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Privacy Policy

Last updated: February 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
- Browser type and device information
- Pages visited and time spent on site
- 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.
Legal basis: Legitimate interests (Art. 6(1)(f)) — we do this in a privacy-conscious manner and consider that this processing does not override users' rights and freedoms.

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).

We do not sell your personal data to third parties.

5. International Data Transfers

Our service providers — including Kajabi and Stripe — 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).

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.

7. Cookies

We only use strictly necessary cookies. These are set by Kajabi (for session management, login, and course access) and Stripe (for payment security). They are required for the website to function and do not require your consent. At the time of writing, we do not intentionally deploy advertising or marketing tracking cookies. Certain functional or platform-level cookies may be used by Kajabi or Stripe to operate and secure the service.

8. Your Rights Under GDPR

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