1. Introduction and Controller Information

This Privacy Policy explains how Service to Millions LTD dba Undeniable ("Undeniable," "we," "us," or "our") collects, uses, shares, and protects information about you when you use our website at justundeniable.com and our DWY Mentorship services for web agencies, consultants, and coaches (collectively, the "Services").

Data Controller Details:

• Legal Entity: Service to Millions LTD dba Undeniable
• Registered Address: 120 Cavendish Place, Eastbourne, East Sussex, England, BN21 3TZ
• Contact Email: contact@justundeniable.com
• Company Registration: 10781363, registered in England and Wales

2. Information We Collect

We collect information you provide directly and automatically through your use of our Services.

Personal Information You Provide

• Account Information: Name, email address, phone number, business name, and password when you create an account through Memberstack
• Business Information: Company details, revenue range, business type, professional background, and business goals
• Communication Data: Messages, feedback, and correspondence you send to us
• Program Information: Your progress, goals, and interactions within our educational programs
• Educational Outcomes: Success stories, learning experiences, and feedback you share about our services

Information Collected Automatically

• Technical Data: IP address, browser type and version, device information, operating system, and time zone settings
• Usage Data: Pages visited, time spent on pages, clicks, and navigation patterns
• Cookie Data: Information collected through cookies and similar tracking technologies (see Section 7)
• Geolocation Data: Approximate location based on IP address

Information from Third Parties

We may receive information about you from:

• Business partners who refer you to our services
• Social media platforms when you interact with our content
• Analytics providers about your interactions with our marketing

3. How We Use Your Information

We process your personal information based on the following legal bases under UK GDPR:

Performance of Contract

• Providing access to our DWY educational programs and learning frameworks
• Managing your account and authentication through Memberstack
• Delivering educational content and peer learning support
• Processing your enrollment and managing your membership

Legitimate Interests

• Improving and personalizing our educational services based on usage patterns
• Analyzing program performance and student engagement
• Preventing fraud and maintaining security
• Conducting educational analytics and research
• Developing new educational services and features
• Protecting our legal rights and interests

Consent

• Sending marketing communications about our educational services
• Using cookies for analytics and advertising purposes
• Processing special categories of data if applicable
• Using your educational outcomes and testimonials in marketing

Legal Obligations

• Complying with applicable laws and regulations
• Responding to legal requests and preventing harm
• Maintaining records for tax and accounting purposes

4. How We Share Your Information

We share your information only as described below:

Service Providers

We work with trusted third-party services to operate our educational business:

• Payment Processing: Stripe and Klarna process all payment transactions. We do not store payment card details
• Analytics Services: Google Analytics, Google Tag Manager, and Webflow Analyze for website analytics
• Marketing Tools: Meta Pixel and LinkedIn Insight Tag for advertising optimization
• Infrastructure: Vercel for hosting, Supabase for database services
• Productivity Tools: ClickUp and Airtable for internal project management
• AI Services: OpenAI, Anthropic, and Google Gemini for service enhancement
• Authentication: Memberstack for user account management
• Development Tools: Cursor for development purposes
• Communication: Google Workspace for business communications

Each service provider is bound by data processing agreements and may only process your data according to our instructions.

Legal Requirements

We may disclose your information if required by law, court order, or governmental authority, or when we believe disclosure is necessary to:

• Comply with legal obligations
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or the public
• Prevent or investigate possible wrongdoing

Business Transfers

If we undergo a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our website of any change in ownership and your choices regarding your information.

With Your Consent

We may share your information for other purposes with your explicit consent.

5. International Data Transfers

Your information may be transferred to and processed in countries outside the UK, including the United States. We ensure appropriate safeguards are in place for such transfers:

• Standard Contractual Clauses: We use UK-approved standard contractual clauses with our service providers
• Adequacy Decisions: Some transfers rely on adequacy decisions recognized by the UK government
• Data Privacy Framework: Certain US-based providers are certified under appropriate frameworks

You consent to the transfer of your information to countries outside the UK, understanding that data protection laws may differ.

6. Data Retention

We retain your personal information for as long as necessary to provide our educational services and fulfill the purposes described in this policy:

• Active Accounts: Retained for the duration of your membership and educational relationship
• Post-Termination: Data retained for 7 years for legal and tax compliance, then deleted
• Marketing Data: Updated based on engagement and consent status
• Analytics Data: Aggregated data may be retained indefinitely for educational research
• Educational Testimonials: Retained indefinitely unless you request removal

You may request deletion of your personal data at any time, subject to legal retention requirements.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your educational experience and gather analytics:

Essential Cookies

Required for basic website functionality and authentication. These cannot be disabled.

Analytics Cookies

• Google Analytics (_ga, _gid) for usage statistics
• Webflow Analyze for performance monitoring
• Google Tag Manager for tag management
• These help us understand how students use our educational platform

Marketing Cookies

• Meta Pixel for Facebook and Instagram advertising
• LinkedIn Insight Tag for professional targeting
• Used to deliver relevant educational advertisements and measure campaign effectiveness

Managing Cookies

You can manage cookie preferences through:

• Your browser settings
• Our cookie consent banner
• Opt-out tools at www.aboutads.info/choices

Note that disabling certain cookies may impact Service functionality.

8. Your Rights Under UK GDPR

You have the following rights regarding your personal information:

• Access: Request a copy of your personal data we hold
• Rectification: Correct inaccurate or incomplete information
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit processing of your data in certain circumstances
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing, especially for direct marketing (absolute right)
• Automated Decision-Making: Protection from solely automated decisions

To exercise these rights, contact us at contact@justundeniable.com. We will respond within one month of receipt.

9. Additional Privacy Rights for US Residents

California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act:

• Know: What personal information we collect, use, share, and sell
• Delete: Request deletion of personal information
• Opt-Out: Opt-out of sale or sharing of personal information
• Non-Discrimination: Equal service regardless of privacy choices
• Correct: Request correction of inaccurate information
• Limit Use: Limit use of sensitive personal information

Notice of Collection: We collect identifiers, business information, internet activity, and inferences. We do not sell personal information.

Virginia Residents (VCDPA)

Virginia residents have rights to:

• Access personal data
• Correct inaccuracies
• Delete personal data
• Obtain portable copy
• Opt-out of targeted advertising
• Appeal decisions

Colorado, Connecticut, and Utah Residents

Similar rights apply under respective state privacy laws. Contact us to exercise your rights.

Do Not Sell or Share My Personal Information

We do not sell personal information. Our use of analytics and advertising cookies may constitute "sharing" under some state laws. To opt-out:

• Click "Cookie Preferences" in our website footer
• Email: contact@justundeniable.com with subject "Do Not Sell/Share"
• Use Global Privacy Control (GPC) if available in your browser

10. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Encryption: SSL/TLS encryption for data in transit, encryption at rest for sensitive data
• Access Controls: Limited access to personal data on a need-to-know basis
• Third-Party Security: We work only with service providers maintaining strong security standards
• Incident Response: Procedures to detect, investigate, and respond to data breaches
• Regular Updates: Security measures are regularly reviewed and updated

While we strive to protect your information, no method of transmission over the internet is 100% secure. You understand and accept this inherent risk.

Data Breach Notification

If a breach occurs that poses risk to your rights and freedoms, we will:

• Notify the ICO within 72 hours
• Notify affected individuals without undue delay
• Provide information about the breach and mitigation steps

11. Marketing Communications

If you've consented to receive marketing communications, you may:

• Receive emails about our educational programs, features, and industry insights
• Be included in our peer learning community communications
• Receive invitations to webinars and educational events
• See targeted advertisements on social media platforms

Opting Out

You can unsubscribe from marketing emails:

• Using the unsubscribe link in each email
• Emailing contact@justundeniable.com
• Managing preferences in your account settings

Note: You cannot opt-out of transactional emails (receipts, account notifications).

12. Testimonials and Educational Success Stories

By sharing testimonials or educational outcomes with us, you grant us permission to use this content in our marketing materials. We may:

• Use your name, business name, and location
• Share educational achievements and learning experiences you provide
• Edit for length and clarity
• Use across all marketing channels

To request removal of your testimonial, contact contact@justundeniable.com.

13. Children's Privacy

Our Services are intended for business professionals aged 18 and over. We do not knowingly collect information from individuals under 18. If we learn we've collected information from someone under 18, we will delete it promptly.

Parents/guardians who believe we may have collected information from their child should contact us immediately.

14. Third-Party Links and Services

Our Services may contain links to third-party websites and integrate with third-party services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.

15. Do Not Track Signals

Some browsers transmit "Do Not Track" signals. We do not currently respond to these signals, but you can manage tracking through cookie settings and opt-out tools.

16. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of material changes via:

• Email notification
• Prominent notice on our website
• In-service notifications

Your continued use of our Services after such modifications constitutes acceptance of the updated policy.

17. Data Protection Officer

While not legally required to have a DPO, privacy inquiries can be directed to:

• Privacy Contact: contact@justundeniable.com
• Response Time: Within 30 days for general inquiries

18. Contact Information and Complaints

For questions about this Privacy Policy or to exercise your rights:

Email: contact@justundeniable.com
Address: 120 Cavendish Place, Eastbourne, East Sussex, England, BN21 3TZ

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