David Henzell Sobriety

I care about your privacy. If you're engaging with myself and have nothing better to do - these are for you.

Effective Date: 11.10.2025

Last Updated: 11.01.2026

‍Phenomenal Sobriety Limited ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our website and participate in our programs.

1. Introduction

Welcome to Phenomenal Sobriety. Your privacy matters deeply to us, especially given the sensitive and personal nature of recovery work. This Privacy Policy outlines our practices regarding your information and your rights under applicable data protection laws including the UK GDPR.2.

Information We Collect

‍2.1 Personal Information You Provide Directly:

‍When you interact with our website and programs, we may collect:

Name
Email address
Phone number (if provided)
Billing address
Payment information (processed securely through our payment provider)
Account credentials (username and password)
Program participation data (responses to exercises, worksheets, journal entries, reflections)
Communication with us (emails, support requests, feedback)
Any information you choose to share in community spaces, group calls, or coaching sessions

‍2.2 Information Collected Automatically:

‍We may also collect non-personal information including:

Browser type and version
Operating system
IP address and general location data
Device information
Cookie data
Usage data (pages visited, time spent on site, features accessed)
Login and access timesInteraction with program content

3. How We Use Your Information

We use the collected information for various purposes:

‍Program Delivery:

To provide access to program content, workbooks, resources, and community features

‍Account Management:

To create and maintain your account, process payments, manage subscriptions

‍Service Provision:

To provide and maintain our service and notify you about changes

‍Customer Support:

To respond to your questions and provide assistance

‍Payment Processing:

To process your payments securely

‍Communication:

To send program updates, coaching support, and important notices

‍Improvement: To analyse usage patterns and improve program content and user experience

‍Security: To detect and prevent fraud, unauthorised access, and other security issues

‍Marketing: To send you marketing and promotional communications (with your consent)

‍Legal Compliance:

To comply with applicable laws and regulations

4. Legal Basis for Processing (UK GDPR Compliance)

We process your personal information based on:

‍Contract Performance:

Processing necessary to provide the program and services you've purchased

‍Consent:

Where you've given explicit consent (e.g., marketing communications, optional program features)

‍Legitimate Interests:

To improve our services, prevent fraud, ensure security, and provide you with the best program experience

‍Legal Obligation:

To comply with applicable laws and regulations

5. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information only in the following limited circumstances:

‍Service Providers and Platform Partners:

Mighty Networks:

Our program delivery platform that hosts your course content and community access

‍Payment processors:

Such as Stripe or PayPal for secure payment processing

‍Email service providers:

For program communications and updates

‍Analytics services:

To understand program usage and improve user experience

‍Cloud storage providers:

For secure data storage

All service providers are contractually obligated to protect your information and use it only for specified purposes.

‍Business Partners:

‍We may share anonymised, aggregated data with trusted business partners for research or improvement purposes. This data cannot identify you personally.

‍Legal Requirements:

‍We may disclose your information when legally required:In response to court orders, subpoenas, or other valid legal requests

To enforce our Terms & Conditions
To protect our rights, property, or safety
To protect the rights, property, or safety of others

‍Business Transfers:

‍In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new owner, who will be required to honour this Privacy Policy.

‍With Your Consent:

‍We may share information with your explicit consent for specific purposes not covered here.

6. Data Security

We implement appropriate technical and organisational security measures to protect your personal information:

Secure data encryption (SSL/TLS) for data transmission
Restricted access to personal information on a need-to-know basis
Secure password protection with encryption
Regular security assessments and updates
PCI-compliant payment processing through trusted providers
Secure backup systems

‍Communication Privacy:

Your privacy is our priority. We use Proton's enterprise-grade encrypted email and storage solutions for sensitive communications. Every message and document is protected with end-to-end encryption, ensuring your information remains confidential and secure. Based in Switzerland under the world's strictest privacy laws, Proton provides an uncompromising level of security that your data deserves.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to:

Provide you with program access for the duration of your subscription or purchase
Comply with legal obligations (typically 6-7 years for financial and business records)
Resolve disputes and enforce our agreements
Fulfill the purposes outlined in this Privacy Policy

After this retention period, we will securely delete or anonymise your information unless we are legally required to retain it longer.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:
Track activity on our website
Hold certain information for functionality
Maintain your login session
Remember your preferences and settings
Analyse usage patterns and improve user experience
Provide personalised content

‍Types of Cookies We Use:

Essential Cookies:

Required for basic website and platform functionality

‍Analytics Cookies:

Help us understand how you use the program and website

‍Preference Cookies:

Remember your settings and choices

‍Marketing Cookies: Used for marketing purposes (with your consent)

You can control cookie settings through your browser preferences, though disabling certain cookies may affect website and program functionality.

9. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

‍Access: Request a copy of the personal information we hold about you
‍Correction: Request correction of inaccurate or incomplete data
‍Deletion: Request deletion of your personal information (subject to legal retention requirements)
‍Restriction: Request restriction of processing in certain circumstances
‍Portability: Request transfer of your data to another service in a structured, commonly used format (where technically feasible)
‍Object: Object to processing based on legitimate interests
‍Withdraw Consent: Withdraw consent for processing where we rely on your consent
‍Opt-out of Marketing: Unsubscribe from marketing communications at any time using the unsubscribe link in emails

To exercise these rights, please contact us at hello@phenomenalsobriety.com. We will respond to your request within 30 days (one month) as required by UK GDPR.

10. International Data Transfers

Your information may be transferred to and processed in countries other than the United Kingdom. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

Standard contractual clauses approved by relevant authorities
Ensuring service providers maintain adequate data protection standards equivalent to UK GDPR
Implementing technical and organisational security measures

11. Children's Privacy

Our service is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from someone under 18, we will delete it promptly. If you believe we have collected information from a minor, please contact us immediately.

12. Third-Party Links

Our website and program may contain links to external websites or resources. This Privacy Policy does not apply to those third-party sites, and we are not responsible for their privacy practices or content. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. We will notify you of significant changes by:

Posting the updated policy with a new effective date on this page
Sending email notification to active program participants for material changes
Displaying a prominent notice on our website or platform
Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

‍Email: hello@phenomenalsobriety.com