Privacy Policy Twin Flame Academy
Last updated: April 2nd, 2025
This Privacy Policy describes how Twin Flame Academy, based in The Netherlands (“we,” “us,” or “our”), collects, uses, stores, and protects your personal data when you interact with us through our websites, coaching programs, social media, online platforms, and communities.
We are committed to protecting your privacy and ensuring transparency around how your information is handled, in line with the General Data Protection Regulation (GDPR) and Dutch data protection law.
By using our services or providing your information, you agree to this Privacy Policy.
1. Who We Are
Twin Flame Academy is a coaching and education company serving clients online through:
- Thrivecart Learn (online programs and course delivery)
- Zoom and Microsoft Teams (live coaching and events)
- Instagram, TikTok, Telegram, Voxer, YouTube and Facebook (community and coaching)
- Email communications and downloadable resources
We process your data as the “data controller” under applicable law.
2. What Information We Collect
We may collect and process the following personal information:
- Identity Data – name, username, social media handle
- Contact Data – email address, billing address, phone number
- Payment Data – transaction details (via third-party processors like Stripe/Thrivecart)
- Coaching Data – intake forms, coaching notes, messages in private chats (where applicable)
- Technical Data – IP address, browser type, device usage, cookies (via our website or Thrivecart)
- Usage Data – data about your interactions with our emails, courses, and platforms
We do not intentionally collect or store sensitive personal information unless explicitly shared by you as part of a coaching relationship. We handle all disclosures with confidentiality.
3. How We Use Your Information
We use your information for the following purposes:
- To provide and deliver coaching programs and digital products
- To personalise your learning experience and communications
- To manage payments and purchases securely
- To respond to inquiries or customer service requests
- To improve our services and offerings
- To send you updates, announcements, and occasional promotional content (with your consent)
- To comply with legal obligations
4. Legal Basis for Processing
Under GDPR, we rely on the following legal bases:
- Consent – when you opt in to receive emails or share coaching info
- Contractual necessity – to fulfil our agreement with you (e.g. access to a course or program)
- Legal obligation – e.g. for tax or financial reporting
- Legitimate interest – e.g. to improve our services, protect our business, or prevent fraud
You may withdraw consent at any time by emailing us or clicking “unsubscribe” in our communications.
5. How We Share Your Data
We do not sell or rent your personal data. We only share your data when necessary with trusted third parties who help us deliver services, such as:
- Thrivecart (course delivery & payments)
- Stripe or PayPal (payment processors)
- Google (email, calendar, cloud documents)
- Zoom, Voxer, Telegram, Instagram, Facebook, Tik Tok, YouTube, Typeform (platform access for service delivery)
- Email marketing platforms (e.g. MailerLite, Kit)
All third parties are required to process your data in accordance with GDPR and only on our instructions.
6. International Transfers
Some of our service providers may process data outside the EEA (e.g., the United States). Where this occurs, we ensure adequate safeguards are in place (e.g., standard contractual clauses) to protect your data.
7. Data Retention
We retain your personal data only as long as necessary to fulfil the purposes we collected it for, including:
- Active coaching relationships
- Legal or accounting obligations (e.g. 7 years for tax documentation)
- Client history if relevant for future services (unless you request deletion)
If you request deletion of your data, we will honour this request in accordance with applicable laws.
8. Your Rights Under GDPR
You have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate or incomplete data
- Request erasure of your data (“right to be forgotten”)
- Object to or restrict certain types of processing
- Request transfer of your data to another provider
- Withdraw your consent at any time
To exercise any of these rights, please contact us at contact@imaginesunshine.nl, enclosing our GDPR compliant Data Subject Request Form (DSRF).
If you are not satisfied with our response, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
9. Children’s Privacy
Our services are not intended for children under 18. We do not knowingly collect personal data from minors. If we become aware that a child has provided personal data, we will delete it.
10. Cookies and Tracking Technologies
Our website and third-party tools (e.g. Thrivecart, Google Analytics) may use cookies to:
- Track usage patterns
- Save user preferences
- Improve user experience
You can disable cookies via your browser settings.
11. Data Security
We have implemented appropriate technical and organisational measures to protect your data from loss, misuse, or unauthorised access. However, no digital transmission is 100% secure, and you provide your information at your own risk.
12. Changes to This Policy
We may update this Privacy Policy periodically. We will notify you of significant changes by email or by updating the “last updated” date at the top of this page.
Continued use of our services after changes are posted will be deemed acceptance of the revised policy.
13. Contact Us
If you have any questions or concerns about your personal data, or wish to exercise your rights, please contact:
Twin Flame Academy, located in The Hague, The Netherlands
Business registration number (KvK): 72974982
📧 contact@imaginesunshine.nl