Privacy and Cookie Policy

This Privacy Policy explains what personal information we hold about you, how we obtain or receive it, and how we use and may share information about you. It relates to any personal information:

·       we collect from you (as detailed further in ‘Information We Collect About You’ and ‘Information We Collect Automatically’ below);

·       you provide to us (as detailed further in ‘Information We Receive Directly From You’ below); or

·       is provided to us from other sources (as detailed further in ‘Information Received from Other Sources’ below).

This Privacy and Cookie Policy should be read together with our Terms and Conditions.

There may be other privacy policies or terms and conditions that apply to certain services we provide or promotions/competitions we run. Please always read these when you register for these services or participate in these promotions.

The Website (as defined below) may, from time to time, contain links to websites owned and/or controlled by third parties, or third-party websites may link to our Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites, are not responsible for their compliance with data protection laws, and you should carefully consider the privacy practices of these third parties.


Who we are

When you visit our Website, use our services or products, or interact with us via our Social Media Pages or otherwise provide information to us - (‘us’, ‘our’ and ‘we’) is a ‘data controller’ and gathers and uses certain personal information about you (known under data protection laws as ‘personal data’). When we do so we are regulated under the EU General Data Protection Regulation, the UK Data Protection Act 2018. Swiss Data Protection Act (DPA). is a brand and domain name registered by Learning Tools 21C, a limited liability company having it’s office at Borrens street, 51, 1050, Brussels, Belgium.  VAT number BE-0753602502

For any queries regarding your personal data, please contact us at


Information we collect about you

We may collect personal information from you via:

·       our Website

·       our Social Media Pages: social media pages and accounts under the name of “”

We collect the following information about you to provide the best service and inform about our company

·       Your name

·       Your contact details, such as phone, address and email

·       Information we receive directly from you

Whenever you interact with us directly, we receive information from you, for example when you:

·       buy our products on our Website or via our Customer Service.

·       purchase a gift card

·       attend events including online webinars organised by

·       provide feedback to us or complete a survey about

·       contact us, for example via the contact form on our Website, social media, phone, email or by letter

·       sign up to receive any of our email newsletters and marketing

·       enter any competitions or prize draws we run

·       submit content to us, for example if you post a selfie and use one of our hashtags on your public social media account in response to one of our competitions

Information received from other sources

Sometimes we also obtain information about you from other sources, for example when you:

·       purchase a gift card or products on our Website – we receive information from our payment gateway Stripe, PayPal

·       complete one of our surveys – we receive your answers and any personal information you provide within your answers from Survey Monkey, Google forms

For more details about the types of information we receive from these and other sources, including where it is held and where it came from, see the table under the section ‘More about the information we collect and hold’ at the bottom of this policy.

Information we collect automatically

When you access and browse any of our Website or use our services, we collect information about your usage, location and activity on our Website or services using certain technologies, such as cookies and web beacons. Depending on the cookie settings in your browser and the cookie preferences you set when you first access our Website, our third-party service providers and/or partners may also place view, edit, or set their own cookies. To find out more about cookies, including how we use them and what choices are available to you

Managing cookies on the Website

When you first visit our Website, we do not set cookies on your device (other than essential cookies) unless you accept/enable all cookies, or select your own cookie preferences.

You can manage your cookie preferences at any time via Cookie Settings. However, please be aware that if you choose not to enable cookies it may prevent you from taking full advantage of the Website and some parts of the Website may fail to work.

What are cookies?

Cookies are text files containing small amounts of information which are placed on your computer or device when you visit our website.

What are cookies used for?

Cookies (and other technologies, like pixels and beacons) do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They also help us understand how our website is being used and can help to ensure that adverts you see online are more relevant to you and your interests.

Cookies can be “First Party”, i.e. set by us, or “Third Party”, i.e. placed on your device by another company when you visit our website, for example Google Analytics or Advertising cookies. Third-party cookies may be placed on your device by someone providing a service to us (for example, we use Google Analytics to help us understand how our website is being used) or by our business partners, so that they can advertise products and services to you on our website and elsewhere on the Internet. Because of how cookies work, our website cannot access third-party cookies; nor can other organisations access the data in the cookies we use on our website.

What cookies do we use?

We use four types of cookies, which we describe in this section. You can also find a full list of all different first and third-party cookies that we use in the table below.

Essential cookies. These are cookies that are essential for the operation of our website. They include, for example, cookies that enable you to navigate through pages, log into secure areas of our website, use a shopping cart or make use of e-billing services.

Performance cookies. These help us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We also use third-party cookies to help with performance. For example, the Google Analytics cookie allows us to recognise and count the number of visitors to our website, see what pages are popular and see how visitors move around our website when they are using it.

Functionality cookies (inc. social media). A mix of first-party and third-party cookies are used. For example, we use some social sharing plugins, to allow you to share certain pages of our website on social networks.

Targeting/advertising cookies. These third-party cookies record your visit to our website, the pages you have visited and the links you have followed. We do not use any of these type of cookies.

How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

Browser and third party cookies

You can also find out how to manage cookies for your particular browser by clicking “help” on your browser’s menu or by visiting

Why and how we use your personal information

Generally, the reasons we use your personal information and the legal bases on which we rely in each instance where we collect and use your personal information, are:

·       to fulfil and enforce our Terms and Conditions, and any other contract we have with you including to enable you to partake in our prize promotions/competitions.

·       where you have consented to our use of your personal information, which, for newsletters and marketing you may revoke at any time by clicking the ‘Unsubscribe’ option at the bottom of our emails – if you’re having any issues unsubscribing please email

·       as necessary for our (or others’) legitimate interests – including our interests in providing safe Website, products and services, fraud detection, personalising your experience using our products and services, knowing how customers use our Website, services and products, keeping our Website, products and services updated and relevant, to maintain and improve our services, products and our Website’ infrastructure, and developing our business and informing our marketing strategy – but only if these are not overridden by your interests, rights or freedoms.

We’ve outlined in more detail in the table below and in our Cookies Policy, what categories of personal information we collect about you, why each category of personal information we collect from you is required for us to be able to perform the purpose to which it relates (including the legal basis on which we rely) and the ways in which we use it. We seek to ensure that our information collection and processing is always proportionate to the purpose we need to achieve. We will inform you, at the point of collecting information from you, whether you are required to provide the information to us or not. We will notify you of any changes to the information we collect from you or to the purposes for which we collect and process it.

Who we share your personal information with

With third-parties. We work with vendors, suppliers and other companies who help us support our business, and help us provide and improve our products and services (including our Website), for example, by providing technical infrastructure, assisting us to send our marketing and newsletters to customers who have consented to receive same, analysing how our Website and services are used, providing customer service, facilitating payments, conducting surveys or providing fraud detection service. We may also need to share personal information with other parties, such as external contractors and our professional advisers and potential purchasers of some or all of our business or on a restructuring.

Usually, information will be anonymised but this may not always be possible. Sometimes, these third parties may need to have access to your personal information to provide us with services or to provide services on our behalf. We may also be required to share some personal information as required to comply with the law. In the table under the section ‘More about the information we collect and hold’ at the bottom of this policy and the paragraphs below we name third parties (or where this is not possible, name the categories of third parties) with whom the information we collect and hold about you may be shared.

We contractually bind all third parties with whom we share personal information to keep your information confidential and to use it only for the purpose of providing their services and pursuant to the applicable privacy legislation in the EU. Some of these third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal information when this occurs, see the section about ‘Transfer of your information out of the EEA’ below.

How long your personal information will be kept

We will keep your personal information while we are providing any services to you (including any marketing or newsletter services). Thereafter, we will keep your personal information for as long as is necessary:

·       to respond to any questions, complaints or claims made by you or on your behalf

·       to show that we treated you fairly

·       to keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy and we will delete or anonymise your personal information when it is no longer necessary to retain it. Different retention periods apply for different types of personal information. If you require further details, please see below ‘How to contact us’.

Transfer of your information outside the EEA

To deliver the Website and our Services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:

·       with your and our suppliers or service providers located outside the EEA

·       if you are based outside the EEA

These transfers are subject to special rules under European and UK and Swiss data protection laws. Prior to permitting such transfers, we ensure all personal information transferred will be kept secure. Our standard practice is to use standard data protection model contract clauses that have been approved by the European Commission (as permitted under Article 46(2) of the General Data Protection Regulation) or to only transfer your data to companies that are registered with the Privacy Shield (for transfers to the USA). If you would like further information please see ‘How to contact us’ below.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being used, destroyed, lost, altered, disclosed or accessed either accidentally or without authorisation. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner, where permitted by law and are subject to a duty of confidentiality. We continually test our systems to make sure the level of security matches any risk and we run regular security tests. Our data servers are located in Switzerland. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Privacy Policy

We may vary this Privacy Policy from time to time. When we do we will post the changes on the Website. Where the changes are significant, we will inform all our current customers or subscribers by email. Where required by law, will we obtain your consent to make these changes.

How to contact us

If you have any questions about this Privacy Policy or the information we hold about you, please contact us by sending a email to

Learning Tools 21C LTD
Chaussee d'Alsemberg 995, 1180 Brussels, Belgium
Phone +32 471 62 40 39