Legitimate Interests Assessment
Effective date: 01.06.2026
TEACHER DATA-SHARING TERMS — STUDENT DATABASE ACCESS
Before you can add student details to the Grinberg Method database, you must read and accept the terms below. By ticking "I agree" and continuing, you confirm each of the following on behalf of yourself as an independent data controller.
These terms record the Legitimate Interests Assessment that GDPR (Article 6(1)(f)) requires you to make before sharing student data with WISDOMISSION - UNIPESSOAL LDA. ("the Company"). They apply in addition to your Teacher Data Sharing Agreement.
WHAT YOU ARE SHARING
You are sharing each enrolled student's full name and email address with the Company. Nothing else — no session notes, payment details, health information, or other data.
WHY THIS IS LAWFUL — LEGITIMATE INTERESTS
Your lawful basis for sharing this data is legitimate interests (Article 6(1)(f) GDPR, or the equivalent under your national law). By continuing, you confirm you accept the following assessment:
1. PURPOSE. As a condition of your authorisation to teach the Grinberg Method, all your students must purchase the Company's official study materials at www.grinbergmethod.com. The Company needs students' names and emails to verify this has been met. This serves your legitimate interest in keeping your authorisation to teach, and the Company's legitimate interest in protecting the integrity of its programme.
2. NECESSITY. The Company cannot verify a purchase without identifying the student. Only the minimum data is shared (name and email), and there is no less intrusive way to achieve the same verification.
3. BALANCE. The processing is fair to students because:
- they are told about it before they enrol, through the required disclosure clause in your student agreement;
- the data is not sensitive and does not concern children;
- it is used solely to check a purchase — never for marketing or onward sharing;
- it is deleted within 12 months; and
- students are informed of their rights and how to exercise them (info@grinbergmethod.com).
On balance, these interests are not overridden by students' rights and freedoms.
OUTCOME: You may rely on legitimate interests as your lawful basis for this sharing.
BEFORE YOU ADD A STUDENT
You confirm that, for every student whose details you add:
- the student has already been given the required data-sharing disclosure (the clause provided to you) before enrolling; and
- the student is currently enrolled, or enrolled within the last 3 months.
IF YOU ARE BASED OUTSIDE THE EU/EEA
If you teach from outside the European Economic Area (for example the UK, Switzerland, USA, Australia, or elsewhere), one extra point applies — but nothing else changes:
Adding student data here transfers it to Portugal (EU), where it is protected by the GDPR and Portuguese law. Because the data moves into a jurisdiction with a high standard of protection, this supports the assessment above rather than weakening it. You confirm that you have given your students the international transfer notice (the "Annex B" / non-EEA version of the disclosure wording) and have met any local-law requirement to notify students of, or obtain consent for, the transfer. If you are in the UK the UK GDPR applies to your processing; if you are in Switzerland the Swiss FADP applies.
YOUR CONFIRMATION
By ticking "I agree" and continuing, you confirm that:
- you have read and accept the legitimate interests assessment above;
- you will only add students who have received the required disclosure; and
- you will keep your own record of this acceptance, and review it if your circumstances change.
