Privacy Policy

PRIVACY POLICY — EMPOWERED COACH ACADEMY
Effective Date:28/JAN/2026

This Privacy Policy explains how Fieldstone Ventures OÜ (trading as “Empowered Coach” and “Empowered Coach Academy”) (“Company,” “we,” “us,” “our”) collects, uses, shares, and protects personal data when you visit our websites, purchase the Empowered Coach Academy, or use any related services, portals, communities, calls, recordings, and resources (collectively, the “Services”).

1) DATA CONTROLLER / WHO WE ARE
Fieldstone Ventures OÜ (Estonia) is the data controller for personal data processed under this Policy.
Registered address: Tornimäe tn 5, 10145 Tallinn, Harju maakond, Estonia
Owner / Management board member: Matthew Stephen George Cullen (also known as “Lotus”)
Contact (privacy & support): contact@limitlessmindhypnosis.com

2) WHAT DATA WE COLLECT
We may collect the following categories of personal data:

A. Information you provide
- Identity and contact data: name, email address, phone number, billing address (if provided)
- Account data: login credentials (or platform account identifier), profile information, preferences
- Purchase data: products purchased, payment plan selection, invoices/receipts (note: payment card details are handled by our payment processors)
- Communications: emails, messages, support requests, survey responses, and any information you choose to share

B. Information collected from your use of the Services
- Usage data: pages viewed, videos watched, progress, timestamps, clicks, device and browser details
- Technical data: IP address, device identifiers, approximate location (derived from IP), log files, cookies and similar technologies

C. Community and live-session data
- Content you post in community spaces (posts, comments, files you upload)
- Live call participation (display name, audio/video if you enable it, chat messages)
- Recordings: we may record live sessions and store recordings for Program delivery and quality purposes

D. Information from third parties
- Payment processors: payment status, transaction identifiers, billing confirmations
- Email/SMS providers: delivery and engagement signals (opens, clicks)
- Analytics and advertising partners (where enabled): attribution and performance data

3) HOW WE USE YOUR DATA (PURPOSES)
We use your personal data to:
- Provide and administer the Services (create access, deliver content, run calls and community)
- Process payments, prevent fraud, and maintain accurate records
- Communicate with you about your purchase, access, updates, support, and operational notices
- Improve and secure the Services (debugging, analytics, service quality, platform safety)
- Comply with legal obligations (accounting, tax, regulatory requests)
- Send marketing communications, where permitted by law (you can opt out at any time)

4) LEGAL BASES (GDPR / UK GDPR)
Where GDPR/UK GDPR applies, we rely on the following legal bases:
- Contract: to provide the Services you purchased
- Legitimate interests: to operate, secure, and improve the Services, prevent fraud, and communicate about the Services
- Consent: where required (e.g., certain marketing, certain cookies/trackers)
- Legal obligation: to retain records and comply with applicable laws

5) MARKETING COMMUNICATIONS
You may receive marketing emails from us where permitted by law. You can opt out at any time by using the “unsubscribe” link in our emails or contacting contact@limitlessmindhypnosis.com.
Operational emails (e.g., access, billing, important service notices) may still be sent because they are necessary to provide the Services.

6) COOKIES AND SIMILAR TECHNOLOGIES
We use cookies and similar technologies to operate the site, remember preferences, enable core functionality, and understand site performance. Depending on your location, you may see a cookie banner or preference tool.
You can also manage cookies in your browser settings.

7) HOW WE SHARE YOUR DATA
We do not sell your personal data.

We may share personal data with:
- Service providers (processors) who help us deliver the Services (payment processing, email delivery, video hosting, community platforms, analytics, scheduling, conferencing tools, customer support tools)
- Professional advisors (e.g., accounting, legal) as necessary
- Authorities if required by law or to protect rights, safety, and security
- A buyer or successor in connection with a merger, acquisition, or sale of assets (with appropriate safeguards)

8) INTERNATIONAL DATA TRANSFERS
Because we use global service providers, your personal data may be processed outside your country, including in the United States or other jurisdictions. Where required, we use appropriate safeguards such as Standard Contractual Clauses or other lawful transfer mechanisms.

9) DATA RETENTION
We keep personal data only as long as necessary for the purposes described above, including:
- Account and Program access data: typically for the duration of your access term (12 months) and a reasonable period afterward for support, dispute resolution, and system integrity
- Financial and transactional records: as required by applicable accounting and tax laws
- Community content and call recordings: retained as needed for Program delivery and quality, then deleted or anonymized when no longer necessary (or sooner where feasible upon valid request)

10) SECURITY
We use reasonable administrative, technical, and organizational measures to protect personal data. No method of transmission or storage is 100% secure; you use the Services at your own risk.

11) YOUR RIGHTS (GDPR/UK GDPR)
Depending on your location, you may have rights including:
- Access to your personal data
- Correction of inaccurate data
- Deletion (erasure) in certain circumstances
- Restriction of processing in certain circumstances
- Data portability
- Objection to processing based on legitimate interests
- Withdrawal of consent (where processing is based on consent)

To exercise your rights, email contact@limitlessmindhypnosis.com. We may need to verify your identity before fulfilling a request.

You also have the right to lodge a complaint with your local supervisory authority. In Estonia, this is the Estonian Data Protection Inspectorate.

12) US STATE PRIVACY DISCLOSURES (IF APPLICABLE)
Depending on your US state of residence (e.g., CA/CO/CT/UT/VA), you may have rights to access, delete, or correct certain personal information, and to opt out of certain processing.
We do not sell personal information as defined by these laws. To make a request, email contact@limitlessmindhypnosis.com.

13) CHILDREN’S PRIVACY
The Services are not intended for children under 18. We do not knowingly collect personal data from children.

14) CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. The latest version will be posted on our website with a new effective date.

15) CONTACT
For privacy questions or requests:
contact@limitlessmindhypnosis.com