PRIVACY POLICY

Last updated: September 1, 2026

1. ABOUT THIS PRIVACY POLICY

This Privacy Policy explains how personal information is handled when you use TRKA.

TRKA is an independent digital startup and creative project based in Spain.

TRKA provides short online courses, digital comics, downloadable content, and access or links to a free online community.

Website:

https://www.trkauniverse.com

Privacy contact:

trkamail10@gmail.com

2. WHO IS RESPONSIBLE FOR YOUR DATA

For the purposes of applicable data protection law, including the General Data Protection Regulation (GDPR), the person responsible for deciding why personal information is processed in connection with TRKA is:

Eric Botifoll

Operating under the TRKA brand

Spain

Privacy contact:

trkamail10@gmail.com

TRKA uses third-party platforms such as Podia and Stripe to provide technical, course, account, and payment services.

Those providers may process personal information as service providers and, in some circumstances, may also process information for their own legal or operational purposes.

3. WHAT INFORMATION MAY BE PROCESSED

The information processed depends on how you use TRKA.

A. ACCOUNT AND COURSE INFORMATION

If you create an account or use a course through Podia, information may include:

• Name

• Email address

• Account information

• Products or courses associated with your account

• Course progress

• Lesson completion

• Quiz responses or results where applicable

B. PURCHASE INFORMATION

If you purchase a course, comic, or other digital product, information may include:

• Name

• Email address

• Product purchased

• Purchase date

• Amount paid

• Currency

• Payment status

• Transaction or order identifiers

• Relevant billing information

• Refund information where applicable

Payments are processed through Stripe using Podia's payment infrastructure.

TRKA does not directly store your complete payment-card number, security code, or full card credentials.

C. INFORMATION YOU SEND TO US

If you contact TRKA, we may process:

• Your name

• Your email address

• The contents of your message

• Questions or support requests

• Refund requests

• Feedback

• Other information you choose to provide

D. WEBSITE AND TECHNICAL INFORMATION

When you visit the website, our platform and service providers may process technical information such as:

• IP address

• Browser type

• Device type

• Operating system

• Referring page or website

• Pages visited

• Date and time of access

• Website interactions

• Session information

• Approximate location derived from technical information

TRKA does not intentionally collect precise GPS location through the website.

E. COOKIES

TRKA and its service providers may use cookies and similar technologies.

Some cookies are necessary for the website to function, including functions such as:

• Login

• Security

• Session management

• Account functionality

• Remembering necessary preferences

Other cookies may be used for analytics or advertising where enabled and where legally permitted.

More information is available in our Cookie Policy.

4. WHY WE USE PERSONAL INFORMATION

Personal information may be used for the following purposes:

A. PROVIDING TRKA PRODUCTS AND SERVICES

We may process information to:

• Create and manage accounts

• Give customers access to courses

• Deliver purchased digital products

• Record course progress

• Operate quizzes

• Process purchases

• Process refunds

• Provide customer support

The legal basis for this processing is generally the performance of a contract or taking steps requested before entering into a contract.

B. COMMUNICATIONS

We may use information to:

• Respond to questions

• Provide customer support

• Handle complaints

• Respond to refund requests

• Send important account or purchase information

This processing may be necessary to provide a service or based on our legitimate interest in communicating with users.

C. SECURITY AND FRAUD PREVENTION

We may process information where reasonably necessary to:

• Protect user accounts

• Prevent fraud

• Detect abuse

• Protect TRKA's website

• Protect paid content

• Investigate security incidents

This is based on our legitimate interest in protecting TRKA and its users.

D. LEGAL AND ACCOUNTING OBLIGATIONS

Certain information may be processed or retained where necessary to:

• Comply with tax requirements

• Maintain transaction records

• Comply with accounting obligations

• Respond to legal requests

• Handle consumer claims

• Establish, exercise, or defend legal rights

This processing is based on applicable legal obligations and legitimate interests where appropriate.

E. ANALYTICS

Where enabled and where the required consent has been provided, TRKA may use analytics services such as Google Analytics.

Analytics may help us understand:

• How many people visit TRKA

• Which pages are visited

• How people use the website

• General traffic patterns

• Device and browser information

• Approximate geographic information

Where legally required, analytics cookies or similar technologies are used only according to the user's consent choices.

F. ADVERTISING

TRKA may use services such as Google Ads.

Where enabled, these services may be used to:

• Measure advertising performance

• Measure conversions

• Understand whether ads lead to visits or purchases

• Support remarketing or personalized advertising where legally permitted

Where consent is legally required, advertising technologies are subject to your cookie consent choices.

G. EMAIL COMMUNICATIONS

TRKA may send:

• Purchase confirmations

• Account-related messages

• Course-related information

• Support replies

• Service notices

If TRKA sends promotional or marketing emails, those communications will be sent in accordance with applicable law.

Where consent is required, you can withdraw that consent or unsubscribe from marketing communications at any time.

5. LEGAL BASES FOR PROCESSING

Depending on the activity, TRKA may rely on:

PERFORMANCE OF A CONTRACT

For example:

• Providing a purchased course

• Delivering a digital comic

• Managing an account

• Processing a transaction

• Providing purchase-related support

CONSENT

For example:

• Non-essential cookies

• Analytics cookies

• Advertising cookies

• Certain marketing communications

You may withdraw your consent at any time.

LEGITIMATE INTERESTS

For example:

• Preventing fraud

• Protecting accounts

• Protecting TRKA's intellectual property

• Responding to enquiries

• Maintaining website security

• Preventing abuse

LEGAL OBLIGATIONS

For example:

• Tax requirements

• Accounting requirements

• Consumer protection obligations

• Legal or regulatory requests

6. PODIA

TRKA uses Podia to provide much of its website and digital-product infrastructure.

Podia may process information for functions including:

• Website hosting

• User accounts

• Course access

• Course progress

• Quizzes

• Digital product delivery

• Customer records

• Checkout infrastructure

• Email and account functions

Podia processes much of this information on behalf of TRKA as a service provider.

Podia maintains its own privacy policy and data-processing terms.

7. STRIPE

TRKA uses Stripe for payment processing.

Stripe may process information required to complete and secure payments, including payment and transaction data.

TRKA does not directly store complete card numbers or card security codes.

Stripe may act as a data processor when facilitating payments on behalf of TRKA and may also act as an independent data controller for certain purposes, including fraud prevention, security, compliance, and operation of Stripe's own services.

Stripe maintains its own privacy policy and data protection documentation.

8. GOOGLE SERVICES

TRKA currently uses or may use Google services including:

• Google Analytics

• Google Ads

• Google email services

Where enabled, these services may process technical, analytics, advertising, or communication information.

Analytics and advertising technologies that require consent will be subject to the user's cookie consent choices.

9. COOKIE SCRIPT

TRKA uses Cookie Script as a cookie-consent management service.

Cookie Script may process information necessary to:

• Display cookie choices

• Remember consent preferences

• Manage cookie categories

• Communicate consent choices to website technologies

Necessary cookies may operate where permitted without consent because they are required for the website or requested service to function.

Non-essential cookies are subject to applicable consent requirements.

10. DISCORD COMMUNITY

TRKA may provide access or links to a free community hosted through Discord.

Discord is an independent third-party service.

If you use Discord, Discord processes information according to its own terms and privacy practices.

Within a TRKA community, TRKA may be able to view information that you voluntarily make visible on Discord, such as:

• Username

• Profile information

• Messages

• Posts

• Community activity

TRKA does not control Discord's independent processing of your personal information.

11. THIRD-PARTY SERVICE PROVIDERS

TRKA may rely on third-party services including:

• Podia

• Stripe

• Google

• Cookie Script

• Discord

• Social-media platforms

• Other technical providers necessary to operate the service

These providers may receive or process information where necessary to provide their services.

TRKA does not sell personal information to third parties.

12. INTERNATIONAL DATA TRANSFERS

Some providers used by TRKA operate internationally.

As a result, personal information may in some circumstances be processed outside Spain or the European Economic Area.

Where applicable data protection law requires safeguards for an international transfer, the relevant transfer must rely on an appropriate legal mechanism, such as an adequacy decision, contractual safeguards, or another mechanism permitted by law.

13. HOW LONG INFORMATION IS KEPT

Personal information is kept only for as long as reasonably necessary for the purpose for which it was collected or where a longer period is required by law.

For example:

• Account information may be retained while the account remains active

• Course progress may be retained while necessary to provide the course

• Purchase records may be retained for tax, accounting, consumer, or legal requirements

• Support messages may be retained where necessary to resolve issues or protect legal interests

• Consent records may be retained where necessary to demonstrate compliance

When information is no longer required, it may be deleted or anonymized unless continued retention is required by law.

14. DATA SECURITY

TRKA uses reasonable organizational and technical measures intended to protect personal information.

TRKA also relies on service providers such as Podia, Stripe, and Google, which maintain their own security measures.

However, no internet service or electronic storage system can guarantee absolute security.

Users are responsible for keeping their login credentials secure.

15. YOUR PRIVACY RIGHTS

Depending on applicable law, including the GDPR, you may have rights including:

• The right to access your personal information

• The right to correct inaccurate information

• The right to request deletion of personal information

• The right to request restriction of processing

• The right to object to certain processing

• The right to data portability where applicable

• The right to withdraw consent where processing is based on consent

• The right not to be subject to certain solely automated decisions

• The right to lodge a complaint with a data protection authority

These rights may be subject to conditions and exceptions provided by law.

16. HOW TO EXERCISE YOUR RIGHTS

To exercise a privacy right or ask a privacy-related question, contact:

trkamail10@gmail.com

Please explain what you are requesting.

We may request reasonable information necessary to verify your identity before providing, changing, or deleting personal information.

Requests will be handled in accordance with applicable data protection law.

17. SPANISH DATA PROTECTION AUTHORITY

If you believe that your personal information has been processed unlawfully, you may have the right to lodge a complaint with the:

Agencia Española de Protección de Datos (AEPD)

Website:

https://www.aepd.es

18. AUTOMATED DECISION-MAKING

TRKA does not currently use personal information to make solely automated decisions that produce legal effects or similarly significant effects on users.

If this changes, this Privacy Policy will be updated where required.

19. CHILDREN'S DATA

TRKA does not intentionally seek unnecessary personal information from children.

Where consent from a parent or legal guardian is required by applicable law, TRKA will rely on the legally required authorization.

If you believe that personal information relating to a minor has been provided to TRKA unlawfully, contact:

trkamail10@gmail.com

20. THIRD-PARTY LINKS

TRKA may contain links to independent websites and platforms.

TRKA does not control the privacy practices of third-party websites.

Users should review the privacy information of those services before providing information directly to them.

21. CHANGES TO THIS PRIVACY POLICY

TRKA may update this Privacy Policy to reflect:

• Changes to our services

• Changes to technology providers

• Changes to data-processing practices

• Legal or regulatory changes

• Improvements or clarifications

The latest version will be published on this page with an updated "Last updated" date.

22. CONTACT

For privacy-related questions or requests:

TRKA

Email:

trkamail10@gmail.com

Website:

https://www.trkauniverse.com