PRIVACY POLICY

Effective Date: 14th November 2025
Controller: META Group (on behalf of the ESIL initiative)
Contact: [email protected]

1. Introduction

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you register for and participate in the ESIL MOOC course (named ‘‘ESIL Angel Academy’’) hosted on the Thinkific platform.

The course is developed by the UK Business Angels Association (UKBAA) as part of the Early Stage Investing Launchpad (ESIL) initiative, co-funded by the European Commission (EIC/EISMEA).

For the purposes of the General Data Protection Regulation (GDPR), the data controller is META Group, acting on behalf of the ESIL partnership, which includes:

Thinkific Labs Inc. (Canada) acts as the data processor, providing the hosting and technical platform under a Data Processing Agreement compliant with GDPR standards.

2. Personal Data We Collect

When you register for the ESIL MOOC, we collect the following personal data:

Mandatory information (required by Thinkific):

Additional information (collected via custom fields):

We may also collect usage data (e.g. course progress, quiz scores, login activity) and analytics information through Thinkific to help improve our course experience.

3. How We Use Your Data

We process your personal data for the following purposes:

Purpose

Lawful Basis under GDPR

To register you as a learner on the MOOC

Performance of a contract

To provide course access, support, and updates

Performance of a contract

To analyse participation and improve the course

Legitimate interest

To communicate with you about similar courses, events, and opportunities related to early-stage investment

Consent

To share your contact details with verified Business Angel Networks in your region for networking purposes

Consent

To comply with EU funding and reporting obligations

Legal obligation / Legitimate interest

You can withdraw your consent at any time by contacting us at [email protected] or updating your preferences in your Thinkific account.

 

4. Data Sharing and Disclosure

Your data may be shared only as necessary with:

All partners are contractually bound to protect your data and process it only in accordance with GDPR.

We do not sell, rent, or otherwise disclose your personal information to third parties for commercial gain.

5. International Data Transfers

Because the Thinkific platform is hosted by Thinkific Labs Inc. in Canada, your personal data may be transferred outside the EU/EEA.

Canada benefits from an adequacy decision by the European Commission, ensuring that your data receives an equivalent level of protection as under EU law.

If data is transferred outside the EEA to other jurisdictions, this is done under Standard Contractual Clauses (SCCs) or other legally approved safeguards.

6. Data Retention

We retain your personal data only for as long as necessary to:

Course participation data will be stored for up to five years following project completion unless you request deletion earlier.

7. Your Rights Under the GDPR

You have the following rights regarding your personal data:

To exercise these rights, please contact us at [email protected]. If you believe your rights have been infringed, you may lodge a complaint with your local Data Protection Authority.

 

8. Security of Your Data

We use appropriate technical and organisational measures to protect your personal data against loss, misuse, or unauthorised access.

Thinkific also maintains secure servers and encryption mechanisms in compliance with GDPR and Canadian privacy laws.

9. Cookies and Tracking

The Thinkific platform and the ESIL website use cookies to:

You can manage or disable cookies in your browser settings. See Thinkific’s Cookie Policy for more details.

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10. Contact Details

Data Controller:
 META Group S.r.l.
 Via Francesco Mancini 23, 05100 Terni, Italy
Email: [email protected]

ESIL Partner Contacts:

Business Angels Europe (Belgium) – [email protected]

Bpifrance / EuroQuity (France) – [email protected]

Developer contact:

UK Business Angels Association (UK) – [email protected]

Data Processor:
 Thinkific Labs Inc.
 #400 – 369 Terminal Avenue, Vancouver, BC, V6A 4C4, Canada
[email protected]

 

11. Updates to This Policy

This Privacy Policy may be updated periodically. Any significant changes will be communicated via the Thinkific platform or by email.
 Your continued use of the ESIL MOOC after such updates constitutes your acceptance of the revised policy.