1. Who is responsible for your data
The data controller is Stroud Private Foundation, which operates the BTC Curaçao website (hereinafter, “BTC Curaçao,” “we,” “us,” or “our”), located at Eden Mall, Unit 15F, Caracasbaaiweg 280, Willemstad, Curaçao.
General contact: +5999 686 6970.
Privacy and data-rights contact: info@btccuracao.com.
2. Scope
This Policy explains how we collect, use, store, share, and protect the personal data of people who visit btccuracao.com, complete our forms or landing pages, request information, express interest in or register for in-person courses, participate in educational activities, or agree to receive marketing communications.
BTC Curaçao provides education about bitcoin, blockchain, cryptocurrencies, wallets, and the practical uses of these technologies, including at local businesses. We do not offer user accounts or host online courses. We also do not operate as an exchange, custodian, wallet provider, financial adviser, or platform for buying or selling digital assets.
3. Data we collect
3.1 Data you provide to us
Identification and contact data, such as your first and last name, email address, telephone number, and country or place of residence.
Your WhatsApp number and any communications you choose to have with us through that channel.
Information relating to in-person courses and events, such as the course you are interested in, preferred date or session, language, availability, number of attendees, and any comments you choose to provide.
Communication preferences and evidence of consent, such as acceptance of email marketing, date, time, form used, and the version of the notice accepted.
The content of messages, inquiries, and responses to surveys or forms.
Other custom fields included in the relevant form. In each form, we will seek to explain the purpose of those fields and distinguish required fields from optional ones.
Business or partner information when an organization asks to be listed in the directory or participate in adoption initiatives, such as business name, contact person, address, telephone number, category, website, or social media accounts.
We do not request private keys, seed phrases, wallet passwords, exchange credentials, or sensitive financial information. You should never send us this type of information through forms or messages.
3.2 Data collected automatically
When you visit the website, we may receive technical and usage data such as your IP address, approximate location derived from your IP address, device and browser type, operating system, pages visited, date and time, referring website, search terms, originating advertisements or campaigns, interactions with the website and forms, conversion events, and cookie or similar-technology identifiers. The exact scope depends on the tools enabled and your cookie preferences.
We may currently use Google Analytics, Google Search Console, Google Tag Manager, Google Ads, Meta Pixel, and Meta’s Conversions API. Google Tag Manager manages tags, but technologies loaded through it may collect data for their respective purposes. Search Console primarily provides aggregated search-performance information, although Google may process technical data under its own terms.
4. Why we use data and our legal basis
To manage requests for information, waiting lists, availability, and registrations for in-person courses; confirm dates, locations, changes, or cancellations; and provide support before and after a course. Processing is necessary to respond to your request and, where applicable, manage a pre-contractual or contractual relationship.
To send newsletters, updates, invitations, promotions, and email marketing campaigns when you have given consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To respond to inquiries and maintain operational communications based on your request and our legitimate interest in managing our relationship with the community.
To administer educational activities, measure attendance, and improve content, forms, campaigns, and the website experience based on our legitimate interests, provided that your rights do not override those interests.
To maintain website security, prevent fraud, abuse, or unauthorized access, retain technical records, and establish, exercise, or defend legal claims based on our legitimate interests and legal obligations.
To comply with legal, tax, and accounting obligations or valid requests from authorities.
To publish business information in the directory where we have authorization or another lawful basis. A contact person’s details will not be published as personal data without authorization.
If we need to use your data for a new and incompatible purpose, we will inform you and, where required, request new consent.
5. Email marketing and advertising
We will send promotional communications by email or equivalent channels only when we have a valid legal basis, normally your consent through a separate, unchecked box. Registering for or requesting information about a course does not, by itself, constitute consent to general marketing.
We manage our lists, campaigns, and email automations through MailerLite. Every promotional email will include an unsubscribe mechanism. You may also withdraw consent by writing to info@btccuracao.com. Withdrawal does not prevent us from sending communications strictly necessary for a course in which you are registered.
We may measure opens, clicks, and conversions through MailerLite, Google, or Meta when permitted by law and your preferences. We may create advertising audiences or measure conversions through Google Ads, Meta Pixel, and Meta’s Conversions API. These tools will be described in the banner and Cookie Policy and will be activated only in accordance with the applicable legal basis and consent requirements.
6. Cookies and similar technologies
We use Complianz – GDPR/CCPA Cookie Consent to manage the cookie banner, preferences, and cookie documentation. The configuration follows the GDPR model by requesting prior consent before activating non-essential categories. Complianz is a management tool; using it does not replace our other legal obligations or, by itself, guarantee compliance.
We use strictly necessary cookies for website operation and security. Analytics or advertising cookies and technologies associated with Google Analytics, Google Ads, Meta Pixel, and services loaded through Google Tag Manager will be activated only after obtaining any required consent. Visitors may accept, reject, or configure non-essential categories and later withdraw consent through the “Manage Consent” link or button available on the website.
The current list of cookies, providers, purposes, and durations is maintained in the Cookie Policy generated or managed through Complianz. Rejecting non-essential cookies should not prevent access to basic educational content.
7. Who we share data with
We may disclose data only to the extent necessary to:
Website hosting, maintenance, security, form, CRM, automation, and email marketing providers.
Analytics and advertising providers, only in accordance with the applicable configuration and your cookie preferences.
Instructors, coordinators, venues, and logistics providers when necessary to organize an in-person course or event.
Professional advisers, auditors, insurers, or authorities when required by law, a valid request, or the need to establish, exercise, or defend legal rights.
A successor entity in the event of a reorganization, merger, or transfer of activities, subject to appropriate safeguards.
These recipients may process data only for authorized purposes and must apply appropriate confidentiality and security measures. We do not sell personal data or share lead lists so that third parties can conduct their own marketing without a valid legal basis and the required disclosures.
Our providers include SiteGround for hosting and related services; MailerLite for forms, lists, and email marketing; Google for Analytics, Search Console, Tag Manager, and Ads; Meta for Pixel, the Conversions API, and Meta Ads; and Complianz for consent management and cookie documentation. Depending on the service and its terms, each provider may act as a processor, service provider, or independent controller.
8. International transfers
SiteGround, MailerLite, Google, and Meta may store or allow access to data from countries outside Curaçao, including the United States, the European Economic Area, or other countries where they or their subprocessors operate. We will assess the applicable level of protection and adopt appropriate contractual, technical, and organizational safeguards, such as data processing agreements and valid transfer mechanisms where required. Where consent or another authorization is required for a transfer, we will obtain it before making the transfer.
9. Application of the GDPR and CCPA/CPRA
The primary legislation governing our operations in Curaçao is the National Ordinance on the Protection of Personal Data (Landsverordening bescherming persoonsgegevens). We will also apply the GDPR where processing falls within its territorial scope, for example, where we offer services to individuals located in the European Union or monitor their behavior there within the meaning of that regulation.
Where the GDPR applies, we will recognize, as appropriate, the rights of access, rectification, erasure, restriction, portability, objection, and withdrawal of consent, as well as the right to lodge a complaint with a competent supervisory authority.
The CCPA/CPRA does not automatically apply to every website accessible from California. If BTC Curaçao becomes subject to that legislation, it will recognize the applicable rights of California consumers, including the rights to know, access, correct, and delete information; limit certain uses of sensitive information; receive no discriminatory treatment; and opt out of the sale or sharing of personal information for cross-context behavioral advertising.
BTC Curaçao does not sell lists or personal data in exchange for money. However, the use of certain Google or Meta technologies may be considered “sharing” for behavioral advertising under the CCPA/CPRA where that law applies. In that case, we will provide a “Do Not Sell or Share My Personal Information” mechanism, or its equivalent, through Complianz and will respond to requests sent to info@btccuracao.com.
10. Retention
We retain data only for as long as necessary for the purposes described and to comply with legal obligations or defend claims. Our operational retention periods are:
Leads who do not register and marketing contacts: up to 24 months after the last interaction, unless they withdraw consent earlier or another valid legal basis applies.
Course operations and attendance data: up to 5 years after the course, or for any longer period required by accounting, tax, or legal obligations.
General inquiries: up to 12 months after they are closed.
Evidence of consent, withdrawal, or objection: while communications are being sent and for up to 5 years afterward to demonstrate compliance.
Technical and security logs: normally up to 12 months, unless an incident or justified need requires longer retention.
When the applicable period expires, we will securely delete or anonymize the data.
11. Security
We apply reasonable technical and organizational measures appropriate to the risk to protect data against loss, unauthorized access, alteration, disclosure, or destruction. These measures may include access controls, strong passwords and enhanced authentication, encryption where appropriate, backups, system updates, permission limits, and confidentiality agreements.
No system is completely secure. If we identify a security incident, we will assess its scope and take the containment, documentation, and notification measures required by applicable law.
12. Your rights
Under applicable law in Curaçao, you may request information about the processing of your data and, where appropriate:
Access your personal data and receive a copy of the available information.
Correct or update inaccurate or incomplete data.
Request deletion, blocking, or cessation of processing where applicable.
Object to processing, particularly direct marketing.
Withdraw consent at any time.
To exercise a right, write to info@btccuracao.com and provide your name, contact details, the right you wish to exercise, and the information necessary to locate your data. We may request reasonable information to verify your identity without requesting excessive data. We will respond within the period required by applicable law.
You may also submit an inquiry or complaint to the Curaçao Personal Data Protection Board (College bescherming persoonsgegevens) or another competent authority.
13. Children
The website and campaigns are not intentionally directed to children without the involvement of a parent or legal guardian. If a course admits minors, the relevant form must state the minimum age and obtain verifiable authorization from a guardian where required. If we discover that we collected a child’s data without valid authorization, we will delete it or take the appropriate corrective measures.
14. Links, Telegram, and third-party websites
The website may link to businesses, social networks, Telegram, wallets, exchanges, or other external resources. Those third parties operate under their own policies, and BTC Curaçao does not control their data processing. We recommend reviewing their privacy notices before providing information or installing applications.
15. Educational information; no financial advice
BTC Curaçao’s information and courses are for educational purposes. They do not constitute financial, investment, legal, or tax advice or a recommendation to buy, sell, or hold bitcoin or other assets. BTC Curaçao does not need and will not request access to your funds, private keys, or seed phrase to manage a registration or marketing campaign.
16. Changes to this Policy
We may update this Policy to reflect changes in our activities, providers, or legal requirements. We will publish the current version on the website and state its effective date. If a change materially affects processing based on consent, we will request new authorization where required.
17. Contact
For questions about this Policy or our use of your data:
Controller: Stroud Private Foundation / BTC Curaçao
Address: Eden Mall, Unit 15F, Caracasbaaiweg 280, Willemstad, Curaçao.
Telephone: +5999 686 6970.
Privacy email: info@btccuracao.com.