Millennials With Money

This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to and user of our Thinkific profile at https://millennialswithmoney.thinkific.com/. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. In this sense, Millennials With Money OÜ, Tornimäe 3, 10145 Tallinn, Estonia (“Millennials With Money”, “we”, “us”, “our”) is the data controller. If you have any questions about data protection at Millennials With Money in general, you can reach us by email using [email protected].

WHAT IS PERSONAL DATA?

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

WHY DO WE HAVE A PRIVACY POLICY?

Estonia's Personal Data Protection Act (“PDPA”) and the EU's General Data Protection Regulation (“GDPR”) control how your Personal Data is used by us. We are also required to explain which Personal Data we collect from you via our Thinkific profile, what we use it for, when we delete it and what rights you have.

WHAT IS PROCESSING?

Processing means any operation or set of operations which is performed on Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

WHICH PERSONAL DATA DO WE COLLECT?

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data including first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data including billing address, delivery address, email address and telephone numbers.
• Transaction Data including details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Thinkific profile.
• Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data including information about how you use our Thinkific profile, products and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Thinkific profile feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you: apply for our products or services; create an account on our Thinkific profile; subscribe to our service or publications; request marketing to be sent to you; enter a survey; or give us some feedback or contact us.
• Automated technologies or interactions. As you interact with our Thinkific profile, we will automatically collect Technical Data about your equipment, Browse actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other platforms employing our cookies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. 

HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have given us your consent.
• We will not sell your data to third parties.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We plan to use your Personal Data for the following purposes, relying on the specified legal bases:

• To register you as a new customer: We use your Identity and Contact Data for the performance of a contract with you.
• To enable your access to and participation in the course: We use your Identity, Contact, Profile, Usage, and Transaction Data for the performance of a contract with you and where necessary for our legitimate interests (to deliver the course services effectively and enhance user experience).
• To process and deliver your order: This includes managing payments, fees, and charges, and collecting and recovering money owed to us. We use your Identity, Contact, Financial, Transaction, and Marketing and Communications Data for the performance of a contract with you and where necessary for our legitimate interests (to recover debts due to us).
• To manage our relationship with you: This includes notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey. We use your Identity, Contact, Profile, and Marketing and Communications Data for the performance of a contract with you, to comply with a legal obligation, and where necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
• To enable you to partake in a survey: We use your Identity, Contact, Profile, Usage, and Marketing and Communications Data for the performance of a contract with you and where necessary for our legitimate interests (to study how customers use our products/services to develop them and grow our business).
• To administer and protect our business and this Thinkific profile: This includes troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data. We use your Identity, Contact, and Technical Data where necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and to comply with a legal obligation.
• To deliver relevant Thinkific profile content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you: We use your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data where necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
• To use data analytics to improve our Thinkific profile, products/services, marketing, customer relationships and experiences: We use your Technical and Usage Data where necessary for our legitimate interests (to define types of customers for our products and services, to keep our Thinkific profile updated and relevant, to develop our business and to inform our marketing strategy).
• To make suggestions and recommendations to you about goods or services that may be of interest to you: We use your Identity, Contact, Technical, Usage, Profile, and Marketing and Communications Data where necessary for our legitimate interests (to develop our products/services and grow our business).

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out above.

THINKIFIC

Our online course offering utilizes Thinkific, a Learner Management System (LMS) provided by Thinkific Labs Inc., which is also in charge of the sign-up process. Clicking on the "Log In" or "Sign up" button on our Thinkific profile will redirect you to pages hosted by Thinkific. Stripe payment is dealt with through Thinkific.

Participation in the online courses offered by us requires registration by providing personal data. In the process, the data is entered into an input mask and transmitted to us and stored. Upon our request, Thinkific may also access this data. The following data is collected as part of the registration process:

• First and last name
• E-mail address
• Password
• Payment information

The following data is also stored at the time of registration:

• The user's IP address
• Date and time of registration

As part of the registration process, the user's consent to the processing of this data is obtained. The legal basis for the processing of the data, is your consent and the performance of a contract.

The prerequisite for participation in the online courses offered by us is the effective conclusion of a contract. In this context, the registration of the user serves to identify the contracting party. After conclusion of the contract, the e-mail address and selected password from the registration mask serve as login information for each login. In addition, we use the data entered during registration to contact you by e-mail in connection with courses you have attended.

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected.

As a user, you have the option of cancelling your registration or changing the data stored about you at any time under the menu item "My Account" in the main menu. Premature deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.

MARKETING

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your Personal Data with the parties set out below for the purposes set out in the section "PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA" above.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer your Personal Data outside the European Economic Area (EEA).

DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:

• Right to be informed about what Personal Data we collect from you, and why.
• Right of access to your Personal Data.
• Right to rectification of your Personal Data if it is inaccurate or incomplete.
• Right to erasure of your Personal Data.
• Right to restrict processing of your Personal Data.
• Right to data portability of your Personal Data.
• Right to object to the processing of your Personal Data.
• Right to withdraw consent.
• Right to complain to a supervisory authority.
• Right not to be subject to a decision based solely on automated processing, including profiling.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

UPDATING YOUR INFORMATION

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

ACCESS REQUEST

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

COMPLAINT TO A SUPERVISORY AUTHORITY

The supervisory authority in Estonia is the Data Protection Inspectorate (Andmekaitse Inspektsioon) (www.aki.ee). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Inspectorate or any other supervisory authority.

WHAT WE DO NOT DO

We do not request Personal Data from minors and children; We do not process special category data without obtaining prior specific consent; and We do not use Automated decision-making including profiling.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you please contact us by email using [email protected].

CHANGES

The first version of this policy was issued on Saturday, 12th of July, 2025 and is the current version. Any prior versions are invalid and if we make changes to this policy, we will revise the effective date.