Privacy Policy

Last updated: October 1st, 2026

Nea International bv, trading under the Push® brand (“we”, “us” or “our”), respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store and protect personal data when you use the Push Academy (“Platform”).

This Privacy Policy applies to all users of the Platform, including learners, trainers, administrators and other authorised users.

1. Who is responsible for your personal data?

The Platform is operated by:

Nea International bv
 Europalaan 31
 6199 AB Maastricht-Airport
 The Netherlands
Email: [email protected]

Depending on how access to the Platform is provided, Nea International bv may act as a data controller or as a data processor on behalf of an organisation that has provided you with access to the Platform.

Where your employer, educational institution, customer, distributor or another organisation has provided you with access to the Platform, that organisation may be the data controller for certain personal data processed through the Platform. In such cases, you should also consult that organisation’s privacy policy.

2. What personal data do we collect?

Depending on how you use the Platform, we may process the following categories of personal data:

• Account information, such as your name, email address, username, organisation, country and user role.
• Training information, such as courses assigned to you, courses started or completed, training progress, test or quiz results, certificates and completion dates.
• Technical information, such as IP address, browser type, device information, operating system, login information and technical logs.
• Usage information, such as how and when you use the Platform, pages or training modules accessed and interactions with Platform functionality.
• Communication information, such as questions, support requests, feedback or other communications you send to us.
• Other information that you voluntarily provide through the Platform.

We aim to collect only the personal data that is necessary for the relevant purpose.

3. How do we collect your personal data?

We may collect personal data:

• directly from you when you create or use an account;
• from the organisation that provides you with access to the Platform, including an authorised Push® distributor that registers you for a training;
• automatically when you use the Platform;
• when you contact us for support or information; and
• through cookies or similar technologies, where applicable.
• If an authorised Push® distributor registers you for a training, we may receive your name, email address and other relevant registration information from that distributor in order to invite you to the Push Academy and provide access to the relevant training.

4. Why do we process your personal data?

We may process your personal data for the following purposes:

• to create and manage your user account;
• to provide access to online training courses and learning materials;
• to register and monitor training progress;
• to record course completion and assessment results;
• to issue certificates or other evidence of training completion;
• to provide technical support;
• to communicate with you about your account, courses or the Platform;
• to maintain the security and proper functioning of the Platform;
• to improve the Platform and our training services;
• to comply with applicable legal and regulatory obligations; and
• where applicable, to provide aggregated or individual training information to the organisation that has provided you with access to the Platform.

We will not use your personal data for purposes that are incompatible with the purposes for which it was collected unless permitted or required by law.

5. Legal basis for processing

Where the General Data Protection Regulation (“GDPR”) or similar legislation applies, we process personal data only where we have an appropriate legal basis.

Depending on the circumstances, this may include:

• performance of a contract, where processing is necessary to provide the Platform or training services;
• legitimate interests, for example to operate, secure and improve the Platform;
• compliance with a legal obligation;
• consent, where we specifically ask for your permission; or
• processing on behalf of another organisation acting as the data controller.

Where we rely on legitimate interests, we consider the impact of the processing on your privacy and data protection rights.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

6. Training progress and reporting

If you use the Platform through an organisation, including an authorised Push® distributor, certain information about your training activities may be made available to authorised administrators of that organisation.

This may include, for example:

• courses assigned to you;
• training progress;
• completion status;
• completion dates;
• test or assessment results; and
• certificates obtained.

If you were registered for a training by an authorised Push® distributor, we may inform that distributor when you have successfully completed the training and obtained your certificate. This may include your name, email address, completion status and completion date.
 
 The organisation receiving this information is responsible for determining how it may use this information in accordance with applicable privacy and employment laws.

7. Sharing personal data

We do not sell your personal data.

We may share personal data with third parties where this is necessary to provide and operate the Platform. These parties may include:

• hosting and cloud service providers;
• Thinkific Labs Inc., which provides the learning management system used for the Push Academy;
• IT and technical support providers;
• email and communication service providers;
• analytics and security providers;
• organisations that have provided users with access to the Platform; and
• competent authorities where disclosure is required by law.

Where third-party service providers process personal data on our behalf, we require them to process the data only in accordance with our instructions and to implement appropriate data protection and security measures.

8. International data transfers

Where possible, personal data is processed within the European Economic Area (“EEA”).

If personal data is transferred to a country outside the EEA that has not been recognised as providing an adequate level of data protection, we will use appropriate safeguards as required by applicable data protection legislation. These may include the European Commission’s Standard Contractual Clauses or another legally recognised transfer mechanism.

9. How long do we keep personal data?

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required by law or necessary for legitimate business purposes.

Retention periods may differ depending on the type of data and the purpose for which it is processed.

When personal data is no longer required, it will be deleted, anonymised or otherwise securely disposed of in accordance with our retention procedures.

Where an organisation provides you with access to the Platform, retention periods may also be determined by that organisation.

10. Security

We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures may include access controls, authentication, encryption, secure hosting, backups, monitoring and procedures for managing security incidents.

However, no online system can guarantee absolute security.

11. Cookies and similar technologies

The Platform may use cookies and similar technologies to ensure that it functions correctly, maintain user sessions, remember preferences, improve performance and, where applicable, analyse Platform usage.

Cookies that are strictly necessary for the operation of the Platform may be used without consent where permitted by law.

Where consent is legally required for other cookies or similar technologies, these will only be used after you have provided the required consent.

Further information can be provided in a separate Cookie Policy or cookie settings interface.

12. Your privacy rights

Depending on the applicable legislation and the circumstances, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to certain processing;
• receive certain personal data in a portable format;
• withdraw consent where processing is based on consent; and
• lodge a complaint with the competent data protection authority.

These rights are not absolute and may be subject to legal conditions or exceptions.

If your account is provided by an organisation that acts as the data controller, we may need to refer your request to that organisation.

To exercise your rights, please contact us at [email protected].

13. Automated decision-making

Unless specifically stated otherwise, we do not use personal data collected through the Platform to make decisions based solely on automated processing that produce legal effects or similarly significantly affect users.

Automated functionality may be used to support the learning process, for example to calculate training progress, determine whether a course has been completed or generate a certificate based on predefined criteria.

14. Children

The Platform is not intended for children unless explicitly stated otherwise.

If the Platform is made available to minors, we will process their personal data in accordance with applicable data protection requirements and, where required, obtain appropriate consent or authorisation.

15. Third-party links and content

The Platform may contain links to external websites, videos, documents or other third-party content. We are not responsible for the privacy practices of third parties. We recommend reviewing the applicable privacy policies before providing personal data to third-party services.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example when the Platform, our processing activities or applicable legal requirements change.

The most recent version will be made available through the Platform. The “Last updated” date at the top of this Privacy Policy indicates when it was last revised.

Where required, we will inform users of material changes.

17. Contact

If you have questions about this Privacy Policy or about how your personal data is processed, please contact:

Nea International bv
 Europalaan 31
 6199 AB Maastricht-Airport
 The Netherlands
Email: [email protected]

You also have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority).