Privacy Policy
Version 2.0 | Last updated: 4 September 2026
1. Who is responsible for your data
Eicca Production Oy is the data controller for the personal data described in this policy. We are registered in Finland under business ID 1630761-3, with our registered address at Opastinsilta 3 lt. 2, 00520 Helsinki, Finland. We trade as Coaching by Eicca.
For anything relating to your data, contact us at support@coachingbyeicca.com.
This policy covers both of our websites, our main site at coachingbyeicca.com and the course platform at courses.coachingbyeicca.com, and the messages you send us on Instagram and Facebook. It replaces the two separate policies we published previously.
We are not required to appoint a Data Protection Officer and have not appointed one.
2. What we collect
If you buy the course. We collect your name, email address, billing address and country, and the details of your purchase. We do not collect or store your card number. Payment card details are handled directly by our payment processor.
You need to give us your name, email address and billing details in order to buy the course. Without them we cannot complete the sale.
When you use the course. We collect your login activity, which lessons you have opened and completed, and any progress or notes you save within the platform.
If you use the contact form on our main site. We collect the information you enter on the form, which reaches us by email and is stored there.
If you contact us directly. We keep your message and our reply.
If you sign up for our emails without buying. We collect your name and email address.
If you message us on social media. If you message us on Instagram or Facebook, or comment on one of our posts and we reply to you privately, we receive your username, your profile picture and the content of your messages. If you give us your email address in one of those conversations, we collect that too. We do not receive your password or anything else from your social media account.
Technical information. We also collect standard technical information when you visit either site, including your IP address, browser type and the pages you view. Our use of cookies is described in clause 13.
3. Why we use it, and on what legal basis
We use your data to give you access to the course, to take payment, to send you the emails that accompany the course, and to provide support. The legal basis is the performance of our contract with you.
We keep records of sales and payments to meet our accounting and tax obligations. The legal basis is compliance with a legal obligation.
We use technical and login data to keep the platform secure and working properly, and we look at aggregate course progress to understand how the course is used and how to improve it. The legal basis is our legitimate interests in running and improving our business. We have carried out a balancing assessment and consider this proportionate.
If you agree to analytics and marketing cookies, we use them to understand how the site is used and to measure and target our advertising, as described in clause 13. The legal basis is your consent.
Enquiries through the contact form. We use what you send us to reply to you about the services you have asked about. The legal basis is our legitimate interest in responding to people who contact us, or the steps taken at your request before entering a contract. If we cannot help you at the time, we may contact you later about our services only if you have agreed to that.
Messages on social media. We use the messages you send us on Instagram and Facebook to answer your questions and to send you the information you have asked for. The legal basis is our legitimate interest in replying to people who contact us. If you give us your email address so that we can send you something or add you to our mailing list, we use it on the basis of your consent, and you can withdraw that consent at any time.
Marketing to people who have not bought. If you gave us your email address without buying, we send you marketing emails on the basis of your consent. You can withdraw that consent at any time.
Marketing to existing customers. If you have bought from us, we may send you information about similar products and services on the basis of our legitimate interest. We gave you a clear and easy opportunity to opt out at the point we collected your details, and every message we send contains an unsubscribe link.
4. Who we share it with
We do not sell your data and we do not share it for anyone else's marketing.
We share data with the following service providers, who process it on our behalf and under contract:
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Wix, which hosts our main website at coachingbyeicca.com and stores the messages sent through the contact form there. Your data is held on Wix's secure servers.
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Kajabi, which hosts the course platform, stores your account and progress data, and sends the course emails. Kajabi engages its own sub-processors, including providers of cloud hosting, email delivery and platform analytics. We can give you details of these on request.
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Stripe, which processes card payments through Kajabi Payments. Stripe is certified to the PCI DSS standard, which governs the secure handling of card data.
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Google, which provides our business email, so any message you send us is stored there.
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Google Ireland Limited, if you have consented to analytics cookies. We use Google Analytics to understand how our sites and course pages are used. See clause 13.
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Manychat, Inc., which runs our automated replies and our message inbox on Instagram and Facebook. It stores your username, your profile picture, our conversation with you, and any email address you give us in that conversation.
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CookieYes, which manages your cookie choices on the course platform and records what you consented to.
We also work with Meta in relation to the Meta Pixel, if you have consented to marketing cookies. That relationship is different from the ones above and is described in clause 13.
We may also share data with our accountants and professional advisers, or where we are required to by law.
5. Where your data goes
Some of our service providers are based in or transfer data to the United States. Where data leaves the European Economic Area, we rely on the following safeguards:
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Wix: your data is held by Wix.com Ltd., which is based in Israel. The European Commission has decided that Israel provides an adequate level of protection for personal data. Where Wix transfers data onward to a country without such a decision, it relies on the European Commission standard contractual clauses.
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Kajabi: the European Commission standard contractual clauses, in the 2021 form, as set out in Kajabi's data protection addendum.
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Stripe: standard contractual clauses, together with the EU-US Data Privacy Framework where applicable.
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Google, for our business email: certification under the EU-US Data Privacy Framework.
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Google Analytics: your data is collected by Google Ireland Limited, which is established in the EU, and may be transferred to Google in the United States under the European Commission standard contractual clauses, together with Google's certification under the EU-US Data Privacy Framework.
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Meta: your data is collected by Meta Platforms Ireland Limited, which is established in the EU. Where data is transferred to Meta Platforms, Inc. in the United States, that transfer is carried out on the basis of the European Commission standard contractual clauses.
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Manychat: certification under the EU-US Data Privacy Framework, together with the European Commission standard contractual clauses, in the 2021 form, where the Framework does not apply.
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You can ask us for a copy of the safeguards that apply by emailing support@coachingbyeicca.com.
6. How long we keep it
We keep your account and course access data for as long as you have access to the course, and for 12 months after your access ends, so that we can deal with reinstatement requests and any dispute.
We keep accounting vouchers for six years from the end of the calendar year in which the financial period ended, and financial statements, accounting books, the chart of accounts and the list of accounting records for ten years from the end of the financial period, as required by the Finnish Accounting Act.
We keep marketing contact details until you unsubscribe or ask us to delete them.
We keep support correspondence, enquiries sent through our contact form, and conversations on Instagram and Facebook, for as long as we are still dealing with you, and for 24 months after our last contact with you.
Google Analytics keeps the data it collects about your visit for 14 months, after which it is deleted automatically.
7. Your rights
Under the GDPR you have the right to ask us for a copy of the data we hold about you, to have inaccurate data corrected, to have your data deleted, to restrict or object to how we use it, and to receive your data in a portable format.
Where we rely on your consent, you can withdraw it at any time. This does not affect anything we did before you withdrew it.
To exercise any of these rights, email us at support@coachingbyeicca.com. We will respond within one month. If your request is complex, or you make a number of requests, we may extend that by up to two further months and will tell you if we do.
Please note that if you ask us to delete your data while you still have course access, we will usually have to close your account, and that we may need to keep certain records to meet our legal obligations.
8. Your right to object to marketing
You have the right to object at any time to our use of your personal data for direct marketing, including any profiling related to that marketing. If you object, we will stop. You can do this by using the unsubscribe link in any marketing email, or by emailing support@coachingbyeicca.com.
9. If you are unhappy
Please contact us first at support@coachingbyeicca.com and we will try to put it right.
You also have the right to complain to a data protection authority. In Finland this is the Office of the Data Protection Ombudsman (tietosuoja.fi). If you live elsewhere in the EU, you can complain to the authority in your own country.
10. Automated decisions and profiling
We do not make decisions about you by automated means that produce legal effects concerning you or similarly significantly affect you.
We may use your course progress and how you engage with our emails to decide which emails to send you. You can object to this at any time, as described in clause 8.
11. Security
We take reasonable technical and organisational measures to protect your data, and we choose service providers who do the same. No online service can be completely secure, and we cannot guarantee absolute security.
12. Children
The course is sold to adults. We do not knowingly collect data from anyone under 18.
If you are buying the course for someone under 18, you are the contracting party, the account is in your name, and you are responsible for it.
13. Cookies and tracking
A cookie is a small file placed on your device when you visit a website. We use them for the following purposes.
Strictly necessary cookies. These make the sites work. They keep you logged in, remember what is in your cart, and keep the platform secure. The sites cannot function without them, so they are set without asking you.
Functional cookies. These remember choices you have made, such as your language or your cookie preferences, so you do not have to set them again.
Analytics cookies. These tell us how our sites are used, which pages are visited and where people run into difficulty, so that we can improve them. We use Google Analytics 4, provided by Google Ireland Limited. If you consent, it sets cookies beginning _ga and collects your device and browser type, an approximate location derived from your IP address, the pages you view and the actions you take on them. It does not tell us who you are by name. The legal basis is your consent, and you can withdraw it at any time.
Marketing cookies. These allow us and our advertising partners to measure the effect of our advertising and to show you our adverts on other websites. In particular we use the Meta Pixel, provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
If you consent, the Meta Pixel collects information about your visit, including the pages you view, the actions you take and events such as form submissions or purchases, together with technical information such as your browser, device and IP address. This is transmitted to Meta. We use it to measure how our advertising on Facebook and Instagram performs, to show adverts to people who have visited our sites, and to build audiences of people with similar characteristics.
For the collection and transmission of this data, we and Meta act as joint controllers. Meta then processes the data for its own purposes as an independent controller, in accordance with Meta's own privacy policy at https://www.facebook.com/privacy/policy.
The legal basis for the Meta Pixel is your consent. If you do not consent, it is not loaded and no data is collected or sent to Meta. You can also manage the adverts you see in your Facebook and Instagram account settings.
Giving and withdrawing consent. We set analytics and marketing cookies only if you agree to them, and refusing is as easy as accepting. Non-essential cookies, including the Meta Pixel and Google Analytics, are blocked until you accept them.
Our two sites use different cookie banners. On our main site at coachingbyeicca.com the banner is provided by Wix, and you can change your choice at any time using the cookie settings control that appears at the bottom of every page. On the course platform at courses.coachingbyeicca.com the banner is provided by CookieYes, and you can change your choice using its cookie settings control. Because they are separate, a choice you make on one site does not carry across to the other.
You can also block or delete cookies through your browser settings, though the sites may not work properly if you block the strictly necessary ones.
14. Changes to this policy
We may update this policy. Any updated version will be published on this page with a revised version number and date. If we make a significant change to how we use your data, we will tell you by email.
15. Contact
Eicca Production Oy
Business ID 1630761-3
Opastinsilta 3 lt. 2, 00520 Helsinki, Finland