Privacy Policy

Sophelle Academy ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data.

The platform is operated by Sophies Choice Shop d.o.o. Beograd-Savski venac, registered at Karađorđeva 69, 11000 Belgrade, Serbia (Tax ID 110906050, Registration number 21400319).

Full business and contact details are shown in the site footer and in your order confirmation.

By using our platform, you agree to the collection and use of information in accordance with this policy.

We collect the following types of data:

We use your data for the following purposes, each on an appropriate legal basis:

• Create and manage your account (performance of a contract)
• Process payments and provide access to purchased courses (performance of a contract)
• Send notices about your account and purchases (performance of a contract)
• Send promotional messages (based on your consent)
• Improve our platform and user experience (legitimate interest)
• Provide customer support (performance of a contract and legitimate interest)
• Prevent fraud and misuse (legitimate interest)
• Comply with legal obligations (legal obligation)

We do not sell your personal data to third parties. We share it only where necessary to provide the service: with service providers (hosting, database, payment processing, video delivery, email and AI support), with educators (basic information about students enrolled in their courses, for course-related communication), and with authorities when required by law or necessary to protect our rights.

Payment processing: card payments (with 3D Secure), and where available Apple Pay or Google Pay, are processed by Raiffeisen Bank (RaiAccept) as an independent processor of payment data; you enter your card details on the bank's secure page and we do not store them. When you pay via Apple Pay or Google Pay, that data is processed by Apple or Google respectively as independent controllers, under their own privacy policies.

International transfers: some of our processors are located outside the Republic of Serbia, primarily in the USA (e.g. Vercel — hosting, Neon — database, OpenAI — AI chat support) and in the EU. In such cases we transfer data with the safeguards required by the Personal Data Protection Act — standard contractual clauses prescribed by the Commissioner, an adequacy decision, or statutory exceptions. You can request a copy of the applied safeguards at office@sophelle.academy.

We use cookies and similar technologies. Necessary cookies are always on because they are essential for the site to work (e.g. sign-in, security, remembering basic settings). Optional analytics and marketing cookies are enabled only after you consent.

You give consent via the banner on your first visit, and you can change or withdraw it at any time by clicking “Cookie settings” in the site footer.

The cookie categories we use:

• Necessary — sign-in and session, security and core functions; cannot be disabled.
• Analytics — e.g. Google Analytics; measures visits and how the site is used (loaded only with your consent).
• Marketing — e.g. Meta (Facebook) Pixel; measures ad effectiveness and enables more relevant marketing (loaded only with your consent).

We apply technical and organizational measures to protect your data:

Despite our efforts, no system is 100% secure. We will notify you if a data security incident affects your information.

• SSL/TLS encryption for data in transit
• Password hashing in the database
• Regular security reviews and updates
• Restricted data access for authorized personnel only

We keep your data while your platform account remains active. If you request account deletion, your data is deleted within 30 days, except for records we must retain by law.

Specific periods: accounting documents and transaction data (invoices) are kept for the statutory period, as a rule up to 10 years (Accounting Act). Data entered into the “My Clients” module is kept until you delete it yourself or delete your account. Technical logs and analytics data are kept for up to 14 months.

In line with applicable data protection law, you have the right to:

To exercise these rights, contact us using the email below.

• Access the data we store about you
• Correct inaccurate data
• Delete your data ("right to be forgotten")
• Restrict the processing of your data
• Transfer your data to another controller
• Object to data processing
• Withdraw consent at any time

We do not make decisions producing legal effects concerning you based solely on automated processing.

AI chat support: we use an AI assistant (processor: OpenAI) to help users. The content of your chat messages is sent to that service to generate responses; we do not use it to make automated decisions about you. Please do not enter sensitive data into the chat.

Makeup artist directory: the ordering of public profiles depends in part on the “Certified” badge and other objective criteria — this is ranking of how profiles are displayed, not decision-making with legal effect.

“My Clients” module: to protect against double bookings, client phone numbers are automatically compared between accounts in a standardised form, solely to issue a warning, based on legitimate interest. You can object to this processing at office@sophelle.academy.

Our platform is not intended for children under 16. We do not knowingly collect data from children. If we learn that we have done so, we will delete that data promptly.

We may update this Privacy Policy from time to time. We will notify you of material changes by email or platform notice at least 30 days before they take effect.

For any privacy questions, to exercise your rights, or to reach the person responsible for data protection, write to us at office@sophelle.academy. We respond to requests without undue delay and within 30 days at the latest.

Public contact details are listed below, and full business details are shown in the site footer.

If you believe your rights were violated, you may lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection (Bulevar kralja Aleksandra 15, 11120 Belgrade; www.poverenik.rs).

• Email: office@sophelle.academy
• Phone: +381 63 539 357
• Contact form: www.sophelle.academy/contact
• Location: Belgrade, Serbia