Reconnect & Thrive™

Privacy Policy

Clarity Booster™

Last updated: September 2026

We take the trust you place in us seriously. This policy explains how we handle your personal data when you visit reconnectandthrive.com, enrol in the Clarity Booster™, answer the intake questions and join the sessions.

1. Who we are

The controller of your data is ELEVARE LEGACY Oü (registry code 17209738), Veskiposti tn 2-1002, Kesklinna linnaosa, 10138 Tallinn, Estonia. For any privacy question, email [email protected].

2. What we collect, why, and for how long

Data Why we use it Lawful basis (GDPR) How long we keep it
Name, email, phone, billing address, country To process your enrolment and payment, and to send your confirmation, joining links and reminders Contract (Art. 6(1)(b)) 3 years after the programme ends
Payment and invoice records (card details are handled by Stripe only; we never see them) Invoicing and accounting Legal obligation (Art. 6(1)(c)) 7 years, as required by the Estonian Accounting Act
Intake answers, onboarding and session notes To tailor and deliver your coaching Contract (Art. 6(1)(b)) 12 months after your programme ends
Anything sensitive you choose to share (for example about your health) Only to deliver your coaching Explicit consent (Art. 9(2)(a)), which you can withdraw at any time 12 months after your programme ends
What you say or show in live sessions To run the group sessions Contract (Art. 6(1)(b)) Not kept beyond the recording below
Session recordings (video, audio, chat) For Gwen's private use, to prepare each participant's written summary Contract and legitimate interests (Art. 6(1)(b), (f)); explicit consent (Art. 9(2)(a)) for any sensitive information shared Deleted 30 days after the cohort ends
Checkout consents, withdrawal and refund requests, correspondence To keep a record of what was agreed and to handle questions or claims Legal obligation and legitimate interests (Art. 6(1)(c), (f)) 3 years after the programme ends
Email address for news and offers To send occasional updates about similar programmes. You can unsubscribe in every email Legitimate interests for customers; consent for everyone else (Art. 6(1)(f), (a)) Until you unsubscribe
IP address, device and browser data, essential cookies To keep the website, forms and checkout secure and working Legitimate interests (Art. 6(1)(f)) Up to 13 months

Please share only what feels right to you. Coaching is not therapy, and we don't ask for health information. We do not sell your data, and we never make decisions about you by automated means alone.

Session recordings: the live sessions are recorded. Because participants share sensitive personal information, the recordings are for Gwen's private use only. They are never shared with participants or anyone else, are stored securely and are deleted 30 days after the cohort ends. Each participant receives a written summary instead. You can keep your camera off or use a first name only if you prefer, and you can ask us about any recording that includes you.

Group sessions: other participants will see and hear what you share in the live sessions. Everyone agrees to keep it confidential, and participants are not allowed to record sessions.

3. Who helps us

We use trusted providers who process data on our behalf under data processing agreements:

Provider Role Location and safeguard
HighLevel Inc. (GoHighLevel) Website, forms, customer records, automated emails USA: EU-U.S. Data Privacy Framework (DPF) and Standard Contractual Clauses (SCCs)
Stripe Payments, refunds, fraud prevention (independent controller for some purposes) EU and USA: DPF and SCCs
Zoom Video Communications, Inc. Onboarding call, live sessions and session recordings USA: DPF and SCCs
Cloudflare Spam and bot protection on forms USA: DPF and SCCs
bunny.net, Google Fonts Website fonts EU / USA: DPF and SCCs
Our accountant Bookkeeping and tax compliance Estonia

Where data leaves the European Economic Area, it is protected by the EU-U.S. Data Privacy Framework or by the European Commission's Standard Contractual Clauses. We may also share data with authorities or professional advisers where the law requires.

4. Your rights

You have the right to access, correct or delete your data, to restrict or object to its use, to receive it in a portable format, and to withdraw consent at any time. Email us and we'll respond within one month, free of charge.

You may also complain to a data protection authority in your country, or to ours: the Estonian Data Protection Inspectorate (AKI), Tatari 39, 10134 Tallinn · [email protected] · www.aki.ee.

5. Security and changes

We use secure, reputable systems and limit access to those who need it. The programme is for adults only. If we update this policy, the date above will change, and we'll tell you by email if the change affects you significantly.

Reconnect & Thrive™

ELEVARE LEGACY Oü · Registry code 17209738 · Veskiposti tn 2-1002, 10138 Tallinn, Estonia

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