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:
- META Group (Italy)
- Business Angels Europe (Belgium)
- Bpifrance / EuroQuity (France)
- UK Business Angels Association (UK)
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):
- First name
- Last name
- Email address
- Password
Additional information (collected via custom fields):
- Organisation / Company
- Country or region
- How you heard about this course
- Marketing consent (optional)
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:
- ESIL consortium partners (META Group, Business Angels Europe, Bpifrance/EuroQuity) for programme delivery and reporting;
- MOOC developer (UKBAA)
- Verified Business Angel Networks in your region for relevant professional networking and collaboration opportunities (only if you have opted in);
- Thinkific Labs Inc., which provides the course platform and acts as a data processor;
- The European Innovation Council and its implementing agencies, for monitoring and reporting purposes under the ESIL/EIC framework.
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:
- Administer your participation in the ESIL MOOC,
- Comply with EU funding reporting obligations, and
- Meet legal or regulatory requirements.
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:
- Access – to obtain a copy of the personal data we hold about you;
- Rectification – to correct inaccuracies in your data;
- Erasure (“right to be forgotten”);
- Restriction of processing;
- Data portability – to receive your data in a machine-readable format;
- Objection – to object to processing based on legitimate interests;
- Withdrawal of consent – to withdraw your consent at any time.
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:
- Enable site functionality,
- Analyse engagement and learning progress, and
- Improve user experience.
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.