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LEGAL

Privacy Policy

Last updated: May 2026

This Privacy Policy explains what personal data Transform with Toska collects, why we collect it, how we use it, and your rights under UK GDPR and applicable data protection law.

1. Who We Are

Transform with Toska is operated by Toska, trading as Transform with Toska, a VAT-registered business based in the United Kingdom. References to “we”, “us”, or “our” refer to Transform with Toska. We are the data controller for all personal data described in this policy.

Contact: hello@transformwithtoska.com

2. What Data We Collect

2.1 Data You Give Us Directly

  • Full name and email address when you join our waitlist, newsletter, or create an account
  • Billing address, card type, and last 4 digits of payment card (full card details are held by Stripe or GoCardless, not by us)
  • Messages, responses, and content you submit through intake questionnaires, forms, or surveys associated with any programme or workshop
  • Communications you send us directly, including emails, direct messages on Instagram, TikTok, Telegram, or any other platform, and any other written or recorded communication

2.2 Data from Live Sessions and Recordings

Where you attend a live workshop, coaching call, group session, or other event hosted on Zoom or a similar platform, we may collect:

  • Your name, profile image, and any display name shown on the platform
  • Audio and video if you participate with camera or microphone on
  • Chat messages, reactions, and comments posted during the session
  • Session recordings and transcripts, which may include your voice, image, or written contributions
  • Poll responses and Q&A submissions within the session

We use this data to deliver and improve our services, create replay recordings for enrolled participants, and where relevant, improve the quality of our programmes. We will always notify you when a session is being recorded. If you do not wish to appear in a recording, you may keep your camera and microphone off.

2.3 Communications Data

We collect and retain data from all forms of communication with us or related to our services, including:

  • Emails sent to or from hello@transformwithtoska.com or any Transform with Toska address
  • Direct messages sent to our Instagram, TikTok, or other social media accounts
  • Comments posted on our social media posts or content
  • Messages sent within the Many Butterflies Telegram community
  • Any other written or recorded communication

This data is used to respond to your enquiries, deliver our services, resolve disputes, improve our programmes and communications, and where applicable, for the AI-assisted analysis described in our AI and Data Statement.

2.4 Data Collected Automatically

  • Device type, browser, and operating system
  • IP address and approximate geographic location
  • Referring URL and UTM campaign parameters
  • Pages visited, session duration, and interaction data on our website
  • Payment transaction IDs and payment status (not full card details)

2.5 Publicly Available Social Media Data

We collect and analyse publicly available content from Instagram and TikTok to understand our audience and inform our content strategy, including public posts, comments, and engagement metrics from our own @transformwithtoska accounts. We do not collect data from private accounts or private messages on platforms we do not control. We rely on legitimate interests as our legal basis.

2.6 Community Data (Telegram)

When you join Many Butterflies, we collect and process content you share in that community, including messages, reactions, and participation data. By joining you consent to this processing. You may withdraw at any time.

2.7 Member Profiles

We may build a profile of your engagement with our services by combining data from the sources above. This includes your participation history, communication patterns, community activity, and programme enrolment. This profiling is used to personalise your experience, improve our services, and inform the content and programmes Toska creates. It is never used for automated decision-making that has legal or similarly significant effects on you.

3. How We Use Your Data

  • To deliver services: processing payments, providing access to workshops and programmes, maintaining your membership
  • To communicate with you: transactional messages, community updates, marketing emails (consent only)
  • To improve our services: analysing usage, communications, recordings, and community data to improve programmes, content, and platform quality
  • To build audience intelligence: using public social data and internal analytics to understand what our audience needs
  • To fulfil legal obligations: tax records, compliance with UK and applicable law
  • To resolve disputes and enforce our terms: retaining communications records as required

4. Legal Bases for Processing

  • Contract: delivering services you have purchased
  • Consent: marketing emails, newsletter, recording of live sessions
  • Legitimate interests: analytics, public social media analysis, communications improvement, fraud prevention, service quality, member profiling for service personalisation
  • Legal obligation: tax records and regulatory compliance

5. Waitlist and Unconverted Subscribers

If you join our waitlist or newsletter and do not subsequently purchase a service, we will retain your data for a maximum of 3 years from your last interaction with us. After this period your data will be deleted unless you have an active subscription or purchase history.

6. Who We Share Your Data With

We do not sell your personal data. We share data only with processors acting on our behalf, including Stripe and GoCardless (payments), Loops (email), Zoom (live sessions), Supabase, Render and Vercel (infrastructure), Telegram (community), and analytics providers. All processors are bound by data processing agreements.

7. International Data Transfers

Some processors are based in the United States. We ensure appropriate safeguards including standard contractual clauses approved by the UK ICO.

8. AI and Automated Processing

We use AI-assisted tools in our platform operations. See our AI and Data Statement for full details.

9. Data Retention

  • Account and membership data: duration of membership plus 2 years
  • Purchase and billing records: 6 years (tax law)
  • Session recordings and transcripts: duration of programme availability plus 1 year, or as stated at point of purchase
  • Email and communications records: 3 years from last interaction
  • Community content: duration of community operation unless deletion is requested
  • Waitlist and unconverted subscribers: 3 years from last interaction
  • Social media analytics: aggregated and anonymised after 12 months

10. Your Rights

Under UK GDPR you have the right to access, correct, delete, or port your personal data; object to processing on legitimate interests grounds; withdraw consent; and lodge a complaint with the ICO at ico.org.uk or 0303 123 1113. Contact us at hello@transformwithtoska.com to exercise any right.

11. Cookies

We use essential and analytics cookies. You can manage preferences through your browser settings.

12. Changes

Material changes will be notified by email to active members. The current version is always at transformwithtoska.com/privacy.