1. Introduction

This Privacy Policy explains how [Company Legal Name] ("we," "us," or "our"), a company based in

Portugal, collects, uses, shares, and protects your personal data when you visit our website or purchase

our digital products and services, including online courses and 1-1 coaching programs (the "Services").

We are committed to protecting your privacy in accordance with the General Data Protection Regulation

(GDPR) and other applicable laws. This policy applies to users worldwide, with particular attention to

customers in the United States and the United Kingdom.

2. Data Controller

The data controller responsible for your personal data is:

[Company Legal Name]

[Street Address]

[City, Postal Code]

Portugal

Email: [[email protected]]

3. Personal Data We Collect

We may collect the following categories of personal data:

• Identity and contact data: name, email address, phone number (if provided).

• Account data: username, password (encrypted), purchase history, course progress.

• Transaction data: payment information processed by our third-party payment providers (we do

not store full card details).

• Coaching-related data: information you share during 1-1 coaching sessions (notes, goals,

feedback).

• Technical data: IP address, browser type, device information, pages visited, and cookies.

• Communications: emails, support requests, and any messages you send us.

4. How We Use Your Personal Data

We use your personal data for the following purposes:

• To provide and deliver the Services (course access, coaching sessions).

• To process payments and manage orders.

• To communicate with you about your purchases, account, and customer support.

• To send marketing communications (only with your consent, where required).

• To improve our website and Services.

• To comply with legal obligations and prevent fraud.

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• To enforce our Terms and Conditions.

5. Legal Bases for Processing (GDPR)

We process your personal data on the following legal bases:

• Performance of a contract: to deliver the courses and coaching you purchase.

• Legitimate interests: to operate and improve our business, prevent fraud, and provide customer

support.

• Consent: for marketing emails and non-essential cookies.

• Legal obligation: to comply with tax, accounting, and other legal requirements.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the website, remember your preferences, and

analyze usage. Essential cookies are necessary for the site to function. Analytics and marketing cookies

are used only with your consent (where required).

You can manage cookie preferences through your browser settings or any cookie banner we provide on

the website.

7. Sharing Your Personal Data

We do not sell your personal data. We may share it with:

• Payment processors (e.g., Stripe, PayPal) to complete transactions.

• Email and marketing platforms (e.g., for course delivery and newsletters).

• Hosting and technical service providers.

• Professional advisers (lawyers, accountants) when necessary.

• Authorities when required by law.

8. International Data Transfers

As a company based in Portugal (EU), we may transfer personal data to service providers located outside

the EU/EEA (including the United States). Where we do so, we rely on appropriate safeguards such as

Standard Contractual Clauses or adequacy decisions to protect your data.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected,

including to satisfy legal, accounting, or reporting requirements. Course access data is typically retained

for the duration of your access rights plus a reasonable period thereafter. Coaching notes are retained

for the duration of the program and a limited time afterward, unless a longer period is required by law.

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10. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access the personal data we hold about you.

• Request correction of inaccurate data.

• Request erasure ("right to be forgotten") in certain circumstances.

• Request restriction of processing.

• Object to processing based on legitimate interests or for direct marketing.

• Data portability.

• Withdraw consent at any time (where processing is based on consent).

UK and EU residents have additional rights under GDPR/UK GDPR. US residents may have rights under

applicable state laws (e.g., CCPA/CPRA in California).

To exercise your rights, contact us at [[email protected]]. You also have the right to lodge a

complaint with a supervisory authority (in Portugal: Comissão Nacional de Proteção de Dados – CNPD).

11. Security

We implement appropriate technical and organizational measures to protect your personal data against

unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over

the internet is 100% secure.

12. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal

data from children. If we become aware that we have collected data from a child, we will take steps to

delete it.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top will be revised

when changes are made. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

[Company Legal Name]

[Street Address]

[City, Postal Code]

Portugal

Email: [[email protected]]

Website: [https://www.yourdomain.com]