Privacy Policy
Last Updated: 07 Aug 2025
Effective for: pouyaeti.com, university.pouyaeti.com, and all associated domains
IMPORTANT PRIVACY NOTICE
This Privacy Policy describes how Pouya Eatemadi Rad (operating as Pouya Eti) collects, uses, and protects your personal information in compliance with international privacy laws including GDPR, CCPA, and UAE Data Protection Law.
1. Data Controller Information
This Privacy Policy applies to all personal information collected and processed by:
- Data Controller: Pouya Eatemadi Rad (operating as Pouya Eti)
- Websites Covered: pouyaeti.com, university.pouyaeti.com, and all subdomains
- Services: Udemy Passive Profit Program, Traffic Insights Accelerator, and related educational content
2. Legal Basis for Processing (GDPR Compliance)
We process your personal information based on the following legal grounds:
- Contract Performance: Processing necessary for course delivery, account management, and customer support
- Legitimate Interest: Website analytics, service improvement, fraud prevention, and security measures
- Consent: Marketing communications, non-essential cookies, and newsletter subscriptions
- Legal Obligation: Compliance with tax, regulatory, and legal requirements
3. Information We Collect
Personal Information You Provide:
- Account Information: Name, email address, username, password
- Payment Information: Billing address, payment method details (processed securely by third-party processors)
- Course Interaction: Progress tracking, completion status, quiz results, assignments submitted
- Communication Data: Support requests, feedback, survey responses, forum posts
- Profile Information: Bio, profile picture, professional background (optional)
Information We Collect Automatically:
- Technical Data: IP address, browser type, device information, operating system, screen resolution
- Usage Data: Pages visited, session duration, click patterns, referral sources, search terms
- Location Data: General geographic location based on IP address (city/country level)
- Performance Data: Website loading times, error reports, system diagnostics
Information from Third-Party Sources:
- Social Media: If you connect social media accounts or share our content
- Payment Providers: Transaction confirmations and payment status from Stripe, PayPal
- Analytics Services: Website performance data from Google Analytics
- Course Platforms: Learning progress data from Kajabi hosting platform
4. How We Use Your Information
Essential Service Operations:
- Providing access to courses and educational materials
- Processing payments and managing subscriptions
- Creating and maintaining user accounts
- Delivering customer support and technical assistance
Communication and Marketing:
- Sending course updates, announcements, and educational content
- Marketing communications about new courses and services (with consent)
- Responding to inquiries and providing customer support
- Conducting surveys and collecting feedback for service improvement
Analytics and Improvement:
- Analyzing website usage patterns and user behavior
- Improving course content and user experience
- Conducting A/B tests for website optimization
- Generating anonymized statistics and insights
Legal and Security:
- Complying with legal obligations and regulatory requirements
- Preventing fraud, abuse, and security threats
- Protecting intellectual property rights
- Maintaining audit trails and business records
5. Comprehensive Cookie Policy
Cookie Categories and Consent Management
Essential Cookies (No Consent Required):
- Session management and user authentication
- Course progress tracking and saved preferences
- Security and fraud prevention
- Payment processing and transaction security
Analytics Cookies (Consent Required):
- Google Analytics: Website traffic analysis, user behavior insights
- Hotjar: Heatmaps and user session recordings (if implemented)
- Facebook Analytics: Social media performance tracking
- Opt-out Options: Google Analytics Opt-out
Marketing Cookies (Consent Required):
- Facebook Pixel: Personalized advertising and conversion tracking
- Google Ads: Remarketing and advertisement performance
- LinkedIn Insight: Professional audience targeting
Cookie Consent Management: You can modify your cookie preferences at any time through our consent management system or your browser settings. Blocking certain cookies may limit website functionality.
6. Data Sharing and Third-Party Processors
WE NEVER SELL YOUR PERSONAL INFORMATION. We only share data with trusted service providers for specific business purposes:
Essential Service Providers:
- Course Hosting: Kajabi (course delivery platform)
- Payment Processing: Stripe, PayPal (PCI DSS compliant processors)
- Email Services: ConvertKit, Mailchimp (marketing communications)
- Cloud Storage: Amazon Web Services, Google Cloud (secure data hosting)
Analytics and Marketing:
- Website Analytics: Google Analytics (anonymized data)
- Social Media: Facebook, Instagram, LinkedIn (advertising pixels)
- Customer Support: Zendesk, Intercom (help desk services)
Legal and Compliance:
- Legal Authorities: When required by law, court order, or regulatory request
- Business Protection: To protect our rights, property, safety, or investigate fraud
- Business Transfers: In case of merger, acquisition, or business sale (with notice)
7. International Data Transfers and Safeguards
INTERNATIONAL BUSINESS NOTICE: Our business operates from Dubai, UAE, and serves customers worldwide. Your personal information may be transferred to and processed in countries different from your residence.
Data Transfer Protections:
- Adequacy Decisions: Transfers to countries with EU adequacy decisions when possible
- Standard Contractual Clauses: EU-approved contracts with processors in non-adequate countries
- Privacy Shield (Legacy): For US-based processors with valid Privacy Shield certification
- Explicit Consent: For transfers where other safeguards are not available
Specific Transfer Arrangements:
- UAE Processing: Primary data processing occurs in Dubai, UAE
- US Services: Google Analytics, Facebook, Kajabi (with Standard Contractual Clauses)
- EU Services: When available, we prioritize EU-based alternatives
8. Your Privacy Rights
GDPR Rights (European Union Users):
- Right to Access: Request copies of your personal data and processing information
- Right to Rectification: Correct inaccurate or incomplete personal information
- Right to Erasure: "Right to be forgotten" (with legal limitations for business records)
- Right to Restrict Processing: Limit how we process your data in certain circumstances
- Right to Data Portability: Receive your data in a structured, machine-readable format
- Right to Object: Opt-out of processing based on legitimate interests or direct marketing
- Rights Related to Automated Decision-Making: Contest purely automated decisions (including profiling)
CCPA Rights (California Residents):
- Right to Know: Categories and specific pieces of personal information collected
- Right to Delete: Request deletion of personal information (with business exceptions)
- Right to Opt-Out: "Do Not Sell My Personal Information" (we don't sell data)
- Right to Non-Discrimination: Equal service regardless of privacy rights exercise
- Right to Correct: Request correction of inaccurate personal information
How to Exercise Your Rights:
- Email: support@pouyaeti.com
- Subject Line: "Privacy Rights Request - [Specific Right]"
- Identity Verification: We may request verification to protect your privacy
- Response Time: 30 days (GDPR) or 45 days (CCPA) from verified request
- No Fee: Rights requests are processed free of charge
9. Data Security Measures
Technical Safeguards:
- Encryption: SSL/TLS encryption for all data transmission
- Access Controls: Role-based access with multi-factor authentication
- Regular Updates: Security patches and system updates
- Firewall Protection: Network security and intrusion detection
- Secure Backups: Encrypted backup storage with access controls
Organizational Safeguards:
- Staff Training: Regular privacy and security awareness training
- Data Minimization: Collect only necessary information for stated purposes
- Vendor Assessment: Security evaluation of all third-party processors
- Incident Response: Documented breach notification and response procedures
Data Breach Notification:
In the event of a personal data breach, we will:
- Notify supervisory authorities within 72 hours (GDPR requirement)
- Inform affected users without undue delay when high risk to rights and freedoms
- Document all breaches and remediation measures taken
- Conduct post-incident reviews to prevent future breaches
10. Data Retention Policy
Retention Periods:
- Account Data: Retained while account is active plus 2 years after closure
- Course Progress: Maintained for lifetime access or until account deletion
- Payment Records: 7 years for tax and accounting requirements
- Marketing Data: Until unsubscribe or consent withdrawal
- Support Records: 3 years for quality assurance and issue resolution
- Legal Documentation: As required by applicable laws and regulations
Deletion Procedures:
- Automated deletion based on retention schedules
- Secure data destruction using industry-standard methods
- Third-party processor notification for coordinated deletion
- Backup purging according to retention policies
11. Children's Privacy Protection (COPPA)
AGE RESTRICTION: Our services are intended for users 18 years and older. We do not knowingly collect personal information from children under 13 years of age.
If we become aware of collecting information from a child under 13:
- We will immediately delete all personal information
- We will terminate any associated accounts
- We will implement additional safeguards to prevent future collection
- Parents may contact us to request information deletion
12. Marketing Communications and Opt-Out
Types of Communications:
- Transactional Emails: Course access, payment confirmations, account updates (essential)
- Educational Content: Course announcements, learning tips, industry insights
- Promotional Materials: New course launches, special offers, affiliate promotions
- Newsletters: Weekly/monthly updates about business and marketing strategies
Consent Management:
- Double Opt-in: Email confirmation required for newsletter subscriptions
- Clear Consent: Separate checkboxes for different communication types
- Easy Unsubscribe: One-click unsubscribe in all marketing emails
- Granular Control: Choose specific types of communications to receive
13. Third-Party Websites and Services
Our websites may contain links to third-party sites including:
- Social Media Platforms: Facebook, Instagram, LinkedIn, YouTube
- Partner Websites: Affiliate partners and recommended tools
- Payment Processors: Stripe, PayPal checkout pages
- Course Platforms: Udemy, Kajabi external links
IMPORTANT: We are not responsible for the privacy practices of these third parties. Please review their privacy policies before providing personal information.
14. California "Shine the Light" Law
California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes.
Our Policy: We do not share personal information with third parties for their direct marketing purposes without explicit consent. To request information about our disclosure practices, contact privacy@pouyaeti.com.
15. Updates to This Privacy Policy
Policy Changes: We may update this Privacy Policy to reflect:
- Changes in applicable privacy laws and regulations
- New features, services, or business practices
- Enhanced security measures or data protection practices
- User feedback and privacy enhancement requests
Notification Process:
- Material Changes: 30 days advance notice via email
- Minor Updates: Website notification and updated effective date
- Continued Use: Constitutes acceptance of updated policy
- Withdrawal Option: You may close your account if you disagree with changes
16. Contact Information and Data Protection
Privacy Inquiries and Data Requests:
General Support: support@pouyaeti.com
Website: pouyaeti.com
Course Platform: university.pouyaeti.com
Response Time: We respond to privacy inquiries within 72 hours