Privacy Policy — Mind Artists LTD
1. Who we are
Mind Artists LTD (“Mind Artists”, “we”, “us”, “our”) is the data controller responsible for the personal data described in this policy.
- Legal entity: Mind Artists LTD
- Company number: [COMPANY NUMBER]
- Privacy contact: [email protected]
- General contact: [email protected]
If you have any question about this policy or about how we handle your information, write to us at the privacy contact above.
2. What this policy covers
This policy applies to all Mind Artists LTD digital properties and services, including:
- themindartists.com and all of its programme pages
- lp.themindartists.com and any other landing, opt-in, booking or checkout page we operate
- the Mind Artists Journey application and any associated tools or dashboards
- our email, SMS and messaging communications
- coaching calls, workshops, webinars and community spaces we run
- Mind Artists Tech services and tutorials
Where a separate notice is provided for a specific programme or tool, that notice applies in addition to this one. Where they conflict, the specific notice governs for that programme only.
3. Information we collect
3.1 Information you give us
- Identity and contact data — name, email address, phone number, postal or billing address, country, time zone.
- Account data — username, password (stored hashed, never in readable form), profile details, preferences.
- Programme and coaching data — application and intake form answers, goals, progress notes, milestones, submissions, and anything you share with a coach or in a group setting.
- Transaction data — the programme or product purchased, price, currency, invoice records, payment status, refund and chargeback records. We do not store full card numbers; card payments are processed by our payment providers.
- Communications — emails, chat and WhatsApp messages, support tickets, survey and feedback responses.
- Call recordings — where a coaching call, workshop or webinar is recorded, the audio, video, chat transcript and any screen content you share. We tell you before recording starts and you may decline to appear on camera.
- Business data you connect — if you link an advertising account to our tools, the campaign, ad set, ad, spend, lead and performance data from that account, and the access tokens needed to read it.
3.2 Information collected automatically
- Device and usage data — IP address, browser type and version, operating system, device identifiers, referring URL, pages viewed, time on page, clicks, scroll depth, and approximate location derived from IP.
- Cookies and similar technologies — see section 7.
- Email engagement — whether an email was delivered, opened, or clicked, and which links were clicked.
3.3 Information from third parties
- Advertising and social platforms — aggregated campaign and audience data from Meta and similar platforms, and lead form submissions passed to us when you respond to one of our ads.
- Payment providers — confirmation of payment, partial card details (last four digits, card type), and fraud or chargeback signals.
- Publicly available sources — business information you have made public, where relevant to a B2B enquiry.
- Referrals — where an existing client or partner refers you and provides your contact details, having confirmed they have your permission to do so.
3.4 Special category data
We do not ask for health, religious, political, biometric or similar special category data. Coaching conversations may occasionally touch on sensitive topics; anything you choose to disclose is treated as confidential and is not used for marketing, profiling or any purpose beyond delivering the coaching you asked for. Please do not submit special category data through forms, chat or file uploads.
4. How we use your information, and our legal basis
| Purpose | Legal basis (UK/EU GDPR) |
|---|---|
| Delivering the programme, coaching or service you purchased | Performance of a contract |
| Processing payments, invoicing, refunds, and keeping financial records | Contract; legal obligation |
| Creating and administering your account | Contract |
| Responding to enquiries and providing support | Contract; legitimate interests |
| Sending service and transactional messages (access details, schedule changes, receipts) | Contract |
| Sending marketing emails and offers | Consent, or legitimate interests where you are an existing client and may opt out at any time |
| Running and measuring advertising, including custom and lookalike audiences | Consent (where cookies or tracking are involved); legitimate interests |
| Analysing site and product usage to improve what we build | Legitimate interests; consent where analytics cookies are used |
| Recording calls for delivery, quality and training | Consent; legitimate interests |
| Preventing fraud, abuse and misuse of our services | Legitimate interests; legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests; legal obligation |
| Complying with tax, accounting and regulatory obligations | Legal obligation |
Where we rely on legitimate interests, we have assessed that our interest in operating and protecting the business does not override your rights and freedoms. You may object at any time — see section 11.
We will never sell your personal data.
5. Marketing communications
You can unsubscribe from marketing at any time using the link in any marketing email, by replying STOP to an SMS where offered, or by writing to us. We will action it promptly.
Unsubscribing from marketing does not stop service messages relating to a programme you are enrolled in, a payment you have made, or your account security.
6. Advertising and audience matching
We advertise on Meta (Facebook and Instagram) and may use other advertising platforms. To do this we may:
- place advertising cookies and pixels on our sites (subject to your consent);
- share a hashed version of your email address or phone number with an advertising platform so it can match you to an existing account and show you relevant ads, or exclude you from ads for something you have already bought;
- build “lookalike” audiences from patterns in existing client data, without disclosing any individual’s identity.
You can opt out of this by declining advertising cookies in our consent banner, by adjusting your ad preferences on the relevant platform, and by writing to us to ask that we exclude you from audience matching.
7. Cookies and tracking technologies
We use:
- Strictly necessary cookies — required for login, security, checkout and load balancing. These cannot be switched off.
- Functional cookies — remember your preferences and settings.
- Analytics cookies — tell us how our pages and product are used, in aggregate.
- Advertising cookies and pixels — including the Meta pixel, used to measure ad performance and to show relevant ads.
Non-essential cookies are set only with your consent, collected through our cookie banner. You can change or withdraw that consent at any time by clearing cookies in your browser. Blocking cookies may break parts of the site.
A full list of the cookies we set, their purpose and their duration, is available at [COOKIE POLICY LINK].
8. Who we share your information with
We share personal data only where necessary, and only with organisations that are bound to protect it. Categories of recipient:
- Payment processors — to take payment and manage refunds and chargebacks.
- CRM, email and messaging providers — to run our client database and send communications.
- Hosting, database and infrastructure providers — to run our websites and applications.
- Analytics and product-measurement providers — to understand usage.
- Advertising platforms — as described in section 6.
- Video conferencing providers — to run coaching calls and workshops.
- Project and workflow tools — where client delivery is coordinated internally.
- Professional advisers — accountants, lawyers, insurers and auditors, under duties of confidentiality.
- Coaches and contractors — team members delivering your programme, under written confidentiality and data protection terms.
- Authorities — where required by law, court order, or to protect our rights, property or safety, or those of others.
- A buyer or successor — if we sell, merge or restructure the business, in which case your data transfers subject to this policy.
A current list of our named sub-processors is available on request from [email protected].
9. International transfers
We are based in [JURISDICTION] and some of our providers are located outside the UK and European Economic Area, including in the United States.
Where we transfer personal data outside the UK/EEA, we rely on one of the following safeguards:
- an adequacy decision covering the destination country;
- the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses, together with a transfer risk assessment;
- your explicit consent, where no other safeguard is available.
You can request a copy of the safeguards we rely on by writing to [email protected].
10. How long we keep your information
We keep personal data only as long as we need it:
| Data | Retention |
|---|---|
| Account and programme delivery records | For the duration of your relationship with us, then [24] months |
| Financial and tax records | [7] years from the end of the relevant financial year, as required by law |
| Marketing contact data | Until you unsubscribe, then a suppression record is kept indefinitely so we do not contact you again |
| Call recordings | [12] months, unless you ask us to delete sooner |
| Website analytics and cookie data | Up to [26] months |
| Support and communication records | [24] months |
| Records relating to a dispute or claim | Until the claim is resolved and the limitation period has expired |
After these periods we delete the data or irreversibly anonymise it.
11. Your rights
Depending on where you live, you may have the right to:
- Access — get a copy of the personal data we hold about you.
- Rectification — correct data that is inaccurate or incomplete.
- Erasure — ask us to delete your data, where we have no overriding reason to keep it.
- Restriction — ask us to pause processing while a concern is resolved.
- Portability — receive certain data in a machine-readable format, or have it sent to another provider.
- Object — object to processing based on legitimate interests, and to direct marketing at any time, with no justification needed.
- Withdraw consent — where we rely on consent, withdraw it at any time, without affecting processing already carried out.
- Avoid solely automated decisions — we do not make decisions producing legal or similarly significant effects about you by automated means alone.
California residents additionally have the right to know what personal information is collected, used and disclosed, the right to delete, the right to correct, the right to opt out of sale or sharing (we do not sell personal information), and the right not to be discriminated against for exercising these rights.
To exercise any right, email [email protected]. We will respond within one month (or 45 days for California requests) and may ask you to verify your identity first. There is no charge unless a request is manifestly unfounded or excessive.
If you are unhappy with how we have handled your data you can complain to your local supervisory authority — in the UK, the Information Commissioner’s Office (ico.org.uk); in the EU, your national data protection authority. We would appreciate the chance to resolve it with you first.
12. Deleting your data
You can request deletion of your account and associated personal data at any time by emailing [email protected] or by using our data deletion request form at themindartists.com/data-deletion-request.
We will delete or anonymise your data except where we are required to retain it — for example, financial records we must keep for tax purposes, or records needed to defend a legal claim. We will tell you what has been retained and why.
If you connected a Facebook or Instagram account to our tools, you can also request deletion of the data we obtained through that connection using the same route, and we will remove it along with any stored access tokens.
13. Security
We protect your information with technical and organisational measures including encryption in transit, access controls on a need-to-know basis, hashed password storage, logging, and confidentiality obligations for everyone working with us.
No system is completely secure. We cannot guarantee the security of information transmitted to us over the internet, and you send it at your own risk. If a breach occurs that is likely to result in a high risk to your rights, we will notify you and the relevant authority as required by law.
You are responsible for keeping your account credentials confidential and for any activity under your account.
14. Children
Our services are for adults. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it.
15. Third-party sites and platforms
Our pages link to third-party sites, and we deliver some content through third-party platforms. We are not responsible for their privacy practices. Read their policies before providing personal data to them.
16. Nature of our services
Our programmes, coaching, workshops and tech tutorials are educational and business-development services. They are not medical, psychological, therapeutic, financial, legal or tax advice, and no outcome or result is guaranteed. Information you receive from us is general in nature and you remain responsible for your own decisions. Nothing in this policy creates a professional relationship beyond the services set out in your purchase terms.
This section is a summary. Your commercial relationship with us is governed by our Terms & Conditions at [TERMS LINK].
17. Changes to this policy
We may update this policy as our services, providers or legal obligations change. The “last updated” date at the top always reflects the current version. Where a change is material, we will notify you by email or through a notice on our site before it takes effect. Continuing to use our services after that means you accept the updated policy.
18. Contact us
Mind Artists LTD
[email protected]