Privacy Policy

Privacy Policy

Introduction

1. Preamble

The protection of your data is very important to us. This Privacy Policy informs you about the type, scope, and purpose of the processing of personal data within our website and connected services (collectively, the “Website”). This Privacy Policy also applies to personal data processed in connection with our coaching services, digital products, events, communications, and client relationships, whether provided via the Website or through third-party platforms.

2. Data Controller and Contact

The controller within the meaning of the General Data Protection Regulation (GDPR) and other applicable data protection laws is:

Corporate Warriors, LLC
2870 Rampart Cir
Clearwater, Florida 33761, USA
Email: info@corporatewarriors.io

For any questions regarding data protection or the exercise of your rights, you may contact us using the contact details above.

3. Definitions

This Privacy Policy is based on the terms used in the GDPR. Definitions (e.g., “personal data” and “processing”) can be found in article 4 of the General Data Protection Regulation (GDPR).

4. General information on data processing

4.1. Scope of processing of personal data

We process personal data to the extent necessary to provide a functional Website, deliver our services and digital products, communicate with you, and operate our business. Depending on the context, processing may be based on your consent, a contract, legal obligations, or our legitimate interests.

4.2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, art. 6 para. 1 lit. a EU Data Protection Regulation (GDPR) serves as the legal basis.
In the processing of personal data required for the performance of a contract to which the data subject is a party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
Insofar as the processing of personal data is required to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

4.3. Data erasure and storage time

We store personal data only as long as necessary for the purposes described in this Privacy Policy or as required by law. Data will be deleted or restricted once the purpose no longer applies, unless retention is required for legal or contractual reasons.

Cookies and other technologies

5. Provision of the Website and Server Log Files

When you access our Website, technical data is automatically processed by our hosting provider, WP Engine, to ensure the secure and stable operation of the Website.

The following data may be processed in server log files:

  • IP address
  • Date and time of access
  • Requested page or file
  • Browser type and operating system
  • Referrer URL (if applicable)

This processing is carried out for:

  • Website security and stability
  • Detecting and preventing misuse or attacks
  • Technical error analysis

Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

Server log data is stored by our hosting provider for a limited period in accordance with their retention practices and is not combined with other personal data by us.

We do not use server log files to identify individual visitors.

6. Cookies

Our Website uses cookies that are necessary for the technical operation of the Website. Additional cookies (e.g., for embedded third-party content or analytics, if enabled) are used only if you have provided consent via our cookie banner.

You may accept or reject non-essential cookies at any time through the cookie settings on our Website.

Further information can be found in our Cookie Policy.

7. Analytics and Tracking

At this time, we do not use Google Analytics or remarketing/advertising tracking (such as Meta Pixel or LinkedIn Insight Tag) on our Website.

If we implement analytics or tracking in the future, we will update this Privacy Policy accordingly and, where required, request your consent via our cookie banner.

Communication and Marketing

8. Newsletter, Email Communication, and Marketing

We offer newsletters, automated emails, and informational messages related to our services, products, and free resources.

When you subscribe, download a free resource, register for an offer, or otherwise provide your email address, we process your data based on your consent pursuant to Art. 6(1)(a) GDPR.

We use the following service providers for email communication and marketing:

  • Brevo (former Sendinblue)
  • Kit (former ConvertKit)

In the course of email communication, our email service providers may process additional technical and usage data, such as IP address, device and browser information, timestamps, delivery status, opens, clicks, and unsubscribe actions. This data is used to ensure deliverability, system security, and to improve the relevance and effectiveness of our communications.

These providers process personal data on our behalf under applicable data protection agreements.

Emails may contain educational content, updates, and information about our offerings. You may unsubscribe at any time via the link included in each email.

Email performance tracking: We may process technical information such as email opens and link clicks to improve our communication and measure effectiveness. Legal basis: Art. 6(1)(a) GDPR (consent), and where permitted by applicable law, Art. 6(1)(f) GDPR (legitimate interests), in particular for deliverability, security, and system integrity.

Retention: Your email address is stored for as long as you remain subscribed. After unsubscribing, your data will be deleted or anonymized unless legal retention obligations apply.

8.1 Messenger-Based Communication (ManyChat)

We use automation tools such as ManyChat to manage communication via social media messaging platforms (e.g., Instagram Direct Messages). Data processed may include usernames, message content, and information voluntarily provided during conversations or automations.

Processing is based on Art. 6(1)(a) GDPR (consent) and Art. 6(1)(f) GDPR (legitimate interest in responding to inquiries and delivering requested information).

8.2. Right to Object, Withdrawal of Consent, and Deletion

You may withdraw your consent to receive emails at any time by using the unsubscribe link included in each email or by contacting us directly.

After unsubscribing, we will no longer send you marketing emails. Certain data may be retained in a restricted form (e.g., on a suppression list or for compliance and documentation purposes) to ensure that we respect your opt-out request and to meet legal obligations.

You may also object to the processing of your personal data for direct marketing purposes at any time. If you do so, your personal data will no longer be processed for such purposes.

Requests for deletion of personal data will be handled in accordance with applicable legal requirements. Data that is no longer required and not subject to legal retention obligations will be deleted.

9. Contact, Forms, and Scheduling

9.1 Contact Forms and Email Contact
If you contact us via a form or by email, we process the data you provide (e.g., name, email address, message content) to respond and manage the communication.

Legal basis:

  • Art. 6(1)(b) GDPR if communication relates to a contract or pre-contractual steps
  • Art. 6(1)(f) GDPR for general inquiries (legitimate interest in responding)
  • Art. 6(1)(a) GDPR if we request and receive consent in a specific context

Retention: We store communication data only as long as needed to handle the request and for documentation purposes, unless a longer retention is required by law.

Forms and Questionnaires (Typeform)

We use Typeform for applications, intake forms, waitlists, and feedback. Submission of certain forms is required to enter our programs or services.

Depending on the context, forms may include open-ended questions where users voluntarily share personal reflections, professional challenges, or experiences related to stress, burnout, or workplace situations.

Such information is processed solely for the purpose of evaluating applications, delivering services, and improving our offerings. We do not request medical or therapeutic information.

Processing is based on Art. 6(1)(b) GDPR (pre-contractual measures and contract performance) and Art. 6(1)(a) GDPR (consent). Where special category data is voluntarily shared, processing is based on explicit consent pursuant to Art. 9(2)(a) GDPR.

Spam protection (CAPTCHA): We may use CAPTCHA services (e.g., Google reCAPTCHA) to protect forms from abuse. This may involve processing your IP address and technical device information. Legal basis: Art. 6(1)(f) GDPR (legitimate interests in security) and/or Art. 6(1)(a) GDPR (consent where required).

9.2 Scheduling (Calendly)
We may use scheduling tools such as Calendly to arrange appointments. When you book, the data you provide is processed to schedule and manage the appointment. Please also review the provider’s privacy policy.

10. Customer Relationship Management (CRM) and Automation

We use a customer relationship management (CRM) system (Close) to manage leads, clients, email subscribers, and business communications.

Personal data processed in the CRM may include contact details (such as name, email address, phone number), communication history, notes, application or intake information, and information related to booked calls or services.

Data is transferred to the CRM from forms, applications, email marketing tools, and booking systems. We use automation tools such as Zapier to securely transfer data between systems. Zapier does not enrich or independently process data but facilitates automated data transmission between connected services.

Processing is based on Art. 6(1)(b) GDPR (contract performance), Art. 6(1)(a) GDPR (consent), and Art. 6(1)(f) GDPR (legitimate interests in efficient business operations), as applicable.

Sales, Digital Products, and Service Delivery

11. Payments, Orders, and Digital Platforms

We process payments and deliver services and digital products through the following platforms:

  • Stripe
  • Podia
  • Whop

These providers process personal data necessary for payment processing, invoicing, fraud prevention, and service delivery.

Legal basis: Art. 6(1)(b) GDPR (contract performance) and Art. 6(1)(c) GDPR where retention is required by tax or accounting obligations.

Retention: Transaction and invoice records may be stored for the period required by applicable tax and accounting laws.

12. Video Conferencing, Webinars, and Recordings

We use video conferencing and recording tools such as Zoom, Google Meet, and Riverside for coaching sessions, group programs, webinars, and podcast or masterclass recordings.

Depending on the session, personal data may include name, image, voice, chat messages, and shared content. Sessions may be recorded in certain cases. Participants are informed when a recording takes place.

Recordings are stored within the respective platform’s cloud environment and retained for as long as necessary for the intended purpose, in accordance with our operational needs and the retention settings of the respective platform.

Zoom links and related session information may be distributed via email and/or via Discord, depending on the program.

Processing is based on Art. 6(1)(b) GDPR (contract performance), Art. 6(1)(a) GDPR (consent), and Art. 6(1)(f) GDPR (legitimate interests), as applicable.

13. Use of AI Tools

We may use AI-based tools (such as ChatGPT) to assist with drafting content, summarizing anonymized information, or improving internal workflows. Personal data is not intentionally submitted in identifiable form to such tools.

We do not use AI systems for automated decision-making that produces legal or similarly significant effects within the meaning of Art. 22 GDPR.

14. Embedded Content and Third-Party Media

Our Website may embed content from third parties, such as YouTube, Spotify, and Apple Podcasts. When you interact with embedded content, those providers may process personal data (such as IP address and usage data) under their own privacy policies.

Where required, embedded content may be loaded only after your consent via the cookie banner.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in providing content) and/or Art. 6(1)(a) GDPR (consent where required).

15. Fonts and Third-Party Resources (Google Fonts)

Our Website may use fonts provided by Google Fonts, a service of Google LLC. When pages are accessed, requests may be sent to Google servers, which may include the user’s IP address.

The use of fonts serves the purpose of ensuring a consistent and visually appealing presentation of our Website and is based on Art. 6(1)(f) GDPR (legitimate interests).
Where required, we will request your consent before loading third-party resources.

Further information can be found in Google’s privacy policy: https://policies.google.com/privacy

16. Coaching, Assessments, and Sensitive Information

As part of our coaching services, clients may voluntarily share personal information, including sensitive details (for example, relating to stress, burnout, or personal development). We process such information solely for the purpose of providing coaching services and handling the client relationship.

We do not provide medical, psychological, or therapeutic diagnoses.

Legal basis:

  • Art. 6(1)(b) GDPR for delivering contracted coaching services
  • Where special category data is voluntarily shared and processed, explicit consent may apply under Art. 9(2)(a) GDPR, where applicable.

17. Community Platform and Group Communication (Discord)

We use Discord as a community and communication platform for certain group programs. Depending on the offer, Discord may be used to provide program updates, share links (including Zoom links), post resources, and enable optional participant interaction.

Participation in Discord may require you to have a Discord account in order to access the group space and receive program-related information. You may choose whether to use your real name or a username within Discord. Interaction with other participants is voluntary, and participants are not required to actively engage or share information with others.

When using Discord, personal data may be processed by Discord and/or visible to other participants depending on your account settings and what you choose to post (e.g., username, profile information, messages, reactions, and shared content). We recommend avoiding the sharing of sensitive personal information in community channels.

In addition, Discord may be used internally by our team to coordinate program delivery, client support, and operational communication related to booked calls and services. Access is limited to authorized team members and, where applicable, enrolled clients.

Processing is based on Art. 6(1)(b) GDPR (contract performance) and Art. 6(1)(f) GDPR (legitimate interest in efficient communication and service delivery). Where participants voluntarily share sensitive information, this is done at their discretion. Please note that Discord processes personal data under its own privacy policy and acts as an independent controller for its platform processing.

18. Data Transfers to Third Countries

We are based in the United States and use service providers that may process data in the United States and other countries. When personal data is transferred outside the EU/EEA, we implement appropriate safeguards, such as the EU Standard Contractual Clauses, where applicable, or other lawful transfer mechanisms.

19. Right of Access (Information)

You can ask the person in charge to confirm whether personal data concerning you will be processed by us.
If such processing has taken place, you can request the following information from the person responsible:

  • the purposes for which the personal data are processed;
  • the categories of personal data processed;
  • the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;
  • the planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period;
  • the existence of a right to have your personal data concerning you corrected or deleted, a right to have processing restricted by the controller or a right to object to such processing;
  • the existence of a right of appeal to a supervisory authority;
  • any available information on the origin of the data if the personal data are not collected from the data subject;
  • the existence of automated decision-making, including qualification in accordance with Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.

20. Right to Rectification

You have a right of rectification and/or completion with regard to the responsible party if the personal data processed concerning you are incorrect or incomplete. The party responsible shall make the correction without delay.

21. Right to Restriction of Processing

Under the following conditions, you may request that the processing of personal data concerning you be restricted:

  • if you dispute the accuracy of the personal data concerning you for a period of time that enables the person responsible to verify the accuracy of the personal data;
  • the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;
  • the controller no longer needs the personal data for the purposes of the processing, but you do need them to assert, exercise or defend legal claims, or
  • if you have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the person responsible outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.
If the processing restriction has been restricted according to the above conditions, you will be informed by the person responsible before the restriction is lifted.

22. Right to Erasure

You may request the data controller to delete the personal data relating to you without delay and the controller is obliged to delete this data without delay if one of the following reasons applies:

  • The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
  • You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.
  • You file an objection against the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 GDPR.
  • The personal data concerning you have been processed unlawfully.
  • The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.
  • The personal data concerning you have been collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.

Information to third parties

If the data controller has made the personal data concerning you public and is obliged to delete it pursuant to Art. 17 para. 1 GDPR, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform data processors who process the personal data that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.

Exceptions

The right to cancellation does not exist insofar as the processing is necessary

  • to exercise freedom of expression and information;
  • for the performance of a legal obligation required for processing under the law of the Union or of the Member States to which the controller is subject or for the performance of a task in the public interest or in the exercise of official authority conferred on the controller;
  • for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the law referred to under a) is likely to render impossible or seriously impair the attainment of the objectives of such processing, or
  • to assert, exercise or defend legal claims.

23. Right to Be Informed of Recipients

If you have exercised your right to have the data controller correct, delete or limit the processing, he/she is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.
The person responsible shall have the right to be informed of such recipients.

24. Right to Data Portability

You have the right to receive the personal data concerning you that you have provided to the person responsible in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another person in charge without obstruction by the person in charge to whom the personal data was provided, provided that

  • processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and
  • processing is carried out using automated methods.

In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one data controller to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
The right to transferability shall not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority conferred on the responsible party.

25. Right to Object

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you under Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.
The responsible party no longer processes the personal data concerning you, unless he can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility to exercise your right of objection in connection with the use of Information Society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

26. Right to Withdraw Consent

You have the right to revoke your data protection declaration of consent at any time. The revocation of consent shall not affect the legality of the processing carried out on the basis of the consent until revocation.

27. Automated Decision-Making, Including Profiling

You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. This does not apply if the decision

  • is necessary for the conclusion or performance of a contract between you and the person responsible,
  • is admissible by law of the Union or of the Member States to which the person responsible is subject and that law contains appropriate measures to safeguard your rights, freedoms and legitimate interests, or
  • with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.
In the cases referred to in (1) and (3), the party responsible shall take reasonable measures to safeguard your rights, freedoms and legitimate interests, including at least the right to obtain the intervention of a person by the party responsible, to state his own position and to challenge the decision.

28. Right to Lodge a Complaint

Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or suspect of infringement, if you believe that the processing of personal data concerning you is contrary to the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

29. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or business changes. The current version is always available on our Website.