Privacy Policy – Invicta Capital

PRIVACY POLICY

Last updated: 24 August 2026

At Baatsen BV, hereinafter referred to as Invicta Capital ("we", "us", "our"), your privacy matters. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and what rights you have.

By using our website or services, you agree to this Privacy Policy. If you do not agree, please do not use our website or services.


1. DATA CONTROLLER

The data controller responsible for your personal data is:

Batsen BV (Invicta Capital)
Email: ilias@invictacapital.co
Website: https://www.invictacapital.co


2. INFORMATION WE COLLECT

We collect the following categories of personal data:

2.1 Information you provide directly

- Name, email address, phone number
- Billing address and VAT identification (for business clients)
- Company name, industry, business details
- Payment method details (processed securely by Stripe or PayPal; we do not store full card details)
- Content you submit through forms, surveys, calls, or communications
- Content you share within our community platforms (e.g. Skool)

2.2 Information collected automatically

- IP address, browser type, device type, operating system
- Pages visited, time spent, click behavior
- Referrer URLs (the site that sent you to ours)
- Cookies and similar tracking technologies (see Section 6)

2.3 Information from third parties

- Meta (Facebook, Instagram) and Google may share aggregated ad performance data when you interact with our ads
- Payment processors (Stripe, PayPal) may share payment status and metadata


3. HOW WE USE YOUR DATA

We process your personal data for the following purposes:

- Delivering our Services: providing coaching, training, marketing, consulting, and community access
- Processing payments: invoicing, subscription management, refunds
- Customer support: responding to questions, troubleshooting
- Marketing communications: sending newsletters, offers, and campaign updates (only with your consent, or under legitimate interest for existing clients)
- Analytics and improvement: understanding how our website and funnels perform
- Legal compliance: VAT reporting, bookkeeping, fraud prevention
- Advertising: retargeting via Meta and Google, always in line with your cookie preferences


4. LEGAL BASIS FOR PROCESSING

Under the EU General Data Protection Regulation (GDPR), we process your data based on:

- Contract performance: to deliver the Services you purchased
- Legal obligation: for tax, invoicing, and record-keeping requirements
- Legitimate interest: for improving our services, security, and B2B marketing to existing clients
- Consent: for marketing to non-clients, advertising cookies, and optional integrations (you may withdraw consent at any time)


5. THIRD-PARTY SERVICES WE USE

We work with the following processors and platforms. Each has its own privacy policy governing how they handle your data:

Stripe (payment processing): https://stripe.com/privacy

PayPal (payment processing): https://www.paypal.com/privacy

ClickFunnels (funnel hosting and lead capture): https://www.clickfunnels.com/privacy

GoHighLevel (CRM, automation, SMS, and email delivery): https://www.gohighlevel.com/privacy-policy

Brevo / Sendinblue (email marketing and transactional email): https://www.brevo.com/legal/privacypolicy/

Skool (community platform and course delivery): https://www.skool.com/privacy

Make (automation and workflow integration): https://www.make.com/en/privacy-notice

Zapier (calendar sync between Calendly and GoHighLevel): https://zapier.com/privacy

Calendly (meeting scheduling): https://calendly.com/privacy

Google Tag Manager and Google Analytics (website tracking and analytics): https://policies.google.com/privacy

Meta / Facebook and Instagram Pixel (advertising, retargeting, and conversion tracking): https://www.facebook.com/privacy/policy

We do not sell your personal data to any third party.


6. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

- Enable essential website functions (session, security)
- Analyze site performance and user behavior (Google Analytics)
- Measure ad performance and enable retargeting (Meta Pixel, Google Ads)
- Personalize content based on your visit history

You can manage your cookie preferences at any time through your browser settings. Blocking non-essential cookies will not affect your ability to purchase or use our Services.

Where required by law (EU/UK), we display a cookie consent banner before setting non-essential cookies.


7. DATA RETENTION

We retain your personal data only as long as necessary for the purposes described above:

- Client and payment data: kept for the duration of our commercial relationship, plus a minimum of 7 years for legal and tax purposes (as required under Belgian bookkeeping law).
- Marketing data: kept until you unsubscribe or withdraw consent, and up to 24 months thereafter for statistical purposes.
- Analytics data: kept in aggregated form; personally identifiable analytics data is retained for a maximum of 26 months.
- Support communications: kept for up to 3 years after resolution.

After the retention period, data is either deleted or fully anonymized.


8. YOUR RIGHTS UNDER GDPR

If you are located in the European Union, you have the following rights regarding your personal data:

- Access: request a copy of the data we hold about you
- Rectification: request correction of inaccurate or incomplete data
- Erasure ("right to be forgotten"): request deletion of your data, subject to legal retention obligations
- Restriction: request that we limit how we use your data
- Data portability: receive your data in a structured, machine-readable format
- Objection: object to processing based on legitimate interest, including direct marketing
- Withdraw consent: where processing is based on consent, you may withdraw it at any time
- Complaint: file a complaint with the Belgian Data Protection Authority (https://www.dataprotectionauthority.be) or your local supervisory authority

To exercise any of these rights, contact us at ilias@invictacapital.co. We will respond within 30 days.


9. INTERNATIONAL DATA TRANSFERS

Some of our processors (e.g. Stripe, ClickFunnels, GoHighLevel, Meta, Google) are located outside the European Economic Area (EEA), primarily in the United States. When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:

- EU Standard Contractual Clauses (SCCs)
- Adequacy decisions by the European Commission where applicable
- The EU-US Data Privacy Framework where applicable


10. DATA SECURITY

We implement reasonable technical and organizational measures to protect your data, including:

- Encrypted data transmission (HTTPS/TLS)
- Access control and authentication on all internal systems
- Secure third-party processors that are GDPR-compliant
- Regular review of security practices

Despite our efforts, no method of internet transmission or electronic storage is 100% secure. In the event of a data breach, we will notify affected users and the relevant authorities as required by law.


11. CHILDREN'S PRIVACY

Our Services are intended for individuals aged 18 or older. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected data from a minor, we will delete it promptly.


12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make significant changes, we will notify you by email (if we have your email) or by prominent notice on our website.

The "Last updated" date at the top of this page reflects the most recent revision.


13. CONTACT

For any questions, requests, or concerns about this Privacy Policy or how we handle your personal data, please contact:

Batsen BV (Invicta Capital)
Email: ilias@invictacapital.co
Website: https://www.invictacapital.co


By using our website or Services, you acknowledge that you have read and understood this Privacy Policy.