1. Privacy at a glance

General information

The following information gives you a simple overview of what happens to your personal data when you visit this website and use our membership offering. Personal data is any information that relates to you as an identified or identifiable person, for example your name, email address or IP address. Detailed information is set out in the sections below.

Who is responsible for data processing on this website?

Data processing on this website is carried out by MR Seraph Limited, Dublin, Ireland. You will find the full contact details in section 2 of this privacy policy and in our Legal Notice.

How do we collect your data?

Some of your data is collected because you provide it to us, for example when you fill in a form, register for a membership, place an order, book an appointment or open a support ticket. Other data is collected automatically by our IT systems when you visit the website. This is mainly technical data such as your IP address, browser, operating system or the time of your visit. Data for website analysis is collected only if you have given your consent.

What do we use your data for?

We use your data to provide the website securely and without errors, to answer your enquiries, to provide your membership, community access, courses and live sessions, to process orders and payments, to send you the emails you have requested and, with your consent, to understand how our website is used.

What rights do you have regarding your data?

You have the right to access your personal data, to have it corrected or erased, to restrict its processing, to data portability and to object to certain processing. Where processing is based on your consent, you can withdraw your consent at any time. You also have the right to lodge a complaint with a supervisory authority. Details are set out in section 3.

2. Controller and contact

The controller within the meaning of the General Data Protection Regulation (EU) 2016/679 (GDPR) for data processing on this website is:

MR Seraph Limited
St. Mary’s Chapel of Ease, St. Mary’s Place
Dublin 7, D07 P4AX
Republic of Ireland
Company Reg. No. 710591

Responsible for content: Melanie Rentmeister

Email: info [at] melrentmeister.com

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data. For all questions about data protection and for exercising your rights, please contact us at the email address above.

This privacy policy is based on the GDPR and the Irish Data Protection Acts 1988 to 2018, as well as the rules on cookies and electronic communications that apply in Ireland.

3. Your rights

Under the GDPR you have the following rights with regard to your personal data. To exercise them, simply contact us at the email address given in section 2. We may ask you to confirm your identity before we act on your request.

  • Right of access (Art. 15 GDPR): You can request confirmation as to whether we process personal data about you and, if so, receive information about this data, the purposes of processing, the recipients, the storage period and the origin of the data, as well as a copy of the data.
  • Right to rectification (Art. 16 GDPR): You can ask us to correct inaccurate data or to complete incomplete data.
  • Right to erasure (Art. 17 GDPR): You can ask us to erase your data, unless we are required to keep it, for example because of statutory retention obligations, or need it to establish, exercise or defend legal claims.
  • Right to restriction of processing (Art. 18 GDPR): You can ask us to restrict the processing of your data, for example while the accuracy of the data is being checked, if the processing is unlawful but you do not want the data erased, if we no longer need the data but you need it to establish, exercise or defend legal claims, or while it is being checked whether your objection under Art. 21 GDPR prevails.
  • Right to data portability (Art. 20 GDPR): You can request to receive data that we process by automated means on the basis of your consent or in order to perform a contract in a structured, commonly used and machine-readable format, or to have it transferred to another controller where this is technically feasible.
  • Right to withdraw consent (Art. 7(3) GDPR): Many processing operations are only carried out with your consent. You can withdraw your consent at any time with effect for the future. An informal message by email is sufficient. The withdrawal does not affect the lawfulness of the processing carried out before the withdrawal.
  • Automated decision-making (Art. 22 GDPR): We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

Right to object (Art. 21 GDPR)

IF WE PROCESS YOUR DATA ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. IF YOU OBJECT, WE WILL NO LONGER PROCESS THE DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (ART. 21(1) GDPR).

IF WE PROCESS YOUR DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (ART. 21(2) GDPR).

Right to lodge a complaint with a supervisory authority

If you believe that the processing of your personal data infringes data protection law, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). As our company is established in Ireland, our lead supervisory authority is:

Data Protection Commission
6 Pembroke Row
Dublin 2, D02 X963
Ireland
Website: www.dataprotection.ie

You can also lodge a complaint with the supervisory authority in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. We would, however, appreciate the chance to address your concerns first, so please feel free to contact us directly.

4. General information on data processing

Legal bases

We process personal data only where a legal basis under the GDPR applies. Depending on the purpose, we rely on the following legal bases, which we name for each processing operation below:

  • Consent (Art. 6(1)(a) GDPR): You have given us your consent to process your data for one or more specific purposes, for example for website analysis or for receiving our newsletter.
  • Contract (Art. 6(1)(b) GDPR): The processing is necessary to perform a contract with you, for example your membership, a course or a purchase, or to take steps at your request before entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR): The processing is necessary to comply with a legal obligation, for example statutory retention obligations under tax and company law.
  • Legitimate interests (Art. 6(1)(f) GDPR): The processing is necessary for the purposes of our legitimate interests or those of a third party, unless your interests or fundamental rights and freedoms override those interests, for example the secure and stable operation of our website.

Where we store information on your device or access information already stored on your device (for example by means of cookies), we do so only with your consent, unless this is strictly necessary to provide a service you have explicitly requested.

Recipients and processors

We only pass your personal data to third parties where this is necessary for the purposes described in this privacy policy, where you have consented, or where we are legally required to do so. Some service providers process data on our behalf as processors under a data processing agreement in accordance with Art. 28 GDPR, and are bound by our instructions. Other providers, such as payment providers, process certain data as independent controllers. Details are given in the relevant sections below.

Transfers to countries outside the EU/EEA

Some of the services we use are provided by companies based in the United States or other countries outside the European Union and the European Economic Area, or may involve the processing of data there. For transfers to the United States, the European Commission adopted an adequacy decision for the EU-U.S. Data Privacy Framework on 10 July 2023. Transfers to US companies that are certified under this framework are based on this adequacy decision (Art. 45 GDPR). Where a recipient is not certified, or for transfers to other third countries without an adequacy decision, we rely on the Standard Contractual Clauses adopted by the European Commission (Art. 46(2)(c) GDPR) or on another legal basis provided by the GDPR. You can check whether a US company is certified at www.dataprivacyframework.gov.

Storage period

Unless a more specific storage period is stated in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you make a justified request for erasure or withdraw your consent, your data will be erased unless we have another legal reason for storing it, for example statutory retention periods under tax or company law. Accounting records such as invoices and order data are generally kept for six years under Irish tax law. In such cases, the data is erased once these reasons no longer apply.

Are you obliged to provide your data?

You are not legally obliged to provide us with personal data. However, some data is required to conclude and perform a contract, for example to create a member account or to process an order. Without this data we cannot provide the service concerned. Mandatory fields in our forms are marked as such.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders, form submissions or enquiries that you send to us, this website uses SSL/TLS encryption. You can recognise an encrypted connection by the fact that the address line of your browser begins with “https://” and by the lock symbol in your browser bar. When encryption is active, the data you transmit to us cannot be read by third parties.

Please note that data transmission over the internet (for example when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.

Children

Our website and our offerings are not directed at children or young people under the age of 16. We do not knowingly collect personal data from persons under 16. If you believe that a child has provided us with personal data, please contact us so that we can delete it.

Objection to unsolicited advertising

We hereby object to the use of the contact details published in our Legal Notice for sending advertising and information material that we have not expressly requested. We expressly reserve the right to take legal action in the event of unsolicited advertising, for example by spam emails.

5. Hosting and technical provision of the website

Hosting by IONOS

This website is hosted on servers operated by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. All data collected on this website, including the data you enter in forms, your member account, community content and order data, is stored on these servers. IONOS processes this data on our behalf as a processor on the basis of a data processing agreement in accordance with Art. 28 GDPR. Further information can be found in the privacy policy of IONOS: https://www.ionos.ie/terms-gtc/privacy-policy/.

The use of IONOS is based on our legitimate interest in a secure, fast and efficient provision of our website (Art. 6(1)(f) GDPR) and, where you have a contract with us, on the performance of that contract (Art. 6(1)(b) GDPR).

Server log files

When you visit our website, the server automatically collects and stores information in so-called server log files, which your browser transmits to us automatically. These are:

  • browser type and browser version
  • operating system used
  • referrer URL (the page from which you came to our website)
  • host name of the accessing computer
  • date and time of the server request
  • IP address

This data is not merged with other data sources. It is processed in order to deliver the website to your device, to ensure the stability and security of our systems and to detect and defend against misuse. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the technically error-free and secure provision of our website. The log files are stored for a limited period only and then deleted, unless further storage is required in an individual case to investigate a security incident.

WordPress, Elementor and Blocksy

Our website is built with the content management system WordPress, the page builder Elementor and the theme Blocksy. These are installed on our own server; they do not themselves transmit your data to the developers of this software. Where individual elements load content from external servers (for example fonts or videos), this is described separately below.

Sending emails

Emails from this website, such as order confirmations, account notifications, replies to support tickets and newsletters, are sent via the email servers (SMTP) of IONOS SE, Germany. In doing so, your email address, your name where applicable and the content of the email are processed by IONOS on our behalf. The legal basis depends on the purpose of the email and is stated in the relevant sections below.

6. Cookies and consent management

Cookies

Our website uses cookies. Cookies are small text files that are stored on your device by your browser. They do not harm your device and do not contain viruses. Some cookies are “session cookies”, which are deleted automatically at the end of your visit. Other cookies remain on your device until you delete them or until they expire automatically; they enable us or third parties to recognise your browser on your next visit.

Cookies that are strictly necessary for the operation of the website or for providing functions you have requested, for example logging in to your member account, the shopping cart and checkout, or storing your cookie settings, are used on the basis of Art. 6(1)(f) GDPR and, where you have a contract with us, Art. 6(1)(b) GDPR. They do not require your consent. All other cookies and similar technologies, in particular those used for analysis, are only used if you have given your consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time with effect for the future.

You can also set your browser to inform you when cookies are set, to allow cookies only in individual cases, to refuse cookies for certain cases or in general, and to delete cookies automatically when you close the browser. If you disable cookies, the functionality of this website may be limited, for example you may not be able to log in or complete an order.

Cookie consent banner

When you first visit our website, a cookie banner asks for your consent to the use of non-essential cookies and similar technologies. We use the “Cookies Consent” extension of the Blocksy Companion plugin for this purpose. It runs on our own server. Your choice is stored in a cookie on your device so that the banner does not appear again on every page view and your decision can be respected. You can change or withdraw your decision at any time by deleting this cookie in your browser; the banner will then be shown again on your next visit.

The legal basis for storing your cookie choice is Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR (obligation to be able to demonstrate consent) and Art. 6(1)(f) GDPR (our legitimate interest in managing consents in a legally compliant way).

7. Analysis tools

Google Analytics 4

If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics is integrated via the Google Site Kit plugin. It allows us to analyse how visitors use our website, for example which pages are viewed, how long visitors stay, from which website they arrived and which device, browser and approximate location (country or region) they use. For this purpose, Google Analytics uses cookies and similar technologies that enable the recognition of your browser. Usage data may be combined into pseudonymous user profiles. Google Analytics 4 does not log or store full IP addresses of users in the EU.

The information collected is generally transmitted to and stored on Google servers, which may also be located in the United States. Google LLC, USA, is certified under the EU-U.S. Data Privacy Framework. In addition, Google relies on Standard Contractual Clauses where required. We use the analysis data only to improve our website and our offerings. Google Analytics is not loaded for logged-in members.

The legal basis for the use of Google Analytics is your consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time with effect for the future, for example by changing your cookie settings as described in section 6. You can also prevent the collection of data by Google by installing the browser add-on provided by Google: https://tools.google.com/dlpage/gaoptout. Further information can be found in Google’s privacy policy: https://policies.google.com/privacy.

Google PageSpeed Insights

Within Google Site Kit we also use the PageSpeed Insights module to check the loading speed of our pages. This test is carried out on request from our administration area and analyses our publicly available pages. No data about you as a visitor is collected or transmitted to Google for this purpose.

8. Fonts

Google Fonts

For a uniform presentation of fonts, this website uses so-called Google Fonts provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The fonts are currently loaded from Google’s servers when a page is called up. For this purpose, your browser connects to Google’s servers, and your IP address and technical information about your browser (such as the browser type and the page from which the fonts are requested) are transmitted to Google. It cannot be ruled out that data is also processed by Google LLC in the United States; Google LLC is certified under the EU-U.S. Data Privacy Framework.

The use of Google Fonts is based on our legitimate interest in a consistent and appealing presentation of our website (Art. 6(1)(f) GDPR). Where you have given consent to the loading of external content via our cookie banner, the processing is based solely on your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time. If your browser does not support Google Fonts or blocks them, a standard font from your device will be used. Further information can be found at https://developers.google.com/fonts/faq/privacy and in Google’s privacy policy: https://policies.google.com/privacy.

9. Forms, contact and bot protection

Forms on this website (Fluent Forms)

We use the form plugin Fluent Forms for our contact form, membership signup forms, application forms (for example for 1:1 mentoring) and forms for requesting free content (download or freebie forms). The data you enter, for example your name, email address and your message or answers, is stored together with the time of submission and your IP address in our database on our own server. It is not passed on to the developer of the plugin.

We process this data in order to handle your request, to answer your enquiry, to process your application or to provide the content you have requested. Where your request relates to the performance of a contract or is necessary to take steps prior to entering into a contract, the legal basis is Art. 6(1)(b) GDPR. In all other cases, the legal basis is our legitimate interest in effectively handling the enquiries addressed to us (Art. 6(1)(f) GDPR) or your consent (Art. 6(1)(a) GDPR), where we have requested this. Storing the IP address serves to prevent misuse and to document submissions (Art. 6(1)(f) GDPR).

The data you enter in a form will remain with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies (for example after your enquiry has been completely dealt with). Mandatory statutory provisions, in particular retention periods, remain unaffected. Where you use a form to sign up for our newsletter or for free content with an email series, section 10 also applies.

Enquiries by email

If you contact us by email, your enquiry including all personal data contained in it (name, email address, content of the enquiry) will be stored and processed by us for the purpose of handling your request. The legal basis is Art. 6(1)(b) GDPR if your enquiry relates to a contract or pre-contractual measures, and otherwise Art. 6(1)(f) GDPR, based on our legitimate interest in answering enquiries addressed to us. We do not pass this data on without your consent unless we are required to do so by law.

Cloudflare Turnstile

To protect our forms from spam and automated misuse (bots), we use Cloudflare Turnstile, a service of Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. Turnstile checks whether a form is being submitted by a human or by an automated program. For this purpose, technical signals from your browser are transmitted to Cloudflare, in particular your IP address, information about your browser and device (user agent, TLS fingerprint) and the identifier of our website. According to Cloudflare, this data is used only to detect bots and to improve the bot detection, and not for advertising purposes.

The legal basis is our legitimate interest in protecting our website and forms from misuse and spam (Art. 6(1)(f) GDPR). As Turnstile is strictly necessary to provide the form you are using securely, it does not require your consent. Cloudflare, Inc. is certified under the EU-U.S. Data Privacy Framework; in addition, Standard Contractual Clauses apply. Further information can be found in Cloudflare’s privacy policy, including the Turnstile Privacy Addendum: https://www.cloudflare.com/privacypolicy/ and https://www.cloudflare.com/turnstile-privacy-policy/.

10. Newsletter and email communication

Newsletter

If you would like to receive our newsletter, we need your email address and, where applicable, your first name so that we can address you personally. Further information is provided on a voluntary basis. You sign up via one of our forms by actively giving your consent, for example by ticking a checkbox or by submitting a signup form that clearly explains that you will receive our emails. We record the time of your signup and the form used in order to be able to demonstrate your consent.

We manage our contacts and send our newsletter and automated email series using FluentCRM. FluentCRM is installed on our own server; your data is stored there and is not transmitted to the developer of the software. The emails are sent via the email servers of IONOS SE, Germany (see section 5).

The legal basis for sending the newsletter is your consent (Art. 6(1)(a) GDPR).

You can withdraw your consent to receiving the newsletter at any time, free of charge, via the “Unsubscribe” link included in every email or by sending us a message. The lawfulness of the processing carried out before the withdrawal remains unaffected. After you unsubscribe, your email address is kept on an internal blocklist where this is necessary to make sure that you do not receive any further newsletters (Art. 6(1)(f) GDPR). Data that we store for other purposes, for example for your member account or for orders, is not affected by this.

Transactional emails

Independently of the newsletter, we send you emails that are necessary for the performance of our contract with you, for example confirmations of your registration and orders, password reset emails, information about your membership, notifications from the community area and replies to support requests. The legal basis is Art. 6(1)(b) GDPR. You can adjust the email notifications of the community area in your profile settings.

11. Member account, community and support

Registration and member account

You can register on our website for a free or paid membership. When you register, we process the data you provide, in particular your name, email address and password (stored in encrypted form only), as well as the time of registration and the membership level you have chosen. We use this data to set up and manage your member account, to give you access to the content and functions included in your membership, and to contact you about your membership. Logging in and remaining logged in requires technically necessary cookies.

The legal basis is the performance of the membership contract with you (Art. 6(1)(b) GDPR). We store your account data for as long as your member account exists. You can ask us to delete your account at any time. After deletion, data that we are legally obliged to keep, for example order and invoice data, remains stored for the statutory retention period.

Community area and courses (FluentCommunity)

Members have access to our community area and to our online courses, which we provide with FluentCommunity on our own server. Depending on your membership, the following data may be processed there: your profile information (for example name, user name, profile picture and any further information you choose to add), the spaces and courses you have access to, your course progress, and content you post or react to, as well as notification settings. Content you post in the community and your profile information can be seen by other members who have access to the same area.

The legal basis is the performance of the membership contract (Art. 6(1)(b) GDPR). Please only share personal information about yourself or others in the community if you are happy for other members to see it. You can edit or delete your own content and your profile information, or ask us to do so.

Support tickets (Fluent Support)

If you contact us via our support portal or by email to our support address, we use Fluent Support on our own server to manage your request as a support ticket. We process your name, email address, the content of your messages and any attachments, as well as the history of the ticket. Emails to our support address are retrieved from our mailbox at IONOS and assigned to the relevant ticket. Replies are sent to you by email.

The legal basis is Art. 6(1)(b) GDPR where your request relates to your membership, an order or pre-contractual measures, and otherwise our legitimate interest in answering your enquiry efficiently (Art. 6(1)(f) GDPR). Tickets are kept for as long as is necessary to deal with your request and to be able to understand the history of related requests, unless statutory retention obligations apply.

Appointment booking (Fluent Booking)

We may offer you the option of booking an appointment with us, for example for a call, via our website. For this purpose we use Fluent Booking on our own server. When you book an appointment, we process the data you enter (in particular your name, email address, the appointment you have chosen and any message you add) in order to schedule and carry out the appointment and to send you a confirmation and, where applicable, reminders by email. If the appointment takes place online, you will receive a meeting link (see section 14).

The legal basis is Art. 6(1)(b) GDPR, as the booking serves to perform a contract or to take steps at your request prior to entering into a contract. The data is deleted once it is no longer required for this purpose, unless statutory retention obligations apply.

Affiliate programme (Fluent Affiliate)

We may operate an affiliate programme in which partners can recommend our offerings and receive a commission for successful referrals. We manage the programme with Fluent Affiliate on our own server.

  • If you take part as an affiliate partner, we process your name, email address, the payment details you provide for paying out commissions, and the referrals, sales and commissions attributed to you. The legal basis is the performance of the affiliate agreement (Art. 6(1)(b) GDPR) and our statutory retention obligations (Art. 6(1)(c) GDPR).
  • If you visit our website via a partner’s referral link, a cookie is stored on your device and the referral is recorded so that a purchase can be attributed to the partner. The legal basis is our legitimate interest in the correct attribution and payment of commissions (Art. 6(1)(f) GDPR) or, where required, your consent (Art. 6(1)(a) GDPR).

12. Shop, orders and payment

Orders (FluentCart)

Our shop, through which you can purchase memberships, courses and other offerings, runs on FluentCart on our own server. Prices are shown in US dollars. When you place an order, we process the data required to conclude and perform the contract, in particular your name, email address, billing address, the products ordered, the order amount and the status of your payment and, for subscriptions, the subscription status and renewal dates. We do not store your full card or bank details; these are entered directly with the payment provider.

The legal basis is the performance of the contract (Art. 6(1)(b) GDPR) and, for invoice and accounting records, our legal obligations under Irish tax and company law (Art. 6(1)(c) GDPR). Accounting records are generally kept for six years. In your customer account you can view your orders, subscriptions and invoices.

Stripe

For card payments and other payment methods offered by Stripe, we use the payment provider Stripe. The provider for customers in the European Economic Area is Stripe Payments Europe, Limited, Dublin, Ireland. When you choose to pay via Stripe, the payment data you enter (for example card details), your name, email address, billing address, the order amount and technical data such as your IP address are transmitted to Stripe. Stripe uses this data to process the payment and to prevent fraud, and is in part an independent controller for this processing. Data may also be processed by Stripe companies in the United States. Stripe, LLC complies with the EU-U.S. Data Privacy Framework; in addition, Stripe relies on Standard Contractual Clauses for such transfers.

The legal basis is the performance of the contract (Art. 6(1)(b) GDPR) and our legitimate interest in offering secure and efficient payment methods (Art. 6(1)(f) GDPR). Further information can be found in Stripe’s privacy policy: https://stripe.com/privacy.

PayPal

We also offer payment via PayPal. The provider for customers in the European Union is PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. When you choose to pay via PayPal, you are redirected to PayPal or a PayPal window opens, and the data required for payment, in particular your name, email address, billing address, the order amount and the order details, is transmitted to PayPal. PayPal processes this data as an independent controller, including for fraud prevention and, where applicable, for credit checks in accordance with its own privacy policy. For subscriptions, PayPal informs us about the status of the recurring payments.

The legal basis is the performance of the contract (Art. 6(1)(b) GDPR) and our legitimate interest in offering secure and efficient payment methods (Art. 6(1)(f) GDPR). Further information can be found in PayPal’s privacy statement: https://www.paypal.com/ie/legalhub/paypal/privacy-full.

13. Videos

Vimeo

We embed videos from the video platform Vimeo on our website, in particular in our courses and the community area. The provider is Vimeo.com, Inc., 330 West 34th Street, 10th Floor, New York, NY 10001, USA. The videos are played via the FluentPlayer video player integrated into our website.

When you open a page containing a Vimeo video, a connection to Vimeo’s servers is established. Vimeo receives technical data, in particular your IP address, information about your browser and device and the page you have visited. When you play a video, Vimeo also processes information about the playback. If you are logged in to your Vimeo account at the same time, Vimeo may be able to associate this information with your account. Vimeo is certified under the EU-U.S. Data Privacy Framework and also relies on Standard Contractual Clauses.

We use Vimeo in the interest of an appealing presentation of our online offerings and to provide the video content of our courses and membership (Art. 6(1)(f) GDPR and, for members, Art. 6(1)(b) GDPR). Where we have requested your consent for loading external content, the processing is based solely on your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time. Further information can be found in Vimeo’s privacy policy: https://vimeo.com/privacy.

YouTube

Some pages of our website may contain embedded videos from YouTube. The provider for users in the European Economic Area is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

When you open a page with an embedded YouTube video, a connection to YouTube’s servers is established, and YouTube is informed which of our pages you have visited. In doing so, your IP address and technical information about your browser and device are transmitted. YouTube may store cookies or similar technologies on your device. If you are logged in to your YouTube or Google account, YouTube can associate your browsing behaviour directly with your personal profile; you can prevent this by logging out of your account beforehand. Data may also be processed by Google LLC in the United States; Google LLC is certified under the EU-U.S. Data Privacy Framework.

We use YouTube in the interest of an appealing presentation of our online offerings (Art. 6(1)(f) GDPR). Where we have requested your consent for loading external content, the processing is based solely on your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time. Further information can be found in Google’s privacy policy: https://policies.google.com/privacy.

14. Live sessions and messenger group

Zoom

We hold live sessions, group calls and individual online appointments using the video conferencing service Zoom. The provider is Zoom Communications, Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA. You take part by clicking on a meeting link that we provide to you, for example in the member area or by email. You do not need to create a Zoom account to take part.

When you use Zoom, Zoom processes the data required to carry out the session, in particular the name you enter, your email address if you provide it, your IP address, device and connection information, and, depending on your settings, audio and video data and chat messages. You decide yourself whether to switch on your camera and microphone and which name to display. If a session is recorded, we will inform you about this in advance, for example at the beginning of the session; recordings may be made available to members in the member area. Zoom is certified under the EU-U.S. Data Privacy Framework.

The legal basis is the performance of the contract with you (Art. 6(1)(b) GDPR) where the session is part of your membership or a booked service, and otherwise our legitimate interest in carrying out online sessions efficiently (Art. 6(1)(f) GDPR). Further information can be found in Zoom’s privacy statement: https://www.zoom.com/en/trust/privacy/privacy-statement/.

Telegram group

For some of our offerings we provide an optional group on the messenger service Telegram. We only publish an invitation link; joining is voluntary and is not required to use our membership. If you join the group, you use Telegram under Telegram’s own terms. Telegram Messenger Inc. is the controller for the data processed by Telegram. Members of the group may be able to see your Telegram name, profile picture and the messages you post, and, depending on your Telegram privacy settings, your phone number. Telegram may process data outside the European Union.

We process your data in the group (in particular your Telegram name and your messages) on the basis of our legitimate interest in offering an additional exchange among participants (Art. 6(1)(f) GDPR). Further information can be found in Telegram’s privacy policy: https://telegram.org/privacy.

15. Changes to this privacy policy

We may update this privacy policy from time to time to reflect changes to our website, our offerings or the legal requirements. The version published on this page at the time of your visit applies. If changes affect processing based on your consent, we will ask for your consent again where required.

Last updated: October 2026