Privacy Policy

Last updated: November 2026

This Privacy Policy explains how WISDOMISSION - UNIPESSOAL LDA. (“we”, “us”, “our”) collects, uses, and protects your personal data when you visit www.grinbergmethod.com or purchase our courses.

We are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and applicable Portuguese data protection law.

1. Data Controller

WISDOMISSION - UNIPESSOAL LDA. Caminho da Penteada, Campus da Penteada, 9020-105 Funchal, Madeira, Portugal NIPC / VAT: PT518844625 Email: info@grinbergmethod.com

2. Data We Collect

We collect the following categories of personal data:

a) Account and purchase data - Full name - Email address - Billing address - Payment information (processed by Kajabi Payments / Stripe — we do not store your card details) - Purchase history

b) Usage data - IP address (shortened by our analytics providers before storage) - Browser type and device information - Pages visited, time spent on site, and the website that referred you - How you scroll and click on our pages, including recordings of page visits in which anything you type into forms is hidden (only if you accept analytics cookies — see §7) - Course progress and engagement data

c) Communications - Messages you send us by email - Support requests

3. How and Why We Use Your Data

Fulfil your purchase and provide course access Legal basis: Performance of a contract (Art. 6(1)(b))

Send transactional emails (receipts, access details) Legal basis: Performance of a contract (Art. 6(1)(b))

Send marketing emails Legal basis: Consent (Art. 6(1)(a)) — you may opt out at any time

Analyse website usage to improve our services (Google Analytics, Microsoft Clarity, and Kajabi’s own site analytics) Legal basis: Consent (Art. 6(1)(a)), given through our cookie banner. These tools only run if you accept analytics cookies, and you can withdraw consent at any time (see §7).

Comply with legal obligations (VAT, etc.) Legal basis: Legal obligation (Art. 6(1)(c))

4. Third-Party Processors

We share your data only with trusted service providers who process it on our behalf:

Kajabi — Platform & course hosting Location: United States (see §5)

Stripe — Payment processing Location: United States (see §5)

Google (Google Analytics): Website analytics Location: Ireland / United States (see §5)

Microsoft (Microsoft Clarity): Website analytics, heatmaps and page-visit recordings Location: Ireland / United States (see §5)

We do not sell your personal data to third parties.

5. International Data Transfers

Our service providers (Kajabi, Stripe, Google and Microsoft) are based in or transfer data to the United States, which is outside the European Economic Area (EEA).

These transfers are lawful on the following grounds:

Kajabi: Certified under the EU-U.S. Data Privacy Framework (DPF), an adequacy decision adopted by the European Commission in July 2023. Kajabi has also appointed an EU Representative (EDPO) under GDPR Article 27.
Stripe: Certified under the EU-U.S. Data Privacy Framework (DPF).
Google: Google LLC is certified under the EU-U.S. Data Privacy Framework (DPF).
Microsoft: Microsoft Corporation is certified under the EU-U.S. Data Privacy Framework (DPF).

Where DPF certification applies, transfers are considered adequate under GDPR Article 45. Standard Contractual Clauses (SCCs) under GDPR Article 46(2)(c) serve as an additional safeguard where applicable.

You can request further information about our data transfer safeguards by contacting us at info@grinbergmethod.com.

6. Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations:

Account and purchase data — 10 years (Portuguese tax law requirement)

Marketing preferences — Until you withdraw consent

Support communications — 3 years

Website analytics (Google Analytics): Event data for 2 months, user-level data for 14 months

Website analytics (Microsoft Clarity): Page-visit recordings for 30 days, aggregated heatmap data for up to 13 months

Your cookie choice: 12 months, after which we ask again

7. Cookies

We use two kinds of cookies.

Strictly necessary cookies are set by Kajabi (session management, login, course access, security and load balancing), by Cloudflare on Kajabi’s behalf (protection against automated traffic), by Stripe (payment security) and by our cookie banner (to remember your choice). Kajabi also sets a cookie that counts unique visits to each page for its built-in statistics, and its video player remembers how far you have watched. The website cannot work without these, so they do not need your consent.

Analytics cookies help us understand how visitors use the site so we can improve it. We only set them if you click “Accept” in our cookie banner. If you reject them, or ignore the banner, these tools do not run.

Cookie	Provider	Purpose	Duration
`_ga`	Google Analytics	Distinguishes visitors	2 years
`_ga_0QFFCEZSKR`	Google Analytics	Keeps track of a visit	2 years
`_clck`	Microsoft Clarity	Recognises a returning visitor	1 year
`_clsk`	Microsoft Clarity	Joins the pages of one visit into a single recording	1 day
`rl_anonymous_id`, `rl_session`, `rl_page_init_referrer`	Kajabi (site analytics)	Count visits and link clicks for Kajabi’s analytics	1 year

The necessary cookies are _kjb_session, _csrf_token, AWSALBTG, AWSALBTGCORS, __cf_bm, _cfuvid, vs_uniques_* (Kajabi) and gm_consent (your choice, 12 months).

We do not use advertising or marketing cookies.

You can change your choice at any time with the Cookie Settings link at the bottom of every page. Withdrawing consent does not affect any use of your data that took place before you withdrew it.

You have the following rights regarding your personal data:

Right of access — request a copy of the data we hold about you
Right to rectification — correct inaccurate data
Right to erasure — request deletion of your data (“right to be forgotten”), subject to legal retention requirements
Right to restrict processing — ask us to pause processing your data
Right to data portability — receive your data in a structured, machine-readable format
Right to object — object to processing based on legitimate interests
Right to withdraw consent — at any time, where processing is based on consent (e.g. marketing emails)
Right to LIA summary — where we process data based on legitimate interests, you have the right to request a summary of our assessment of why those interests are not overridden by your data protection rights

To exercise any of these rights, contact us at: info@grinbergmethod.com

We will respond within 30 days. You will not be charged for making a request.

9. Right to Lodge a Complaint

If you believe we have not handled your data correctly, you have the right to lodge a complaint with the Portuguese data protection authority:

Comissão Nacional de Proteção de Dados (CNPD) Website: https://www.cnpd.pt/ Email: geral@cnpd.pt

10. Marketing Communications

We only send marketing emails to people who have explicitly opted in. Consent is collected via an optional, unticked checkbox at checkout at the time of purchase. Ticking this box is entirely voluntary and is not required to complete a purchase.

If you have opted in, you may withdraw your consent and unsubscribe at any time by: - Clicking “unsubscribe” in any marketing email, or - Contacting us at info@grinbergmethod.com

Withdrawing consent does not affect transactional emails related to your purchases (receipts, access details, account notifications), which we send based on our contractual obligation to you.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or prominent notice on the website. The “last updated” date at the top of this page reflects the most recent revision.

12. Contact

WISDOMISSION - UNIPESSOAL LDA. Email: info@grinbergmethod.com Website: www.grinbergmethod.com