Privacy Policy

Townshub Limited — Nicosia, Cyprus
Last updated: 10 September 2026

Summary: We collect your name, email, and payment data to run the platform. We do not sell your data. We store it on Supabase (EU-region) and Stripe. You can ask us to delete your data at any time.

1. Who We Are (Data Controller)

The data controller for this platform is:

We process personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Cyprus Data Protection Law (Law 125(I)/2018), administered by the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus.

2. Data We Collect

DataWhen CollectedPurpose
Full name, email addressAccount registrationAccount management, communications
Password (hashed — never stored in plain text)Account registrationAuthentication
Role selection (student / instructor / graduate)Account registrationContent access control
Payment details (card info)Checkout — processed by Stripe onlyBilling — we never see or store card numbers
Stripe customer IDFirst purchaseSubscription management
Course progress, sessions watchedWhile using the platformProgress tracking, cohort unlock logic
Community posts and repliesWhen you postCommunity feature
Points and leaderboard scorePlatform activityGamification
IP address, browser typeEach page request (server logs)Security, fraud prevention
Profile photo (if taken via the Android app's camera option)When you tap "Take Photo" on your profileDisplayed as your avatar — stored the same way as a browser-uploaded photo
Push notification tokenAndroid app, if you allow notificationsSending you course/community notifications

We do not collect sensitive personal data (e.g. racial or ethnic origin, health data, political opinions). We do not collect or store biometric data (fingerprint/face) — see Section 3 below.

3. Mobile App Permissions (Android)

The Townshub Academy Android app requests a few device permissions the website doesn't need:

PermissionWhat It's ForWhat We Receive
Camera / Photo LibraryOnly used if you tap "Take Photo" when setting your profile pictureThe photo you choose, uploaded to our Supabase Storage the same way a browser-uploaded photo is (see Section 6). We never access your camera or photo library at any other time, and no image is kept on your device by us.
Biometric (fingerprint / face unlock)An optional local screen lock for the app — if you're already signed in, it re-confirms it's you before showing your accountNothing. Your fingerprint or facial data is captured and verified entirely by your device's own operating system. It never leaves your device, is never seen by Townshub Limited, and is never transmitted to our servers — the app only receives a yes/no result from your device.
Push notificationsIf you allow it, your device registers with Google's Firebase Cloud Messaging so we can send you course or community notificationsA device token (not personal content), stored against your account. You can revoke this at any time in your device's notification settings.

4. Lawful Basis for Processing

Processing ActivityLegal Basis (GDPR Art. 6)
Managing your account and delivering the courseArt. 6(1)(b) — performance of a contract
Processing paymentsArt. 6(1)(b) — performance of a contract
Sending transactional emails (receipts, password reset)Art. 6(1)(b) — performance of a contract
Sending course update or promotional emailsArt. 6(1)(a) — consent (opt-in)
Server logs and security monitoringArt. 6(1)(f) — legitimate interests (security)
Legal compliance (VAT records, financial records)Art. 6(1)(c) — legal obligation

5. Cookies

We use the following cookies on this platform:

CookieTypePurposeDuration
PHP Session cookie (PHPSESSID)Strictly necessaryKeeps you logged in during your sessionSession (deleted when browser closes)
Google FontsFunctional (third-party)Loads the Inter typeface. Google may log the request with your IP.None (CDN request, no stored cookie)
StripeFunctional (third-party)Fraud prevention during checkoutAs per Stripe policy

We do not use advertising, analytics, or tracking cookies. If this changes we will update this policy and ask for your consent.

You can disable non-essential cookies in your browser settings. Disabling the session cookie will prevent you from logging in.

6. Who We Share Your Data With

We do not sell your personal data. We share data only with these processors:

ProcessorPurposeLocation
Supabase Inc.Database and authentication hostingEU (Ireland, eu-west-1) — within the EU/EEA
Stripe Inc.Payment processingUSA (Standard Contractual Clauses apply)
Anthropic, PBCAI-generated reply suggestions for direct messages and community posts. When you message the instructor or post in the community, your name and message content may be sent to Anthropic's Claude API to draft a reply.USA (Standard Contractual Clauses apply)
Google LLCFonts CDN (font loading only); Firebase Cloud Messaging (Android app push notification delivery, if enabled)USA (Standard Contractual Clauses apply)
Hostinger International LtdWeb hostingEU / Lithuania

Where data is transferred outside the EU/EEA, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission.

7. How Long We Keep Your Data

DataRetention Period
Account data (name, email, role, progress)Until you request deletion, or 3 years after your last login if account is inactive
Payment records (Stripe customer ID, transaction history)7 years (Cyprus tax/accounting law requirement)
Community posts and repliesUntil deleted by you or us, or until account deletion
Server logs90 days
Push notification device tokenUntil you disable notifications, uninstall the app, or request deletion

8. Your Rights Under GDPR

You have the following rights regarding your personal data. To exercise any of them, email nnamdi@townshub.com with subject line "GDPR Request".

We will respond to all requests within 30 days. We may ask you to verify your identity before acting on a request.

9. Security

No system is 100% secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and you within a reasonable timeframe, as required by GDPR Art. 33 & 34.

10. Children

This platform is intended for users aged 16 and over (the age set by Cyprus for digital consent under GDPR Article 8). If you are under 16, you must have verifiable parental or guardian consent. If we discover that we have collected data from a child under 16 without consent, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email to your registered address at least 14 days before taking effect. The “Last updated” date at the top of this page reflects the current version.

12. Contact

For privacy requests, questions, or complaints:
Townshub Limited
Nicosia, Cyprus
Email: nnamdi@townshub.com

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