Privacy Policy

PRIVACY POLICY

1. Who We Are

Freedom Code LLC is a Wyoming limited liability company that provides coaching, educational content, and personal development services. For the purposes of applicable data protection laws, Freedom Code LLC is the data controller responsible for your personal data.

Contact: legal@contactgavin.com

2. Information We Collect

2.1 Information You Provide

• Identity information: name, email address, phone number, billing address, country of residence
• Payment information: credit/debit card details, PayPal information (processed by third-party payment processors; we do not store full payment card details)
• Account information: username, password, communication preferences
• Coaching information: intake form responses, session notes, goals, progress updates, feedback, testimonials
• Biofeedback data: physiological and biometric data collected during coaching sessions (where applicable)
• Communications: emails, messages, chat transcripts, and other correspondence with us
• User-generated content: posts in community spaces, comments, reviews

2.2 Information Collected Automatically

• Device and browser information: IP address, browser type, operating system, device identifiers
• Usage data: pages visited, time spent, click patterns, referral sources, search queries
• Cookie and tracking data: see our Cookie Policy for full details
• Location data: approximate geographic location based on IP address

2.3 Information From Third Parties

• Payment processors (Stripe, PayPal) confirming transaction details
• Social media platforms if you interact with our content or connect accounts
• Advertising partners and analytics providers

3. How We Use Your Information

We use your personal data for the following purposes:

• To provide, deliver, and improve our Services
• To process payments and manage your account
• To communicate with you about your coaching programme, sessions, and progress
• To send marketing communications (with your consent where required by law)
• To personalise your experience and recommend relevant content or services
• To display testimonials and case studies (with your consent per our Testimonial and Media Release)
• To comply with legal obligations, resolve disputes, and enforce our agreements
• To protect our rights, property, and safety, and that of our users and third parties
• To conduct analytics and improve our website, marketing, and Services

4. Legal Basis for Processing (GDPR/UK GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data on the following legal bases:

• Contractual necessity: To perform the contract between us when you purchase or use our Services.
• Consent: Where you have given explicit consent, including for marketing communications, testimonial use, and processing of special category data (such as biofeedback/health-related information).
• Legitimate interests: For business administration, fraud prevention, website analytics, and improving our Services, where these interests are not overridden by your data protection rights.
• Legal obligation: Where we are required to process data to comply with applicable laws and regulations.

5. Special Category Data

Our Services may involve the collection and processing of data that qualifies as special category data under GDPR/UK GDPR, including health-related information, biofeedback data, and information about your mental or emotional wellbeing shared during coaching sessions. We process this data only with your explicit consent, which we obtain separately before any such processing begins. You may withdraw this consent at any time by contacting us at legal@contactgavin.com, although withdrawal will not affect the lawfulness of processing carried out before withdrawal.

6. Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties. We may share your data with:

• Service providers: Third-party companies that help us operate our business (payment processors, email marketing platforms, website hosting, analytics providers, video conferencing platforms). These providers are contractually obligated to protect your data.
• Professional advisors: Lawyers, accountants, and auditors as necessary for business operations.
• Legal requirements: When required by law, regulation, legal process, or governmental request.
• Business transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets.
• With your consent: For any other purpose with your explicit consent.

7. International Data Transfers

Freedom Code LLC is based in the United States. If you are located outside the United States, including in the EEA, UK, or Switzerland, your personal data will be transferred to and processed in the United States. We implement appropriate safeguards for international data transfers, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• The UK International Data Transfer Agreement or UK Addendum to EU SCCs where applicable
• Any other transfer mechanisms permitted by applicable data protection laws

By using our Services, you acknowledge that your data will be processed in the United States. For EEA/UK residents, transfers are protected by the safeguards described above.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Specific retention periods include:

• Account and coaching data: For the duration of your engagement plus 6 years (to comply with US tax and legal requirements)
• Payment records: 7 years (IRS requirements)
• Marketing consent records: For the duration of consent plus 3 years
• Website analytics data: 26 months
• Testimonial content: Indefinitely, unless revoked per the Testimonial and Media Release

9. Your Rights

9.1 All Users

Regardless of your location, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Opt out of marketing communications at any time
• Request deletion of your account and data (subject to legal retention requirements)

9.2 EEA, UK, and Swiss Residents (Additional Rights)

Under GDPR and UK GDPR, you additionally have the right to:

• Data portability: Receive your data in a structured, commonly used, machine-readable format
• Restriction: Request that we restrict the processing of your data in certain circumstances
• Objection: Object to processing based on legitimate interests or for direct marketing
• Withdraw consent: Withdraw consent at any time where processing is based on consent
• Lodge a complaint: File a complaint with your local supervisory authority (for UK residents, the Information Commissioner's Office at ico.org.uk)

9.3 California Residents (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act, including the right to know what personal information we collect, the right to delete, the right to opt out of sale or sharing of personal information, and the right to non-discrimination. Freedom Code LLC does not sell personal information as defined by the CCPA/CPRA.

To exercise any of these rights, contact us at legal@contactgavin.com. We will respond within the timeframes required by applicable law.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

11. Third-Party Links

Our website may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access.

12. Children's Privacy

Our Services are not directed to individuals under the age of 16 (or the minimum age of digital consent in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected data from a child without appropriate consent, we will take steps to delete that information.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a revised effective date. Your continued use of our website and Services after the updated policy becomes effective constitutes your acceptance of the changes.

14. Contact Us

Freedom Code LLC

Email: legal@contactgavin.com

Website: https://liberatingu.com