Privacy Policy

Effective date: [date of publication] · Version 1.0

1. Who We Are

This Privacy Policy applies to the Deliberate Life™ programme and the website deliberate-life.com.

The data controller responsible for your personal data is: Vidya Culture & Coaching AB, org.nr 556816-9337. Email: hello@deliberate-life.com. Website: deliberate-life.com.

Deliberate Life™ is co-created and co-delivered with Red Bear Consulting Ltd (UK). Where Red Bear Consulting Ltd processes personal data in connection with programme delivery, it does so as a joint data controller. Any data sharing between the two entities is governed by a data sharing agreement.

For privacy-related enquiries, contact us at: hello@deliberate-life.com

2. What Data We Collect

2.1 Data you provide directly

Name and email address (waitlist sign-up, enrolment, or contact form)
Payment information (processed by Teachable and Stripe — we do not store card details)
Your responses in the interactive workbook and self-assessment tool
Communications you send to us by email or through the platform
Content you share during live Zoom sessions

2.2 Data collected automatically

Usage data and course progress tracked by the Teachable platform (lessons viewed, completion status)
Device and browser information and session data collected by the Teachable platform’s essential cookies
Zoom session metadata (attendance, duration) where live sessions are recorded

2.3 Data we do not collect

We do not collect special category data (such as health, political opinions, or biometric data) as part of the standard programme. If you choose to share sensitive personal information in your workbook responses or during live sessions, you do so voluntarily. We treat such information with strict confidentiality.

3. How and Why We Use Your Data

We process your personal data on the following legal bases under GDPR:

3.1 Performance of a contract (Article 6(1)(b))

We use your data to deliver the programme you have enrolled in, including:

Providing access to programme content on Teachable
Delivering and administering live Zoom sessions
Sending programme-related communications (session reminders, access details, updates)

3.2 Legitimate interests (Article 6(1)(f))

We process data where we have a legitimate interest that is not overridden by your rights, including:

Improving programme content and delivery based on aggregated usage data
Maintaining the security of our platform and services
Managing our relationship with you after the programme ends

3.3 Consent (Article 6(1)(a))

Where we send you marketing communications (such as information about future cohorts, events, or related programmes), we do so only with your consent. You may withdraw consent at any time by emailing hello@deliberate-life.com or using the unsubscribe link in any marketing email.

4. Third-Party Processors

We share your data with the following third-party service providers who process data on our behalf. All processors are required to handle your data in accordance with GDPR.

Teachable (Hotmart Company)

Platform hosting, course delivery, enrolment management, and payment processing. Teachable acts as a data processor for platform data and, where it is a deemed VAT supplier, processes transaction data in its own right. Teachable is based in the United States; data transfers are covered by Standard Contractual Clauses. Teachable Privacy Policy: https://teachable.com/privacy-policy

Stripe

Underlying payment infrastructure used by Teachable Pay. Stripe processes card transaction data. We do not receive or store raw card details. Stripe is based in the United States; data transfers are covered by Standard Contractual Clauses. Stripe Privacy Policy: https://stripe.com/privacy

Zoom Video Communications

Live group sessions are delivered via Zoom. When you attend a session, Zoom collects data including your name, email, device information, and session activity. If sessions are recorded, recordings are stored on Zoom’s servers. Zoom is based in the United States; data transfers are covered by Standard Contractual Clauses. Zoom Privacy Policy: https://zoom.us/privacy

Red Bear Consulting Ltd

As co-facilitator of the Deliberate Life™ programme, Red Bear Consulting Ltd (UK) has access to participant names and email addresses for the purpose of delivering live sessions and programme support. Red Bear Consulting Ltd is subject to UK GDPR.

5. Cookies

Our website and the Teachable platform use cookies — small text files stored on your device — to enable core functionality and remember your preferences.

Essential cookies: required for the site and the Teachable platform to function. These cannot be disabled.

We do not currently use analytics or marketing cookies. If this changes, we will update this policy and add a cookie consent banner before any non-essential cookies are set.

You can manage cookies through your browser settings. Restricting essential cookies may affect your ability to access the programme.

6. Data Retention

We retain your personal data for as long as necessary for the purposes set out in this policy:

Programme access data: for the duration of your access period (12 months) plus a further 12 months, after which it is deleted or anonymised.
Marketing consent records: until you withdraw consent, plus a reasonable period thereafter for record-keeping.
Workbook content: retained for the duration of your access period. You may request deletion at any time.
Zoom recordings: retained for 12 months and then deleted. Enrolled participants are notified when recordings are available.

7. International Data Transfers

Some of our third-party processors (Teachable, Stripe, and Zoom) are based in the United States. Transfers of your personal data to these providers are made under the EU Standard Contractual Clauses (SCCs) adopted by the European Commission, which provide an appropriate level of protection for your data.

If you have questions about the safeguards in place for international transfers, contact us at hello@deliberate-life.com.

8. Your Rights Under GDPR

As a data subject under EU GDPR, you have the following rights:

Right of access: to receive a copy of the personal data we hold about you.
Right to rectification: to have inaccurate data corrected.
Right to erasure: to request deletion of your data, subject to legal retention obligations.
Right to restriction: to ask us to limit how we use your data in certain circumstances.
Right to data portability: to receive your data in a structured, machine-readable format.
Right to object: to object to processing based on legitimate interests or for direct marketing.
Right to withdraw consent: where processing is based on consent, to withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at hello@deliberate-life.com. We will respond within 30 days. We may ask you to verify your identity before fulfilling a request.

If you are not satisfied with our response, you have the right to lodge a complaint with the Swedish supervisory authority: Integritetsskyddsmyndigheten (IMY), Box 8114, 104 20 Stockholm. www.imy.se, imy@imy.se

9. Children

The Deliberate Life™ programme is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at hello@deliberate-life.com.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, tools, or legal obligations. We will notify enrolled participants of material changes by email. The current version is always available at deliberate-life.com/privacy. The date at the top of this document indicates when it was last updated.

11. Contact

For any questions about this Privacy Policy or how we handle your data: Vidya Culture & Coaching AB. Email: hello@deliberate-life.com. Website: deliberate-life.com.