Privacy Policy

Effective date: [DD Month YYYY]  |  Last updated: [DD Month YYYY]

1. Who we are

This Privacy Policy explains how [CREATOR / LEGAL BUSINESS NAME], trading as [TRADING NAME], of [BUSINESS ADDRESS], email [PRIVACY CONTACT EMAIL] (“we”, “us” or “our”), collects and uses personal data when you visit [WEBSITE URL], submit a form, create an account, purchase or access a product/service, or contact us. Where applicable, [CREATOR / LEGAL BUSINESS NAME] acts as the data controller for the processing described here. [DESCRIBE KANDA EM’S ROLE, IF RELEVANT, AND ANY DIFFERENT OR JOINT-CONTROLLER ARRANGEMENT AFTER LEGAL REVIEW.]

2. Personal data we collect

Depending on your interactions with us, we may collect:

• Identity and contact details, such as name, email address, phone number and details submitted through forms.
• Account and course data, such as account identifiers, course progress, access records and support requests.
• Order and transaction data, such as items purchased, order amount, currency, payment status, refunds and purchase history. Payments are processed by [PAYMENT PROVIDER(S)]. We do not directly collect or store full card details unless this is specifically true and verified.
• Communications and preferences, including messages, survey responses, newsletter preferences and marketing consent/withdrawal records where applicable.
• Technical and usage data, such as IP address, device/browser information, timestamps, pages viewed and interactions, where collected by the website or configured tools.
• Cookie and similar-technology data, as described in Section 6.

[Remove or add categories only after checking Kajabi settings, checkout and connected tools.]

3. How we collect data

We collect information directly when you submit a form, make a purchase, create/use an account, subscribe to communications or contact us. Some information may be generated automatically or received through Kajabi, payment providers, email platforms, analytics, cookies or other tools listed in [VENDOR / TOOL LIST].

4. Purposes and legal bases

Processing orders and providing products or services

We process contact, account, order and transaction data to process purchases and provide the products or services you request. The legal basis is generally the performance of a contract or taking steps at your request before entering into a contract. Legal obligations may also apply.

Managing accounts, course access and customer support

We process account information, course activity and communications to manage your account, provide access to purchased content and respond to support requests. The legal basis may be the performance of a contract or our legitimate interests, where applicable.

Sending service-related and transactional messages

We use contact, account and order information to send purchase confirmations, access instructions, important service updates and other necessary communications. The legal basis may be the performance of a contract or compliance with a legal obligation, depending on the communication.

Sending marketing communications

We may use your contact details, communication preferences and consent records to send promotional emails or other marketing communications where permitted by applicable law. The legal basis may be your consent or another lawful basis where expressly permitted.

Securing and improving the website

We may process technical, usage and account data to maintain website security, troubleshoot technical issues and improve our services. The legal basis may be our legitimate interests or another applicable legal basis.

Meeting tax, accounting and other legal obligations

We may process order, invoice and transaction records to comply with applicable tax, accounting and other legal requirements. The legal basis is compliance with a legal obligation where applicable.

Using analytics, cookies and advertising technologies

We may process cookie identifiers, device information and usage data to understand website traffic, measure performance and support advertising. We obtain consent where required by applicable law and rely on another appropriate legal basis only where permitted.

The legal bases described above must be reviewed and confirmed for the specific activities, tools and jurisdictions applicable to this business.

5. Marketing communications

Service messages needed to fulfil an order, provide access or manage an account are distinct from promotional messages. We send marketing emails, SMS or other promotional communications only where we have a lawful basis and obtain consent where required. Where an opt-in is required, it will be clear and not pre-selected. You can unsubscribe using the link in a marketing email or contact [MARKETING / PRIVACY EMAIL]. For SMS/telephone marketing, follow the opt-out instructions provided or contact us. Withdrawal does not affect processing carried out lawfully before withdrawal.

6. Cookies and similar technologies

Our website may use cookies, pixels, local storage, analytics and embedded third-party content to operate the site, remember preferences, measure traffic or support advertising. The actual tools, purposes, providers, categories and retention periods must be listed in [COOKIE TABLE / CONSENT TOOL LINK] after auditing the live site. Where consent is required, non-essential cookies or similar technologies must not activate before valid consent. Users should be able to change or withdraw preferences through [COOKIE SETTINGS LINK / BANNER].

7. Who receives data

We may share data with service providers that help operate the business, including [KAJABI], [PAYMENT PROVIDER], [EMAIL MARKETING PROVIDER], [ANALYTICS / ADVERTISING PROVIDERS], [CRM / SUPPORT TOOLS], and professional advisers or authorities where necessary. Replace these placeholders with the actual providers. Confirm whether each provider processes data on our behalf or for its own purposes and link to relevant notices where appropriate.

8. International transfers

Data may be processed in countries other than your own depending on the providers used. Where applicable law requires safeguards for international transfers, we use an appropriate mechanism, such as an adequacy decision or contractual safeguards. Contact [PRIVACY CONTACT EMAIL] for further information. [Legal reviewer: identify actual provider locations and transfer mechanisms; do not publish generic text without verification.]

9. Data retention

Order, invoice and tax records

We retain order, invoice and tax records for the period required by applicable tax, accounting and other laws. The applicable retention period depends on the relevant jurisdiction.

Account and course access data

We retain account information, course access records and related data for as long as necessary to provide our services, manage access, resolve issues and meet applicable legal obligations.

Marketing preferences and consent records

We retain marketing preferences, consent records and unsubscribe information for as long as necessary to manage communication preferences, demonstrate compliance and respect your choices.

Customer support communications

We retain support messages and related correspondence for as long as necessary to respond to requests, resolve disputes and maintain appropriate business records.

Analytics and cookie data

We retain analytics and cookie-related data according to the retention periods configured in the relevant tools and the requirements of applicable law.

When personal data are no longer needed, we will delete them or anonymise them where appropriate, subject to any legal obligation to retain them for longer.

The actual retention periods must be verified against the business's practices, connected tools and applicable legal requirements.

10. Your rights

Depending on applicable law, you may have rights to access, correct or delete personal data; restrict or object to processing; receive a portable copy; withdraw consent; or complain to a data-protection supervisory authority. Rights may be subject to conditions and exceptions. Contact [PRIVACY CONTACT EMAIL]; we may need to verify your identity. If GDPR applies, you may complain to the supervisory authority in the country where you live, work or where an alleged infringement occurred. Add the relevant authority/contact route if required: [AUTHORITY / LINK].

11. Children and minors

Our products and services are intended for [TARGET AUDIENCE]. [State whether the site is directed to children or accepts minors, the applicable age rules, and how parent/guardian consent is handled if relevant. Confirm the applicable law before publication.]

12. Security and third-party links

We use reasonable technical and organisational measures appropriate to the data and our activities, but no transmission or storage method is completely secure. Our website may link to third-party websites or embed third-party content; their own privacy notices apply. Review embeds for cookie/consent implications.

13. Changes to this Policy

We may update this Policy to reflect changes to our practices, tools or legal requirements. We will update the “Last updated” date and provide additional notice where required. Changes take effect as stated in the notice, subject to applicable law.

14. Contact

[CREATOR / LEGAL BUSINESS NAME]
[BUSINESS / REGISTERED ADDRESS]
[PRIVACY CONTACT EMAIL]
[OTHER REQUIRED CONTACT DETAILS]