Privacy Policy for Reflective Mastery Program

Effective Date: April 22, 2026

 

Alpha.Phi Consulting, owned by Andrijana Filipovic, Croatia, operating as Grow With U Academy (the "Provider"), provides this Privacy Policy to inform users ("you") about how we collect, use, disclose, and protect your personal data in connection with the Reflective Mastery development program ("Program") offered at https://grow-with-u-academy.sendpulse.courses/reflective-mastery  (the "Site"). This policy complies with GDPR (EU) and applicable EU/EEA data protection laws for e-learning platforms with payments.

  1. Data Controller

The data controller is Andrijana Filipovic, Zagreb, Croatia - contact: info@growwithu.eu

SendPulse acts as the processor for hosting and course delivery.

 

  1. Personal Data We Collect

We collect the following data:

  • Registration and Access: Name, email, payment details (via Stripe or similar, not stored by us).
  • Course Usage: Progress data, quiz results, completion certificates.
  • Communications: Inquiries, support requests.
  • Technical: IP address, browser type, device info (for security and analytics via SendPulse).

We do not collect sensitive data (e.g., health, political opinions).

 

  1. Legal Basis for Processing
  • Contract: For course delivery and payments (Art. 6(1)(b) GDPR).
  • Consent: For marketing (Art. 6(1)(a) GDPR).
  • Legitimate Interest: Site security and analytics (Art. 6(1)(f) GDPR).

 

  1. How We Use Your Data
  • Deliver the Program (access, certificates).
  • Process payments.
  • Send updates, certificates, and support.
  • Improve services (anonymised analytics).
  • Comply with laws.

 

  1. Data Sharing
  • Processors: SendPulse (hosting), payment gateways (e.g., Stripe) – bound by GDPR DPAs.
  • No Sales: We do not sell data.
  • Legal: Only if required by law.

 

  1. Data Retention
  • Course data: Duration of access + 2 years for certificates.
  • Payments: 7 years for accounting.
  • Inquiries: 3 years.
  • Deletion upon request or account closure.

 

  1. Your Rights

7a. Under the GDPR, you have the following rights regarding your personal data:

  • Right to Access: You can request a copy of the personal data we hold about you.
  • Right to Rectification: You can request that we correct any inaccurate or incomplete personal data.
  • Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data under certain circumstances.
  • Right to Restriction of Processing: You can request that we limit the way we use your personal data.
  • Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format.
  • Right to Object: You can object to the processing of your personal data, particularly for direct marketing purposes.
  • Right to Withdraw Consent: If we are relying on your consent to process your personal data, you have the right to withdraw that consent at any time.

 

7b. California Residents (CCPA/CPRA Rights)

If you are a California resident, you have the right to:

  • Know what personal information we collect, use, or disclose.
  • Request deletion of your personal information.
  • Opt-out of "sale" of data (we do not sell data).

 

To exercise these rights, contact us at info@growwithu.eu. We respond within 30-45 days. Verification required. No discrimination for exercising rights.

 

  1. Security

We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. However, no internet transmission is entirely secure, and we cannot guarantee the absolute security of your data. We use HTTPS, access controls, and SendPulse security.

 

  1. International Transfers

Data processed in EU/EEA via SendPulse. No non-EU transfers.

 

  1. Children's Privacy

Program for adults 18+. No children's data collected.

 

  1. Changes

We reserve the right to update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on our Landing Page and updating the “Last Updated” date. Posted changes are effective immediately.

 

  1. Contact

If you have any questions or concerns about this Privacy Policy or our data practices, please get in touch with us at: Alpha.Phi Consulting, info@growwithu.eu

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