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.