Privacy Policy

1. Controller

The controller is The Zorva Institute. Data protection enquiries: privacy@zorvacourses.com.

2. Data we collect

2.1 Identity and account data

Name as recorded at Tier 1, date of birth, email address, postal region, billing details, practitioner number, and the tier held.

2.2 Submitted practice data

Baseline records, daily logs, notation submissions, response markers, constraint statements, frequency maps, workbook entries submitted to the register, and video playback logs for assessment.

2.3 Behavioural and progress telemetry

From Tier 6 onward, and continuously from Tier 10, we collect adherence telemetry: event timestamps, sequence completion, deviation events and their reported causes, interval duration and interruption, device motion and ambient signals where the practitioner has installed the companion application, and derived indices including load-bearing rating, continuity score, and drift index.

2.4 Annotations

Institute staff attach annotations to practitioner records. Annotations are inferences rather than statements of fact and are not disclosed to the practitioner, as disclosure would compromise their evidential value at later tiers.

2.5 Technical data

IP address, device and browser identifiers, referrer, and pages viewed on this site.

3. Purposes and legal bases

• Contract: administering enrolment, progression, assessment and payment.
• Legitimate interests: maintaining the integrity of the register, preventing falsified telemetry, and longitudinal study of practitioner progression by the Institute.
• Consent: optional companion-application sensors and marketing correspondence. Consent may be withdrawn, though withdrawal may render a tier unassessable.
• Legal obligation: accounting and tax records.

4. Retention periods

• Identity and billing records: ten years from last transaction.
• Foundation Track practice data: duration of practitioner status plus seven years.
• Applied and Advanced telemetry: thirty years from collection.
• Baseline figures, register entries, and Institute annotations: retained indefinitely. Register entries are closed rather than deleted, including on termination and on death.
• Assessment recordings: retained indefinitely as Institute property.
• Custodial Track records: retention is determined by the Board of Practice.

5. Third-party processors

We share data with the following categories of processor under written agreement:

• Payment processing and fraud prevention (EU and Switzerland).
• Cloud hosting and backup (EU regions only).
• Email and correspondence delivery.
• Telemetry ingestion and derived-index computation (Institute Research, Zurich).
• Professional advisers, auditors, and regulators where legally required.

We do not sell personal data. Transfers outside the EEA are made under standard contractual clauses.

6. Cookies

This site uses strictly necessary cookies for session handling and preference storage, and analytics cookies to measure page performance. Analytics cookies are set only with consent and expire after thirteen months. A practitioner-recognition cookie is set on sign-in and persists for the duration of practitioner standing.

7. Your rights

Subject to applicable law, you may request access to your data, correction of factual inaccuracies, erasure, restriction, portability, and objection to processing carried out on the basis of legitimate interests.

Certain records are exempt from erasure where retention is necessary for the integrity of the register or for the Institute's ongoing longitudinal study. In practice this means that identity, tier history, baseline figures and annotations will normally be retained after a valid erasure request has otherwise been honoured. We will tell you which categories were retained, but not their content.

You may lodge a complaint with the Belgian Data Protection Authority or your local supervisory authority.

8. Automated decision-making

Eligibility for progression is informed by derived indices computed from telemetry. A registrar reviews every determination before it takes effect, so no decision is made on a solely automated basis. The weighting of indices is not published.

9. Children

The Method is not offered to persons under eighteen. Where we learn that a practitioner is under age, the enrolment is closed and fees are not refunded.

10. Contact for data requests

Write to privacy@zorvacourses.com. Please quote your practitioner number. Requests are acknowledged within thirty days and are logged against your progression record.