Privacy Policy (No-BS PM Course)

Last updated: April 2025

Introduction

Welcome to the Privacy Policy for no-bs-pm.com, an online product management course operated by Michael Chernyakov. We value your privacy and are committed to protecting your personal data. This policy explains what information we collect, how we use it, and your rights. We adhere to the EU General Data Protection Regulation (GDPR) and applicable German data protection laws in handling your data. This Privacy Policy is written in English for an international audience and aims to be clear and user-friendly.

Data Controller and Contact Information

The “Data Controller” (the person responsible for your data) is Michael Chernyakov, operating as an independent freelancer in Germany. For privacy inquiries or requests, you can reach Michael at no.bs.pm@gmail.com. Michael’s business address is in Berlin, Germany (full address available upon request). If you have any questions or wish to exercise any of your rights regarding your personal data, please contact us at the email above.

Personal Data We Collect

We only collect personal information that is necessary to provide our course services and fulfil our obligations. This includes:

Information You Provide: When you enrol in the course (or contact us), we ask for your first name, last name, and email address. This is so we can register you, communicate about course sessions, and (if applicable) issue any necessary billing documents. You may also provide payment details when purchasing the course, but payment information (like credit card numbers) is handled securely by our payment processor (Wix Payments) – we do not receive or store your full payment card details on our own systems. We only receive necessary billing information such as your name, the amount paid, and payment status to confirm your enrolment. We do not create any user accounts or profiles on the website; each enrollment is handled individually. We also do not send any promotional emails or newsletters – you will only hear from us regarding your course or transactions you’ve initiated.

Information from Website Use: We do not use any additional third-party analytics or tracking tools. However, when you visit our website, certain data may be collected automatically by our website platform (Wix) for technical and security purposes. This can include technical information such as your IP address, browser type, device information, and cookies. Wix uses cookies and similar technologies primarily for essential functionalities – for example, to enable site features, maintain security (e.g. prevent fraud), and monitor the performance of the platform. These are standard, essential cookies (e.g. to keep you logged in during a session or to protect the site) and not used for advertising or profiling. We (Michael Chernyakov) do not have access to or utilize this technical data for any marketing or analytics purposes – it’s only processed in the background to ensure the website works properly and remains secure.

Cookies: As noted, our site itself does not employ any marketing or analytics cookies. The only cookies in use are those set by Wix’s platform which are generally essential for site operation (such as security tokens, session IDs, and load-balancing cookies). These cookies are used “to monitor and analyze the performance, operation and effectiveness of Wix’s platform” and to keep it secure. Because we do not use any non-essential cookies beyond Wix’s built-in functionality, we generally do not present a cookie consent banner for advertising cookies. You can control or delete cookies through your browser settings at any time, but please note that disabling essential cookies might affect the site’s functionality. If you have any questions about cookies on our site, feel free to contact us.

How We Use Your Personal Data (Purposes and Legal Bases)

We only use your personal data for specific purposes and in accordance with the lawful bases permitted under GDPR. Below are the purposes for which we process your data, along with the legal justification for each:

To Provide the Course and Services: We use your name and email to enrol you in the product management course, coordinate sessions, and communicate with you about course details (e.g. schedule, access links, assignments). This is necessary for us to perform our contract with you – when you sign up, a contract is formed for us to deliver the course. Legal Basis: GDPR Article 6(1)(b) – “performance of a contract”. Without this data, we wouldn’t be able to provide the course to you.

Payment Processing and Billing: When you purchase the course, your payment is processed by Wix Payments on our behalf. We use the billing information provided (such as your name and payment confirmation) to process your order, confirm payment, and maintain proper transaction records. We do not see your full credit card or banking details; those are handled by the secure payment processor. We retain basic transaction data (e.g. payment amount, date, status) for accounting and tax purposes. Legal Basis: GDPR Article 6(1)(b) – contract performance (processing your payment is part of providing the service you requested), and GDPR Article 6(1)(c) – compliance with a legal obligation. We have a legal obligation under German law to maintain proper books and records of payments (for example, German fiscal regulations require retaining invoice and payment data for 10 years).

Communicating with You: We may use your email to send you important communications related to the course, such as enrolment confirmations, receipts, course materials, reminders for sessions, or responses if you contact us. These communications are not marketing – they are directly related to the service you signed up for. Legal Basis: GDPR Article 6(1)(b) – contract, since these communications are necessary to deliver the service and ensure you get the full benefit of the course. If you email us with questions (outside of an enrollment), responding to you is based on our legitimate interest in providing good customer service or, if you haven’t enrolled yet, as a pre-contractual step at your request.

Site Operation and Security: As mentioned, Wix (our website host) may process some technical data (like IP address or device info) via cookies or logs to ensure the site runs smoothly and securely. For example, this helps prevent unauthorized access and keeps the platform stable. We rely on legitimate interest (GDPR Article 6(1)(f)) to collect and use this minimal data, as it is necessary to protect our website and provide you with a safe, functional user experience. This data is not used for any profiling or marketing – purely for network security, fraud prevention, and performance monitoring on the platform.

Compliance with Laws: We may process and retain your data as needed to fulfill legal obligations – for instance, keeping transaction records for tax and accounting compliance, or disclosing information if required by law (such as a court order or an audit by tax authorities). Legal Basis: GDPR Article 6(1)(c) – legal obligation. For example, under German tax law we must retain invoice data for up to ten years. Any such processing is strictly limited to compliance requirements.

We do NOT use your personal data for any marketing or advertising purposes. You will not receive newsletters, promos, or unrelated emails from us unless you have explicitly requested them (and currently, we do not even offer a newsletter). We do not engage in “selling” personal data or sharing it for others’ marketing. Each piece of data is used only to serve you in the context of the course or meet our legal duties.

Third-Party Service Providers (Wix Platform and Payments)

In order to run our website and deliver the course to you, we rely on a couple of trusted third-party service providers. We ensure any partners we use are GDPR-compliant and that your data is protected. Here are the third parties involved in data processing for our site:

Wix (Website Hosting Platform): Our website no-bs-pm.com is built and hosted on Wix.com, which means when you enter information on our site, it is transmitted to and stored on Wix’s servers. Wix acts as a data processor on our behalf: it provides the infrastructure that allows us to collect your enrollment information and run the site. Wix.com Ltd. is a company based in Israel, and it has a strong commitment to data protection. In fact, Israel is recognized by the European Commission as a country providing an adequate level of data protection. Wix may store personal information in data centers located in various countries (Wix’s servers are located in Israel, the United States, Europe (e.g. Ireland), and other locations). Regardless of where data is stored, Wix is contractually bound to handle your data in compliance with GDPR standards. We have a Data Processing Agreement in place with Wix, which means they only process your personal data under our instructions and for our specified purposes (like hosting the site, enabling sign-up forms, and processing payments). Wix also implements robust security measures: for example, personal data on Wix’s platform is transmitted securely (Wix ensures HTTPS encryption for data in transit) and stored with encryption and other safeguards to protect it from unauthorized access. By using our website and providing your information, you acknowledge that your data will be processed by Wix on our behalf. (If you wish, you can also review Wix’s own Privacy Policy for more details on their data practices.)

Wix Payments (Payment Processor): We use Wix Payments to handle credit card and other payments on the site. Wix Payments is a payment processing service integrated with our Wix website. When you pay for the course, the payment form is actually provided by Wix Payments (and their banking/payment partners), which means your payment details (like credit card number, expiry, CVC, or bank info) are sent directly to Wix Payments’ secure payment system. We do not manually collect or store your sensitive payment information on our servers. Wix Payments will process the transaction, and we (as the merchant) receive a notification of your payment. This notification includes information such as your name, email, the amount paid, payment method (e.g. last four digits of card or payment type), and payment status (e.g. succeeded or failed). We use this information to confirm your enrollment and for our records. Wix Payments is designed to be PCI-DSS compliant and uses encryption to protect your data during the transaction. Essentially, Wix Payments acts as a data processor and payment intermediary: it processes payments on our behalf and forwards us only the necessary billing data. Any personal data processed via Wix Payments is subject to the same protections described above for Wix. Wix Payments may also be required to retain transaction information to comply with financial regulations (for example, anti-fraud and banking laws), but this is handled by Wix’s systems.

Other than Wix and its payment processing service, we do not share your personal data with any other subcontractors or third parties. We do not transfer your data to any external marketing firms or unrelated service providers. The use of Wix is solely to enable our website’s functionality, and Wix will not use your data for its own purposes beyond providing services to us. Similarly, payment details are only used to process the transaction through banking networks.

Data Sharing and Disclosure

As a rule, we do not sell, rent, or trade your personal information to anyone. Your data is kept confidential. We only share your data in a few select circumstances, all of which are aligned with the purposes stated above:

With Our Service Providers: As detailed, your data is shared with Wix.com (which hosts the site and processes data for us) and Wix Payments (to process payments). These parties are bound by privacy agreements and only use the data to fulfill their services to us – they are not allowed to use your data for anything else. Both Wix and its payments service operate under strict data protection standards as explained (including GDPR compliance).

Legal Requirements: We may disclose personal information if we are legally compelled to do so. For instance, if a government authority or court requires us to provide data (such as for a tax audit, investigation, or legal dispute), we will have to comply. Similarly, we might share information with our tax consultant or accountant for legitimate accounting purposes, or with authorities to fulfill tax obligations (e.g. providing proof of income). In any case, we will only share what is necessary and required by law.

Business Transfers: If in the future the business or website ownership changes (for example, if the course offerings are transferred to another operator), personal data might be part of that transfer. If that happens, we will ensure the new owner has the same commitment to privacy, and we will inform users of any changes. Currently, there are no plans for any such transfer.

Other than the above, no other parties receive your personal data. In particular, we do not share your information with any other instructors, partners, or advertisers. Your data stays within our small operation and the core services we use to run it.

International Data Transfers

Because we use Wix as our platform, it is possible that your personal data will be stored or processed on servers outside of the country where you live. In particular, as noted, data might be stored in Israel (where Wix is headquartered) or in the United States or other countries if needed for technical infrastructure. We want to reassure you that any international transfer of your data is done in compliance with GDPR Chapter V (which governs data transfers outside the EU):

Adequacy Decision (Israel): The European Union has determined that Israel offers an “adequate” level of data protection (this means that under EU law, data can flow to Israel just as it would within the EU). Since Wix is an Israeli company, data stored in Israel is protected under Israel’s privacy laws, which the EU recognizes as strong.