International Anti Crime Academy BV | www.anti-crime-academy.com

These Terms and Conditions apply to the training courses offered by International Anti Crime Academy BV, located at Ericssonstraat 2, 5121 ML Rijen, the Netherlands. Please read these Terms and Conditions carefully.  

These Terms and Conditions constitute a valid and binding agreement between IACA and the Client/Participant. By registering for a Training Course, you agree to be bound by these Terms and Conditions. These Terms and Conditions are available on the International Anti Crime Academy BV website ( www.anti-crime-academy.com ) and will be sent free of charge upon request.

 1. Definitions

In these Terms and Conditions, the following terms are used, capitalized and used in both the singular and plural. These terms have the following meanings:

1.1. IACA 

The private limited liability company International Anti Crime Academy BV, registered with the Chamber of Commerce under number 58500251, with its registered office in Gilze en Rijen, and its registered office at Ericssonstraat 2, 5121 ML, Rijen;

1.2. Client 

Any natural or legal person who purchases a Training from IACA, either for themselves or for their employees. 

1.3. Participant 

Any natural person who participates in a Training Course at IACA, regardless of whether registration takes place in a personal capacity or through a registration arranged by a client. 

1.4. Agreement

• The agreement between IACA and the Client for the purchase and provision of a Training is governed by these General Terms and Conditions. 
• All quotations, offers, orders, and agreements between IACA and its Client are governed by these General Terms and Conditions. These terms and conditions therefore expressly apply to both the quotation and its acceptance, as well as to the resulting agreement.  
• Other General Terms and Conditions or other provisions of the Client will not be accepted unless this is agreed in writing between the Client and IACA. 

1.5. Training

The vocational training, workshop, training, lecture or closed training that the Participant follows or the Client purchases from IACA. 

1.6. Delivery format 

The delivery format refers to the way in which a vocational training program, workshop, training, lecture, open or closed program is offered and followed. The different delivery formats are: 

• In-person: The Training takes place physically at a location where the Participants and instructor(s) are present. 
• Live Classroom: The Course will be delivered live in a classroom setting with the Participants and instructor(s) physically present. 
• Live Virtual: The Training will be delivered live via an online platform or video conference, with Participants and instructor(s) participating remotely. 
• On-demand: The Training is pre-recorded and can be accessed by the Participant at any time, without the need for a live instructor. 

1.7. Intellectual Property Rights

At IACA, intellectual property rights encompass all rights related to training materials, certifications, training materials, and databases such as OSINT (OSIDATA). These materials contain data, concepts, technologies, and other intellectual property owned by, licensed to, and controlled by IACA. IACA's intellectual property rights are intended to ensure the exclusive control and protection of these materials, with unauthorized use being strictly prohibited and subject to legal penalties.

1.8. Additional Terms for US and Canadian Participants
: Additional terms apply to participants located in the United States or Canada. These specific terms will be provided to the participant after receipt of registration and must be explicitly accepted before registration is finalized.

2. Formation of the Agreement

The agreement between IACA and the Client is concluded upon receipt of a signed (digital) registration form and subsequent written confirmation by IACA to the Client. Registration is only final after confirmation by IACA. Any questions about the registration will be answered by IACA as soon as possible, but within a maximum of 48 hours, excluding weekends and public holidays. 

3. Age requirement 

Before the Client or Participant may use an IACA website or register for and participate in any training, product, or service offered by IACA, the Client or Participant must agree to this Agreement. The Client or Participant represents that they are at least 18 years of age and have the legal capacity to enter into this Agreement. If the Client or Participant is under 18 years of age and/or lacks the legal capacity to agree to this Agreement, it is necessary that the Client or Participant have a legal guardian review and agree to this Agreement on their behalf in order for the Client or Participant to access an IACA website or complete the registration and purchase of any training, product, or service offered by IACA. 

If a minor participates without the required consent of a legal guardian, the agreement will be considered null and void. This means that IACA reserves the right to immediately terminate the minor's participation. In such cases, IACA cannot accept any liability for any damages or consequential damages resulting from the minor's participation without the necessary legal consent. The minor and their legal guardians are responsible for all costs arising from the unauthorized participation in the Training. 

4. Execution 

IACA is entitled to: 

• The Training Programs may be changed from time to time due to reprogramming of examination requirements from external examination institutes and/or for reasons of qualitative improvement. 
• To change the schedule of the Training in terms of place and time. 
• If there are insufficient registrations, we may cancel a start date or refuse new registrations for an existing course. Registered participants will receive written notification of this, after which their obligations will be cancelled. 
• To reduce the number of meetings per course, while keeping the price the same and reducing the number of meetings by a maximum of 25%. 
• In exceptional cases, increase the group size by a maximum of 100%. 
• To change the delivery format (for example, from in-person to virtual) without affecting the Training Costs. 
• To screen a (potential) Participant through an open-source investigation and to refuse training to any group, entity or individual or to exclude them from further participation. 
• We conduct a careful selection process for participants in our training programs. We apply the following criteria when admitting participants:
  • Relevance of the Training to the professional background of the Participant.
  • Participant's potential contribution to learning objectives and group dynamics.
  • Strive for a diverse and balanced composition of the Participant Group.
  • Alignment with our strategic Training Objectives.

• In line with these criteria:
  • To give priority to participants from certain professional sectors.
  • To reject potential Participants who do not meet the stated criteria.

IACA will apply these criteria in a non-discriminatory manner.

5. Overtaking

The Participant has the right, after consultation with IACA, to make up a missed (theory) lesson with another group if IACA deems this possible. IACA is not liable for this. Making up exams and practical training is generally not possible; the Participant must re-register and pay the full fee again. 

Exceptions to this prohibition may be considered. In exceptional cases, such as prolonged illness or other serious circumstances, the Participant or Client may submit a request to make up a missed exam or missed practical training. This request must be submitted in writing and with reasons to IACA. After review and approval by IACA, a make-up opportunity may be offered. Any additional costs associated with this will be borne by the Participant or Client. 

6. Examination regulations and responsibilities

• IACA applies the basic examination regulations for its examinations. 
• IACA also prepares for third-party exams. The Client and/or Participant is responsible for registering for these exams on time. 
• Examination fees may be changed once a year, starting in January, without prior notification to Clients. 
• Diplomas and certificates will only be sent after the Client has fully met the payment obligation. 
• The participant is responsible for their own exam results. IACA accepts no liability for missed results. 
• Taking or completing a course at IACA does not guarantee exemptions, admission, or a reduction in study duration at external programs or institutions. IACA is not responsible or liable for these. The responsibility for investigating this prior to registration lies solely with the Participant.

7. Business Partners

IACA reserves the right to have the Training delivered in certain regions by an (international) Business Partner authorized by IACA. 

8. Price

All prices listed in quotes, brochures, and other communications are VAT-exempt, unless explicitly stated otherwise. Prices are valid from January 1st to December 31st of the current year. Any price increases will take effect on January 1st of the Training Year. These new prices also apply to Clients who registered and orders placed before December 31st of the previous year.

9. Payment terms and taxes

• All amounts are due and payable in advance. Payment must be made on or before the due date stated on the invoice. The invoice will be sent immediately after registration and has a standard payment term of 30 days. 
• The Participant always remains personally responsible for the payment of the Training Costs if his or her employer does not make payment (on time). 
• The Client is not authorised to deduct any amount from the invoice amount by reason of a counterclaim made by him. 
• In case of late payment from the invoice due date, a reminder invoice will be sent, for which an administration fee of €10.00 will be charged per reminder after 30 days. 
• After two payment reminders, the invoice will be handed over to a debt collection agency. All judicial and extrajudicial collection costs and interest will be borne by the Client. 
• Failure to pay on time may result in the Participant being denied access to IACA classes and exams. Failure to attend classes and exams does not cancel the Participant's financial obligation to IACA. 
• In the event of non-payment, IACA may unilaterally terminate the agreement with the Client without any notice of default being required. In that case, IACA is entitled to charge the original invoice amount to the Client and demand immediate payment. 
• In the event of non-fulfilment or late fulfilment of any obligation arising from the agreement for the Client, suspension of payments, bankruptcy, liquidation of the business, or seizure, every claim of IACA on the Client shall be immediately due and payable in full. 
• In such cases, IACA also has the right to cancel current agreements, insofar as they have not yet been performed, without judicial intervention and to reclaim the delivered goods that have not yet been paid for, without prejudice to the right to compensation. 
• The Client is obligated to provide accurate, complete, and current information when making a purchase or transaction. Any applicable taxes related to such purchases or transactions from IACA are the sole responsibility of the Client. 

10. Statutory cooling-off period for private individuals

• After registering for a Course, the Client, if a natural person not acting in the course of a profession or business, has a statutory 14-day cooling-off period. During this cooling-off period, registration can be cancelled without giving a reason and without consequences. 
• This cooling-off period also applies if the Client books the Training and the costs are paid by the company or the employer, provided that the Client concludes the agreement themselves. 
• If a company or employer concludes the agreement, no cooling-off period applies. 

11. Retention of title 

• Goods delivered (training materials, textbooks, etc.) remain the property of IACA until full payment has been made. 
• The risk with regard to damage and loss of the goods, as well as any resulting damage, passes to the Client after delivery and acceptance of the goods. 
• Without the consent of IACA, the Client is not entitled to transfer ownership of goods that have not yet been fully paid for to third parties, other than by normal processing according to their intended purpose, or to grant a pledge or any other security right in the broadest sense of the word on these goods to third parties by any agreement or act. 
• In the event of violation of this provision, the purchase price shall become immediately and fully due and payable, without prejudice to any further claims of IACA. 
• If the Client fails to fulfil its payment obligations in a timely manner, IACA shall be entitled, without any notice of default, to reclaim the goods delivered but not yet paid for. 

12. Intellectual Property Rights and Usage Restrictions

All Training Materials, certifications, and training materials provided by IACA, including but not limited to the OSINT database (OSIDATA), are protected by copyright and other intellectual property rights. These materials contain data, concepts, technology, and intellectual property owned by, licensed to, and controlled by IACA. The Client or Participant does not acquire any intellectual property rights to the Training Materials, certifications, and training materials. However, IACA grants the Client or Participant a limited, worldwide, non-transferable, perpetual, irrevocable, and non-exclusive license to use the materials for non-commercial purposes. 

The Client or Participant is expressly prohibited from: 

• To copy, reproduce, distribute, display, modify or create derivative works of the materials without the prior written consent of IACA. 
• To make the materials available to third parties without the written permission of IACA. 
• To use the materials for providing training or for training purposes, nor to enable others to do so. 
• Reverse engineering, decompiling, or otherwise attempting to reconstruct the source code or underlying ideas and principles of the IACA materials. 

If the Client or Participant violates these provisions, IACA reserves the right to take appropriate legal action and claim damages for the damages suffered. Upon detection of unauthorized use or distribution of the material, IACA reserves the right to immediately terminate the Client's or Participant's access to the Training without refunding any Training Fees already paid. IACA also reserves the right to exclude the Client and/or Participant from future Training Courses in the event of a violation of intellectual property rights. 

13. Cancellation of Open Classroom Courses

• Cancellation of a Course must be submitted in writing and by registered mail. The postmark date serves as the cancellation notice period. 
• Written confirmation from IACA serves as proof of cancellation. The scheduled start date of the Training will serve as the basis for handling cancellations. 
• The costs associated with cancelling a Course are: 
  • €100 if cancelled more than 4 weeks before the start date. 
  • 50% of the total price in case of cancellation up to 14 days before the start. 
  • 100% of the total price in case of cancellation within 14 days before or after the start of the Course. 
  • If IACA has incurred additional costs on behalf of the Client, these costs will be claimed in addition to the cancellation costs described above. 
• The refund of the training fee already paid will take place within 14 days after confirmation of the cancellation by IACA. 
• In the event the Participant does not appear during the Training, the Client is not entitled to any refund. 
• An appeal to force majeure by the Participant or his/her employer (e.g. illness, indispensability in the company) does not affect the obligation to fulfil the financial obligations towards IACA. 
• If the Participant dies or if exceptional circumstances exist that make payment of the cancellation fee unacceptable according to standards of reasonableness and fairness, a written, reasoned request can be submitted to IACA. IACA reserves the right to request written proof. 
• Cancellation costs are immediately due and payable. 

14. Cancellation of Closed Training

• Cancellation of a Private Training Course must be submitted in writing and by registered mail. The postmark date serves as the cancellation notice period. 
• Written confirmation from IACA serves as proof of cancellation. The scheduled start date of the Training will serve as the basis for handling cancellations. 
• The costs associated with cancelling a Closed Training Course are: 
  • €1000,- if cancelled more than 4 weeks before the start date. 
  • 50% of the total price in case of cancellation up to 14 days before the start. 
  • 100% of the total price in case of cancellation within 14 days before or after the start of the Closed Training. 
  • If IACA has incurred additional costs on behalf of the Client, these costs will be charged in addition to the cancellation fees described above. Examples of such additional costs may include booked travel and accommodation expenses, as well as costs for specially tailored training materials, hired guest lecturers or instructors, and rental of special locations or equipment necessary for the execution of the Training. 
• The refund of the Training Fees already paid will take place within 14 days after confirmation of the cancellation by IACA. 
• In case of cancellation of a Closed Training Course after the commencement of the Closed Training Course, no refund of the Training Costs is possible. 
• Cancellation costs are immediately due and payable. 

15. Cancellation due to force majeure

• IACA reserves the right to reschedule and/or cancel the Training in the event of external force majeure or insufficient participation (less than 5 Participants). 
• In the event of complete cancellation of the Training by IACA, the Training Fee already paid will be refunded within 14 days. 
• If an alternative start date is offered, there is no right to a refund of the Training Costs. 
• External force majeure means circumstances beyond IACA's control that make it impossible to carry out the Training, such as but not limited to natural disasters, pandemics, government measures, and other unforeseen events. 
• In the event of a rescheduling of the Training, IACA will inform the Client and Participant of the new start date as soon as possible. 
• If the Training is postponed by IACA due to force majeure, the registration of the Client and Participant remains valid for the new start date. 

16. Liability

16.1. The Participant is fully responsible and liable for all actions performed during the Training. The Client indemnifies IACA against all claims arising from the Participant's actions during the Training. 

16.2. IACA disclaims all liability, except as provided by law. If, due to force majeure or insufficient participation, IACA is forced to deviate from the planned Training dates, or to cancel the Training entirely, IACA is not liable for any damages such as lost work hours or travel and accommodation expenses. Force majeure includes any situation beyond our control, such as, but not limited to: instructor illness, natural disasters, terrorism, government measures, strikes, and technical failures. 

16.3. IACA uses third-party tools and software during the Training. IACA is not responsible for the availability, accuracy, or reliability of these tools and accepts no liability for any damage, security risks, or legal consequences arising from their use. The participant remains responsible at all times for the correct and lawful use of the methods learned.

16.4. IACA is never liable for malware or other malicious software such as viruses or spyware, regardless of whether it is present in third-party materials or tools. 

16.5. If IACA is held liable, its maximum liability is limited to direct damages up to a maximum of EUR 500. Indirect damages, such as consequential damages, loss of profits, business interruption, operational consequences, reputational damage, technical failures, or security risks, are explicitly excluded. 

16.6. IACA's liability for breaches of contractual obligations arises only if IACA fails to fulfill these obligations after a written notice of default setting a reasonable period of 30 days for remedy. A breach does not occur if it is the result of force majeure. IACA's liability will in no case exceed the limits stated above. 

16.7. In the event of force majeure lasting longer than 120 days, both IACA and the Client may terminate the agreement without being liable for damages. 

16.8. Any right to compensation arises only if the damage is reported to IACA in writing within 30 days of its occurrence. Any claim for compensation against IACA expires twelve months after the claim arose, unless legal action is taken within that period. 

16.9 The Client and Participant guarantee that they will at all times comply with all applicable laws and regulations relating to the Training and the performance of this Agreement. 

Liability and Indemnification

The Client or Participant agrees to indemnify IACA from and against any claims, liabilities, damages, or costs arising from their participation in the Training or any breach of this agreement. This indemnification includes reasonable attorneys' fees and costs incurred by IACA in defending such claims. Claims for indemnification must be submitted in writing to IACA within 30 days of discovery, and the parties agree to fully cooperate in defending any claims or actions.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IACA'S AGGREGATE LIABILITY UNDER THIS AGREEMENT SHALL NOT EXCEED EUR 500. THIS LIMITATION OF LIABILITY APPLIES ONLY TO DIRECT DAMAGES AND EXCLUDES INDIRECT OR CONSEQUENTIAL DAMAGES, SUCH AS LOST PROFITS, BUSINESS INTERRUPTION, OPERATIONAL IMPACT, REPUTATIONAL DAMAGE, TECHNICAL MALFUNCTION, OR SECURITY RISKS. THE CLIENT OR PARTICIPANT ACKNOWLEDGES AND AGREES THAT THESE LIMITATIONS OF LIABILITY REFLECT A REASONABLE ALLOCATION OF RISK AND ARE AN ESSENTIAL ELEMENT OF THE AGREEMENT BETWEEN IACA AND THE CLIENT OR PARTICIPANT. WITHOUT THESE LIMITATIONS, IACA WOULD NOT BE ABLE TO OFFER THESE COURSES, PRODUCTS, OR SERVICES.

Anti-spam filters and email alerts 

IACA acknowledges that it cannot be held liable if the Client's or Participant's confirmation email is blocked by their spam filters. It is the Client's or Participant's sole responsibility to ensure that their email account associated with their registration allows receipt of emails from anti-crime-academy.com. The Client's or Participant's responsibility is to adjust their email settings accordingly to ensure the successful delivery of important communications from anti-crime-academy.com. 

Warranty disclaimer  

IACA expressly disclaims all representations and warranties, whether oral or written, express, implied, or statutory, including, but not limited to, any implied warranties of fitness for a particular purpose or merchantability. In no event shall IACA be liable for incidental, indirect, consequential, exemplary, special, or punitive damages, regardless of whether reasonably foreseeable, and regardless of whether liability is based on contract, tort, or any other legal theory. 

17. Liability for Material and Immaterial Damage 

• IACA reserves the right to recover any material or immaterial damages resulting from an unlawful act by the Client or Participant from the Client or Participant personally. This applies for the entire duration of the Training. 
• Material damage means damage to IACA property, buildings, equipment and other physical assets. 
• Non-pecuniary damages are understood to mean damage to reputation, loss of goodwill, and other intangible damages suffered by IACA as a result of the unlawful act of the Client or Participant. 
• The Client or Participant shall be liable for all costs incurred by IACA in connection with the recovery of damages, including but not limited to legal costs and collection costs. 
• This provision shall not affect IACA's other rights to take further legal action and claim full compensation for any damages it has suffered. 

18. Confidentiality  

IACA and its employees are obligated to maintain confidentiality with respect to third parties regarding all information obtained about the Client and/or Participant during registration, screening, and participation in the Training. The Client and Participant are obligated to maintain confidentiality regarding the method of operation, the content of the Training, and IACA's (international) business partners. The acquired knowledge may not be commercially exploited by the Client or Participant. The Client or Participant is expressly prohibited from transferring the information to third parties or distributing it internally within their organization, unless explicitly permitted by IACA. It is also prohibited to use the information to provide commercial training to third parties.

If the Client or Participant fails to comply with these obligations, either in full or in part, they will owe IACA an immediately due and payable penalty of €25,000 (twenty-five thousand euros) per event, not subject to judicial mitigation, without prejudice to IACA's right to full compensation. In the event of a breach of confidentiality, IACA will take appropriate legal action to stop the breach and claim compensation for the damages suffered. This may include engaging a debt collection agency or initiating legal proceedings. 

The Participant and/or Client is expressly prohibited from making (secret) sound and/or visual recordings during the lesson, including recordings during virtual/digital lessons. 

19. Code of Conduct 

Professional conduct is required of all Participants during the Training and in interactions with both staff and fellow participants. Inappropriate behavior, including the use of offensive language, sexual harassment, and threatening behavior, will not be tolerated and may result in immediate removal from the training without refund. Participants are expressly prohibited from making (secret) audio or video recordings during the training, including recordings during virtual/digital lessons. 

If this provision is violated, IACA will immediately remove the Participant from the training and no refund will be made. Furthermore, IACA reserves the right to take legal action against the Participant, including seeking damages for any losses resulting from the violation of this Code of Conduct. This may include prohibiting them from future participation in IACA Training Courses. 

20. Privacy Policy 

IACA attaches great importance to protecting the privacy and security of the Client's and/or Participant's personal data. In line with this commitment, IACA has implemented measures to adequately protect and manage personal information. The IACA Privacy Policy, accessible at IACA Privacy Statement , provides detailed information about IACA's collection, use, disclosure, and storage of Client's and/or Participant's data.

The Privacy Policy forms an integral part of this Agreement and is hereby incorporated by reference. By accepting this Agreement, the Client and/or Participant also agrees to comply with the provisions set forth in IACA's Privacy Policy with respect to the purchased Training. IACA reserves the right to update the Privacy Policy periodically. Clients and Participants will be notified of such updates via the contact information they have provided, such as email. It is the Client's and/or Participant's responsibility to review and understand the updated terms of the Privacy Policy. 

21. Transfer of rights

The Client and Participant are not entitled to transfer the rights and obligations under this Agreement in whole or in part to third parties without the prior written consent of IACA.

22. Applicable law 

All our offers, agreements and their execution are exclusively governed by Dutch law.

23. Disputes

• General Procedure: In the event of any dispute arising out of or relating to this Agreement, the parties shall first attempt to resolve such dispute by mutual agreement. 
• Judicial Settlement: If the parties cannot resolve the dispute amicably, the dispute will be submitted to the competent Dutch court. Depending on the nature of the dispute, this will be the court in Breda, unless the law expressly designates another court as competent. 
• Individual Action: All claims must be filed individually, and not as part of a class action or collective action, or any other form of representative proceeding. By entering into this Agreement, both the Client and/or Participant and IACA waive their right to participate in a class action or other representative proceeding of any kind. 

Disclaimer:
IACA offers training courses demonstrating tools, methods, and techniques used in (digital) research. IACA makes no guarantees regarding the effectiveness, reliability, or legal admissibility of these tools and methods in specific cases. The use of third-party tools and the application of the methods learned is entirely at the participant's own risk. IACA is not responsible for technical malfunctions, security risks, legal consequences, operational consequences, or any other damage resulting from the use of these tools. The participant remains responsible at all times for the correct, safe, and lawful application of the knowledge and skills acquired.

Download: General Terms NL | General Terms ENG

International Anti Crime Academy BV | www.anti-crime-academy.com 

Complaints procedure

Below is the procedure for complaints addressed to International Anti Crime Academy BV. This policy applies to all courses, training programs, training programs, or workshops registered on our website: www.anti-crime-academy.com.

International Anti Crime Academy BV, hereinafter referred to as IACA. 

Whereas

That for the careful handling of a participant it is desirable that he or she can turn to a Complaints Committee with any complaints about the implementation of a course, training, education or programme if discussing his or her dissatisfaction with the teacher/trainer/educator/advisor of the registered trainer in question does not lead to a satisfactory result. 

Article 1 Definitions 

Participant

Anyone who is validly participating or has participated in a course, training, education or program that is registered on our website. 

Complaints Committee

The IACA Complaints Committee regarding courses, training programs, or programs. The committee consists of the IACA director and at least one independent officer who has no direct involvement or interest in the course, training program, or program about which the complaint is being filed. This independent officer may not be an employee or contractor of IACA, nor have any other business or personal relationship with IACA, its directors, employees, or the participants in question. 

Commissioner

The Founding Commissioner of IACA.

Course, training, education or trajectory 

The course, training, education or programme that is offered or organised as such and registered with IACA. 

Teacher/trainer/educator/advisor 

The person who carries out the course, training, education or programme on behalf of IACA. 

Complaint

Any written expression of dissatisfaction about a course, training, education or programme should be addressed to the Complaints Committee with the request to conduct an investigation and make a decision. 

Complainant

The person who has filed a written complaint with the Complaints Committee. 

Article 2 Admissibility

1. The participant and the person on whose behalf he or she participates or has participated in the course, training, education or programme may submit a written complaint about the implementation of the course, training, education or programme to the Complaints Committee up to two months after the end of the course, training, education or programme. 

2. The Complaints Committee may decide that a complaint submitted after the period referred to in the first paragraph will nevertheless be processed if, in the Committee's opinion, the complainant could not reasonably have been expected to submit his complaint earlier. 

3. Complaints are always treated confidentially. Registered complaints and the manner in which they were handled are retained for three years. The following measures are taken to ensure data confidentiality: 

• Access: Only members of the Complaints Committee and other directly involved parties have access to the complaint data. 
• Storage: Complaints and related documents are stored digitally in a secure environment protected by passwords and encryption. Physical documents are kept in a locked filing cabinet. 
• Data Destruction: After the three-year retention period, data is securely destroyed. Digital data is permanently erased, and physical documents are destroyed according to a certified procedure. 

Article 3 Composition of the Complaints Committee

The Complaints Committee consists of the IACA director and at least one independent officer (Mr. Chris van Gompel). They investigate complaints submitted in accordance with the complaints procedure described in Article 5.

Article 4 Task of the Complaints Committee

The Complaints Committee is responsible for investigating complaints submitted to it and for issuing a decision on them. 

Article 5 Complaints procedure

1. After the complaint is filed, the complainant will receive notification within five business days that his complaint has been received by IACA. 

2. The Complaints Committee will investigate the admissibility of the complaint. If the complaint is inadmissible, it will notify the complainant in writing, providing substantive reasons. 

3. If the complaint is admissible, the trainer of the relevant course, training, education or programme will be asked to provide a written response to this complaint. 

4. The Complaints Committee will send a copy thereof to the complainant. 

5. If, in the opinion of the Complaints Committee, it is not possible to form an opinion based on the complaint and the response of the trainer/instructor/advisor involved, the Complaints Committee will hear the complainant and the trainer/instructor/advisor involved in each other's presence. 

6. If the complainant or the teacher/trainer/educator/advisor involved is not available for a hearing, the following procedure will be followed: 

• The absent party must notify the Complaints Committee in writing of the reason for his/her absence as soon as possible, but no later than three working days before the scheduled hearing. 
• If the reason for the absence is found to be valid, the Complaints Committee will set a new date for the hearing. This new date will be within two weeks of the original date, unless there are valid reasons to deviate from it. 
• If a party fails to appear without a valid reason or fails to communicate the reason for absence in a timely manner, the Complaints Committee will base its decision on the available written documents and statements. 

7. If the above steps do not lead to a mutually acceptable solution, the complainant may appeal to an independent third party not employed by International Anti Crime Academy BV. IACA has appointed Chris van Gompel, a mediation expert, as its designated independent third party for this appeal. Mr. Van Gompel is completely independent and has no business or personal relationship with IACA, its directors, employees, or participants. Mr. Van Gompel will issue a reasoned, binding decision within a reasonable period of time. Any consequences arising from this decision will be handled by IACA as soon as possible.

Article 6 The decision of the Complaints Committee and the right of appeal

1. The Complaints Committee will reach its decision within four weeks of receiving the complaint. This decision will be in the form of a written recommendation. 

2. The Complaints Committee will also send a copy of its decision to the complainant. 

3. The term referred to in paragraph 1 may be extended by two periods of a maximum of four weeks. 

4. If an extension is necessary, the Complaints Committee will inform the complainant of this extension. 

5. The decision of the aforementioned independent third party (Article 5.7) is binding and any consequences will be dealt with as quickly as possible. 

Article 7 Commissioner's Response

1. The director will submit their written response no later than two weeks after receiving the Complaints Committee's decision. This response is binding on all parties, unless an appeal is possible. 

2. Within two weeks of receiving the Complaints Committee's decision, the director will send a copy of his or her response to the complainant and the teacher/trainer/educator/advisor involved. 

3. This period may be extended by a maximum of two weeks. This extension will also be communicated in writing to the complainant and the teacher/trainer/educator/advisor involved. 

4. In the event of an appeal, after receipt of the binding decision of the independent third party, the decision and the associated consequences will be sent in writing to both the complainant and the teacher/trainer/educator/advisor involved.