Effective date: February 28, 2021

Surfer spółka z ograniczoną odpowiedzialnością with its seat in Wrocław, Poland (“The Surfer”, “us”, “we”, or “our”) is the owner of SEO Writing Masterclass Course, available at Teachable Platform (the “Course”).

This document informs you of our policies regarding the collection, use, and disclosure of personal data that are controlled and processed by us in connection with the Course.

By enrolling to the Course, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, available at


Cookies - Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller - Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers) - Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User) - Data Subject is any living individual who is using our Service and is the subject of Personal Data. In this case, You are the Data Subject.

Personal Data - Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Course - SEO Writing Masterclass Course owned by Surfer, available at Teachable Platform 

Teachable – Teachable, Inc. with its registered office in 470 Park Avenue South, 6th Floor, New York, New York 10016, who operates Teachable Platform.

Usage Data - Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


We collect several different types of information for various purposes to provide and improve our Course. All Your personal data is provided to us by Teachable, in connection with our Course.

Please also note, that Surfer and Teachable are separate data controllers, each in the scope of own purposes, for which Your Personal Data is used for.



When You enroll to our Course, we collect certain personally identifiable information that are used to properly provide You with our service, that is to make the Course available for You. Personally identifiable information may include, but is not limited to:

  • Account information, including your name and email address,
  • Purchase information, including amount paid, your address, and other billing information (but never your complete card number)
  • IP address
  • Information about your participation in the Course, including the Creator Content you enrolled in, lecture completion status, course progress, quiz results, and certificates
  • Any messages you exchange with Us,
  • Cookies and Usage Data

We may use your Personal Data solely for the purposes connected with providing the Course. 


We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.


We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide the Service or to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.


We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.


The Surfer uses the collected data for various purposes:

  • To provide and maintain our Course at Teachable Platform,
  • To answer Your queries sent to us,
  • To notify you about changes in our Course,
  • To issue and provide you with the certificate after completion of our Course,
  • To gather analysis or valuable information so that we can improve our Course,
  • To detect, prevent and address technical issues or infringement of our rights.


Legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

  • Your name and surname, Your email address, Information concerning Your progress (stage) of the Course, Information about Your payments for the Course, Cookies and Usage Data- the legal ground to use this data is our legitimate interest (performance of the service; providing support to You).
  • If we ask for your consent to gather and process Your personal data, the legal basis for such data will be your consent.


The Surfer will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Surfer will also retain your Personal data gather on the basis of Your consent, until the consent is revoked.


Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your Personal Data will be processed by Teachable, for the purpose of making our Course available for You.

The Surfer will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and may transfer your Personal Data to a country with adequate controls in place including the security of your data and other personal information.



Under certain circumstances, The Surfer may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).


The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


You have certain data protection rights. The Surfer aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. In the event that we ask for consent to the processing of personal data, you will also have the right to withdraw consent to their processing at any time without affecting the lawfulness of the processing that was made on the basis of consent given before its withdrawal. A statement of withdrawal of consent to the processing of personal data requires sending it to the email address [email protected].

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).



We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


Surfer stores, processes, and transfers information in and to servers and databases located in European Economic Area as well as in the United States. We may also store, process, and transfer information in and to servers in other countries depending on the location of its affiliates and service providers.

By enrolling to the Course or otherwise giving us information, you consent to the transfer of information to the United States and other countries outside your country of residence.

With respect to the processing of information by our service providers on our behalf, we take all necessary steps required under applicable law to ensure that their transfer of information across borders is compliant with applicable law. This may include the use of EU model clauses. We take many steps to protect your privacy, including entering into a Data Processing Agreement with Teachable and other service providers.


We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:

Google Ads

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page:

Google also recommends installing the Google Analytics Opt-out Browser Add-on –– for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:


Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


If you have any questions about this Privacy Policy, please contact us:

Surfer Sp. z o.o.

Plac Solny 14/3

50-062 Wrocław

VAT ID: PL8971860264

[email protected]