Privacy Policy

1.Who we are

The data controller responsible for your personal data is:

• Lance Samways, trading as Rewired
• Operating as a sole trader in the United Kingdom
• Email: [email protected]
• Website: lancesamways.com

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the details above.

2.What this policy covers

This policy applies to personal data we collect about you when you:

• Visit our website at lancesamways.com
• Sign up for our free 3-night live event or other free content
• Take our identity assessment or any other quiz on our website
• Purchase or enrol in any of our coaching programmes (group or private)
• Subscribe to our email list or other marketing communications
• Participate in our private community on the Kajabi platform
• Attend our live coaching sessions via Zoom
• Communicate with us by email, WhatsApp, or any other channel

3.Information we collect

We collect the following categories of personal data:

Identity and contact information:

• Full name
• Email address
• Telephone number (if you provide one, e.g. for VIP WhatsApp access)
• Country and time zone

Account and programme participation data:

• Account credentials (username, password — handled securely by Kajabi)
• Programme progress (modules completed, sessions attended)
• Workbook responses and reflection exercises you submit
• Posts and comments in the private community
• Live session attendance records

Payment information:

• Billing name and address
• Payment method type (e.g. credit card, PayPal)
• Transaction history and receipts

We do not store full credit card numbers or other sensitive payment details. These are handled directly and securely by our payment processors (Kajabi Payments and Stripe).

Communications:

• Emails you send to us
• WhatsApp messages (for VIP/Private clients only)
• Support requests and any correspondence

Technical and usage data:

• IP address
• Browser type and version
• Device information
• Pages visited, time spent, referral source
• Cookies and similar tracking technologies (see section 9)

Sensitive information: The nature of our coaching means you may voluntarily share sensitive personal details about your life, health, substance use history, and personal circumstances during sessions, in community posts, or in private communications. We treat this information with the utmost confidentiality (see also our Service Agreement, clause 8).

4.How we collect your data

We collect personal data in several ways:

• Directly from you: when you fill in forms on our website, sign up for events, enrol in programmes, take our assessment, attend live sessions, or contact us
• Through our platforms: Kajabi (our hosting and course platform) and Zoom (live sessions) collect technical and usage data as you interact with them
• Through cookies and analytics: when you browse our website (see section 9)
• From payment processors: we receive confirmation of transactions from Kajabi Payments and Stripe

5.Why we use your data

We use your personal data for the following purposes:

• Delivering our services: running coaching programmes, hosting live sessions, providing platform access, managing accounts
• Processing payments: taking and refunding payments, issuing receipts
• Communicating with you: sending programme updates, session reminders, account notifications, responding to your questions
• Marketing: sending you information about our programmes, free events, and related content, where you have given consent
• Improving our services: understanding how people use our website and programmes so we can make them better
• Legal and compliance: keeping financial records, complying with tax obligations, defending against legal claims
• Safety and security: protecting our website, platforms, and clients from misuse or harm

6.Legal basis for processing

Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following:

7.Who we share your data with

We do not sell your personal data to anyone. We share your data only with the following categories of trusted third parties ("data processors") who help us deliver our services:

Each of these processors has their own privacy policy and is bound by data protection agreements with us. They only process your data on our instructions and for the specific purposes listed.

We may also share your data if required by law, by court order, or to protect our legal rights.

8.International transfers

Some of our processors (notably Kajabi, Stripe, Zoom, and Meta) are based outside the UK, primarily in the United States. When your data is transferred outside the UK, we ensure appropriate safeguards are in place, including:

• UK and EU adequacy decisions where applicable
• Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO)
• Processors' own certifications, such as the EU-US Data Privacy Framework

9.Cookies and tracking

Our website uses cookies and similar technologies. Cookies are small text files stored on your device that help websites remember things about your visit.

We use the following types of cookies:

• Strictly necessary: essential for the website to function (e.g. login, checkout). These don't require consent.
• Performance and analytics: help us understand how visitors use the site (e.g. Google Analytics if enabled).
• Functional: remember your preferences (e.g. time zone).
• Marketing: may track your activity across sites to deliver relevant ads.

When you first visit our website, you'll see a cookie banner asking for your consent for non-essential cookies. You can change your preferences at any time via your browser settings or by clearing your cookies.

10.How long we keep your data

We keep your personal data only as long as necessary for the purposes set out in this policy. Specific retention periods include:

• Account data: while your account is active, plus up to 2 years after closure
• Programme participation data: for the duration of your access plus 2 years
• Financial records (transactions, invoices): 7 years, in line with UK tax requirements
• Marketing data: until you withdraw consent or after 2 years of inactivity
• Email correspondence: typically 2 years from the last contact
• Cookies: for the duration set in the cookie itself (typically 30 days to 2 years)

When data is no longer required, we securely delete or anonymise it.

11.Your rights under UK GDPR

You have the following rights in relation to your personal data:

• Right to be informed: to know how your data is being used (which is what this policy is for)
• Right of access: to ask for a copy of the personal data we hold about you
• Right to rectification: to correct inaccurate or incomplete data
• Right to erasure ("right to be forgotten"): to ask us to delete your data, subject to certain legal exceptions
• Right to restrict processing: to limit how we use your data
• Right to data portability: to receive your data in a portable format and transfer it elsewhere
• Right to object: to object to certain types of processing, including direct marketing
• Right to withdraw consent: where we rely on consent, you can withdraw it at any time

To exercise any of these rights, please email [email protected]. We will respond within one month.

Exercising your rights is free of charge. However, if a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on it.

12.Data security

We take the security of your personal data seriously. We use a combination of technical and organisational measures to protect it, including:

• Encryption of data in transit (HTTPS / TLS)
• Encryption of payment data by our processors
• Access controls limiting who can view your data
• Reliance on industry-standard platforms (Kajabi, Stripe, Zoom) with their own robust security certifications
• Two-factor authentication where available

However, no internet transmission or storage method is 100% secure. We cannot guarantee absolute security, but we will do our best to protect your data and notify you of any breach as required by UK GDPR.

13.Marketing communications

We send marketing emails to people who have consented to receive them, or who are existing or recent customers under the "soft opt-in" rule of the Privacy and Electronic Communications Regulations 2003 (PECR).

You can unsubscribe at any time by:

• Clicking the "unsubscribe" link at the bottom of any marketing email
• Emailing [email protected] with "unsubscribe" in the subject

Note: even if you unsubscribe from marketing, we will still send you transactional and service-related emails about your purchases and programme participation, as these are necessary to deliver the service you've paid for.

14.Children's privacy

Our website and services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18.

If you are a parent or guardian and believe a child under 18 has provided us with personal data, please contact us at [email protected] and we will delete it.

15.Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last updated" date at the top of this page
• Notify you by email if the changes are material
• Post a prominent notice on our website

We encourage you to review this policy periodically.

16.How to contact us

If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact us:

• Email: [email protected]
• Website: lancesamways.com

We aim to respond to all enquiries within 5 working days, and to formal data rights requests within one month.

17.Complaints

If you are unhappy with how we have handled your personal data, please contact us first so we have a chance to put things right.

You also have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Helpline: 0303 123 1113
• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF