through the Website, including web-based email, message boards, live chat facilities and email links.

"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 the Data Controller in relation to personal data collected, received, and processed for the purposes of operating the Website, providing the Services, managing course access, communicating with Users, maintaining business records, complying with legal obligations, and protecting our rights.

We use trusted third-party service providers, including LearnWorlds as our learning platform provider, hosting providers, analytics providers, email service providers, customer support tools, and other technical service providers, to help us operate the Website and deliver the Services. Where these providers process personal data on our behalf and in accordance with our instructions, they act as Data Processors.

In some cases, third-party providers may process personal data as independent controllers in accordance with their own terms, privacy policies, legal obligations, and data retention procedures. This may include, for example, payment providers, Merchant of Record platforms, checkout providers, banks, card networks, financial institutions, or other providers involved in payment processing, tax compliance, fraud prevention, invoicing, refunds, chargebacks, or regulatory compliance.

4. What Personal Data May Be Collected

When a User visits the Website, creates an account, purchases or accesses a course, or communicates with us, personal data may be collected directly by MCM GRUP DOOEL uvoz-izvoz Skopje / Towers Method Academy or processed through trusted third-party service providers used to operate the Website and provide the Services, including LearnWorlds, payment providers, Merchant of Record platforms, hosting providers, analytics providers, email service providers, and customer support tools.

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 login and profile information you choose to provide;

4. Limited order, billing, purchase, invoice, payment status, and transaction-related information, where applicable and where provided to us by the relevant payment provider, checkout provider, Merchant of Record, or learning platform;

5. Course access information, course progress, lesson activity, quiz or assessment activity, and platform usage data;

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

7. Technical data such as your IP address, browser type, and operating system (automatically collected);

8. 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 not submit such information through the Website or Services unless specifically requested and legally required.

5. How Your Personal Data Is Collected

Your personal data is collected when you:

1. Register for an account on our Website;

2. Purchase a course;

3. Contact us by email or through any communications system on the Website; or

4. Visit our Website, whereby some data is collected automatically through cookies and similar technologies.

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 trusted third-party service providers acting on our behalf. Some third-party providers, such as payment providers or Merchant of Record platforms, may also process personal data as independent controllers in accordance with their own terms, privacy policies, and legal obligations. 

Your personal data is used to:

1. create and manage User accounts; 

2. process orders, manage course access rights, confirm payment status where applicable, handle support requests, and manage 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 security, prevent misuse, detect fraud, 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 will never sell your personal data to any third party.

7. Legal Basis for Processing

We process your personal data on the following legal bases:

1. Contract: to fulfil our contract with you when you purchase a course;

2. Legitimate interests: to run and improve our school and services;

3. Consent: where required, for example for marketing communications; 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. 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 that are necessary to provide the Services, including account information, purchase confirmations, course access details, technical notices, policy updates, security notices, and important service announcements.

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 through trusted third-party service providers where necessary to operate the Website, deliver the Services, provide course access, send service emails, host content, provide analytics, maintain security, facilitate payment processing, 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. payment processors, Merchant of Record platforms, checkout providers, banks, card networks, and financial institutions; 

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; and 

9. public authorities, courts, regulators, or law enforcement where required by law. 

Where third-party providers process personal data on our behalf, we take reasonable steps to ensure that appropriate data protection arrangements are in place. Some third-party providers, including certain payment providers or Merchant of Record platforms, may process personal data as independent controllers under their own terms, privacy policies, and 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

Payments are processed by third-party payment providers, checkout providers, Merchant of record platforms, banks, card networks or financial institutions.

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

Payment providers may collect and process payment information, billing details, fraud-prevention information, transaction data, and related personal data in accordance with their own terms, privacy policies, and legal obligations.

Where necessary, we may receive limited order-related, access-related, and payment-confirmation information, such as payment status, order reference, transaction reference, invoice or receipt reference, billing contact information where provided, refund status, course purchased, or access entitlement, in order 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 to improve your browsing experience and collect usage data. For full details of what cookies we use, why we use them, and how you can manage them, 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, payment providers, Merchant of Record platforms, or other third-party service providers, such data may also be retained in accordance with the relevant provider’s terms, privacy policy, data processing agreement, legal obligations, and retention procedures. Specifically:

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 defence of legal claims, certain limited records may be retained for up to 5 years, unless a longer or shorter period is required or permitted by applicable law.

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

Where payments are processed through a third-party Merchant of Record, checkout provider, or payment provider, full payment card details, bank details, payment-processing data, tax calculation data, customer payment records, chargeback records, and other transaction data are collected, processed, and retained by that provider in accordance with its own terms, privacy policy, legal obligations, and data retention periods.

Towers Method Academy does not process or store full payment card details, bank details, or customer payment-processing data on its own systems.

Where necessary, Towers Method Academy may receive and retain limited order-related and access-related information from the Merchant of Record or payment provider, such as the customer’s name, email address, course purchased, payment confirmation status, order reference, transaction reference, refund status, and access entitlement, only 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 the Merchant of Record or payment provider 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.

[PAYMENT PROVIDER / MERCHANT OF RECORD DETAILS AND APPLICABLE RETENTION INFORMATION TO BE INSERTED ONCE CONFIRMED.]

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 the duration of the provision of the Services or until a valid deletion request is received, subject to applicable legal, accounting, tax, security, backup, contractual, technical, and compliance 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 is no longer required, it will be securely deleted or anonymised, unless continued retention is required or permitted by applicable law.

13. Your Rights

Under the GDPR and applicable data protection laws, you have the following rights:

1. The right to access your personal data;

2. The right to correct inaccurate or incomplete data;

3. The right to request deletion of your data;

4. The right to restrict or object to processing of your data;

5. The right to data portability; and

6. The right to withdraw consent at any time where processing is based on consent.

We do not use your personal data for automated decision-making or profiling. To exercise any of these rights, please contact us at info@towersmethodacademy.com. 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, to use all Services and Systems available on the Website, including purchasing and accessing courses, you will be required to submit Account information and other data.

You may restrict your internet browser's use of Cookies at any time. Please refer to our Cookie Policy for more information.

15. Data Security

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

Where personal data is processed through LearnWorlds, payment providers, Merchant of Record platforms, hosting providers, or other third-party service providers, those providers are responsible for implementing appropriate security measures for the systems they operate, in accordance with their own terms, privacy policies, data processing agreements, and legal 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 in countries outside North Macedonia, the European Union or the European Economic Area, depending on the location of our service providers and their sub-processors.

Where personal data is transferred internationally, appropriate safeguards required by applicable data protection law are used. These safeguards may include adequacy decisions, Standard Contractual Clauses, data processing agreements, contractual commitments with service providers, or other lawful transfer mechanisms, depending on the provider, destination country, and nature of the transfer.

We take reasonable steps to ensure that personal data transferred internationally is protected in accordance with applicable data protection requirements.

17. Changes of Business Ownership and Control

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 the transfer of personal data, personal data may be transferred to the relevant new owner, successor, purchaser, merged entity, or other party involved in the transaction, but only where necessary 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.

The new owner, successor, purchaser, or receiving party may use the transferred personal data only for the purposes for which it was originally collected, unless another lawful basis applies or Users are informed otherwise in accordance with applicable law.

18. Adult Learners Only

Our courses are designed exclusively for adult learners aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, please do not use our Website or attempt to purchase our courses. If we become aware that we have inadvertently collected personal data from someone under 18, we will take appropriate steps to delete or otherwise handle such data 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. We are not responsible for their privacy practices and encourage you to read their privacy policies before providing any personal data to those sites.

20. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with an updated date. If we make significant changes to how we treat your personal data, we will notify you by email or through a prominent notice on our website. Where required by applicable law, we will request renewed consent before carrying out any new processing activity that requires consent.

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