Privacy notice
Effective date: [TBC with Tracey: go-live date]
Effective date: [TBC with Tracey: go-live date]
Who is responsible
UB Clarity Systems Ltd is the controller for the personal information we use to operate the UNBOUND services covered by this notice. Our company number is 17210684 and our registered office is 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. Contact tracey@unboundglobal.co with privacy questions or requests.
UNBOUND™ and related marks are owned by Unbound Global (Pty) Ltd, a South African company (registration 2026/238916/07), and are used by UB Clarity Systems Ltd with its permission. The operating company remains the seller for its direct sales. Ownership of the domain or intellectual property alone does not determine who controls customer personal information.
Information we collect
Depending on the features you use, we collect contact and account information; order and payment-status records; support communications; assessment answers and results; learning progress; Tutor conversations; and reflections, messages or profile updates you choose to submit. Technical information may include device and browser information, IP address, security events and necessary storage technologies.
On the website, unboundglobal.co, the free reflection sign-up collects your email address and, if you give it, your first name. They are sent to Systeme.io, which sends you the reflection, the free reflection guides and the weekly UNBOUND emails you asked for. Every email has an unsubscribe link, and unsubscribing stops them. The website sets no cookies and loads no tracking or advertising scripts unless you accept them in its cookie notice. If you accept, Google Analytics and Google Ads measurement, loaded through Google Tag Manager, record how you reached the site, the pages you view and whether you signed up; advert personalisation stays off, and your email address is never sent to Google. You can change your answer at any time with "Cookie choices" in the website footer.
Information comes from you, your use of the service and providers administering payments, accounts and delivery. Private journals kept offline are not collected simply because you purchased them. Information enters our systems when you submit it or use a feature that transmits it. Please avoid including unnecessary information about other people.
Stripe handles card details on its own Checkout pages; we never receive card details. This app stores the purchase reference, payment provider, status, amount, currency, Stripe event and session references, payment-intent reference and payment-status evidence. It does not store a Stripe Checkout Session containing customer name, email or address.
Purposes and lawful bases
[TBC with Tracey: confirm] We use account, order and necessary learning information to supply the product or service you request, relying on performance of our contract with you. We use Tutor observations and Living Profile information with consent, which can be withdrawn at /member/profile. We use proportionate security, fraud-prevention and service-administration information for our legitimate interests in protecting accounts and operating a reliable service. We use required financial and compliance records to meet legal obligations. We send the reflection and the UNBOUND emails because you asked for them on the website, relying on your consent, which you can withdraw at any time by unsubscribing. We use website analytics and advert measurement only with your consent, given in the website's cookie notice and withdrawn there at any time.
Sensitive information
We do not ask for health information. If you share health or other special-category information with the Tutor, your message and the recent session turns are sent to Anthropic to produce the Tutor response and are stored as part of your Tutor conversation. If a safety boundary is triggered, a separate safety record stores the category, module and time, but not the message text. [TBC with Tracey: Article 9 condition and handling procedure for incidental special-category disclosures]
Do not submit sensitive information until the relevant feature explains how it will be handled. Withdrawing consent does not affect earlier lawful processing; we will explain any feature that cannot continue without the information and assess deletion requests under applicable law.
Assessments and AI supported profiles
Assessments score the answers you submit. The Identity assessment adds the configured option weights for each lens and can return insufficient responses, no clear signal, mixed signal or a primary signal. The Executive assessment adds each answer to its configured domain, maps scores to bands and can return insufficient responses, no clear focus or calibration focus. A result is a reflective aid and may be wrong; it never decides access, price or eligibility. You can respond that a result does not fit you; that response is recorded and is not used further.
Nothing is saved to a Living Profile unless you choose Add to Profile or Edit first. Leave open and Do not save create no profile entry. At /member/profile you can reword an entry, change its status, archive it, remove it, reset all entries, export the profile, and turn Tutor observations off.
AI messages and selected context are transmitted to Anthropic, using Claude through its API, so the Tutor can respond. Anthropic receives the member message, up to 20 recent session turns, the current module, and approved knowledge excerpts for the current and completed modules. It does not receive journal entries or exchange messages: those are encrypted on the member's device and the server cannot read them. At present, Living Profile wording is not included in any Tutor prompt. [TBC with Tracey: confirm against Anthropic's commercial terms for her organisation]
Who receives information
We share only information needed for the relevant purpose with contracted providers:
- Hetzner Online GmbH provides hosting and the database, on a server in Nuremberg, Germany.
- Stripe provides payment processing. Card details go to Stripe and not to us.
- Resend provides account and transactional email in its EU region.
- Anthropic provides the AI Tutor through its Claude API.
- Sentry provides error monitoring. Emails, tokens and private text are removed before an event is sent.
- Cloudflare provides R2 file storage for lesson videos and, where configured, encrypted off-site backups. Cloudflare Turnstile provides the bot check on registration and contact forms.
- Systeme.io provides UNBOUND's email automation. It holds the email address and first name given at the website sign-up and sends the emails asked for there. [TBC with Tracey: whether platform members are added to it — nothing is sent from the platform today]
- Google provides website analytics and advert measurement on unboundglobal.co (Google Tag Manager, Google Analytics and Google Ads), only after you accept them in the cookie notice. It does not receive your email address or anything from the academy.
- Whop runs UNBOUND's book store at https://unbound-clarity.whop.site. Whop takes the payment for book orders and handles them under its own terms and privacy policy; this platform does not receive them.
Authorised staff or facilitators may access information required for their role. Journal entries are visible only to their owner, not to a guide or an admin. An exchange is visible only to the member and their guide. A Living Profile is visible only to its owner. Within the platform, Tutor conversations are visible only to their owner; guides and admins cannot open them. Unlike the journal, Tutor conversations are not end-to-end encrypted, because the Tutor has to read a message to answer it. Admins can see account details, purchases, progress and enquiries. Guides can see their assigned members' names and progress. [TBC with Tracey: staff names]
We do not sell personal information or use private reflections for advertising.
International processing
[TBC with Tracey: international transfer safeguards, any administration access from South Africa, the applicable transfer mechanism, and how a copy of safeguards can be requested]
How long we keep information
Sessions expire after 30 days. Used or expired email tokens are deleted after 7 days. First-party analytics events are deleted after 13 months. Google Analytics keeps website data for 14 months. Journal entries you delete are permanently removed after 30 days. Private exchange messages, Tutor conversations, Living Profile entries, assessment answers and support messages are kept while your account is open. Deleting your account removes them; if you made a purchase, the purchase record is kept in anonymised form for accounting. [TBC with Tracey: purchase records — 6 years suggested] [TBC with Tracey: encrypted backup retention — 30 days suggested]
Where law or an active dispute requires longer retention, we restrict use to that purpose. Closing an account does not always require immediate removal of legally required transaction records. We explain exceptions when responding to a deletion request.
Your rights
Subject to the applicable legal conditions, you can request access, correction, deletion, restriction or portability of your information, and object to processing based on legitimate interests. You can object to direct marketing at any time. Where processing relies on consent, you can withdraw it. Applicable rights relating to significant automated decisions include safeguards such as human intervention and contesting a decision.
Email tracey@unboundglobal.co. We may proportionately verify your identity. We normally respond to rights requests within one month, subject to lawful extensions or pauses, explaining any refusal or limitation. We do not normally charge a fee.
Children and family features
No child accounts exist. [TBC with Tracey: accounts are for adults 18+]
Security and complaints
Your journal and private exchange are encrypted on your device with keys only you hold. UNBOUND cannot read them, and cannot recover them if you lose both your password and your recovery key.
The server can see who wrote, when, how many entries or messages, sizes, and which lesson a journal entry belongs to. It cannot see titles, bodies or moods. We use proportionate technical and organisational measures to protect information. No online system can guarantee absolute security.
You may complain by email to tracey@unboundglobal.co. [TBC with Tracey: does the registered office accept customer post] We acknowledge data-protection complaints within 30 days, investigate and respond without undue delay, and provide progress updates where needed. You may also complain to the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/ or a competent local regulator. You do not have to surrender that right by contacting us first.
[TBC with Tracey: ICO registration or fee status]
We update this notice when practices change, show the effective date and notify you of material changes where appropriate. New uses requiring consent will not start merely because we changed this page.