PRIVACY POLICY

Effective date: 21st October 2026

1. Introduction

Welcome to Transmute Yourself Coaching.

Javier Andres Penalba Barreto, trading as Transmute Yourself Coaching, sole trader (Einzelunternehmer), Mühlwiese 14, 65779 Kelkheim (Taunus), Germany (“we”, “us”, “our”) operates the website www.transmuteyourself.com (“Service”).

This Privacy Policy explains how we collect, use, store and disclose personal data when you visit our Service, subscribe to our newsletter, take part in our research surveys, or book coaching. It is written to comply with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), the UK GDPR and the UK Data Protection Act 2018 where they apply to you.

Our Terms and Conditions (“Terms”) apply to all use of the Service. Together, the Terms and this Privacy Policy form your agreement with us. Terms used in this Privacy Policy have the same meanings as in the Terms.

​Language: This Privacy Policy is available in English and German. The German version is the legally binding version. The English version is provided for your convenience only. If the two versions differ in meaning, the German version prevails. You can read the German version here.

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2. Definitions

• Personal data means any information about an identified or identifiable person.

• Usage data means information generated by using the Service or by the Service’s infrastructure, such as the duration of a page visit.

• Cookies are small files stored on your device.

• Data controller means the person who decides why and how personal data is processed. For the purposes of this Privacy Policy, we are the data controller.

• Service providers are third parties who process personal data on our behalf.

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3. Information collection and use

We collect personal data only where it is needed to run the Service, respond to you, provide coaching, send newsletters you have subscribed to, and carry out research you have chosen to take part in.

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4. Types of data we collect

Personal data you give us. Depending on what you do, this may include your name, email address, phone number, billing address and country, your booking details, your payment details (handled by our payment provider, see section 13), and your answers to surveys and coaching enquiries.

Usage data. When you visit the Service, your browser sends information such as your IP address, browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type and operating system, and device identifiers. We collect this to keep the Service secure and working.

Cookies and similar technologies. See section 11.

Survey data. See section 5B.

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5. Use of data

We use personal data to provide and maintain the Service; to respond to your enquiries and provide coaching; to process bookings and payments; to send newsletters, but only if you have subscribed; to conduct research, but only if you choose to take part; to keep the Service secure and detect technical problems; to measure how the Service is used, but only where you have consented to analytics cookies; to comply with legal obligations, including tax and accounting rules; and to enforce our rights under our agreements with you.

5A. Legal basis for processing

Where we process your data to provide coaching or process a booking, the legal basis is the performance of a contract (Article 6(1)(b) GDPR). Where we send you newsletters, use analytics or marketing cookies, or run research surveys, the legal basis is your consent (Article 6(1)(a) GDPR), which you can withdraw at any time. Where we must keep invoices and tax records, the legal basis is a legal obligation (Article 6(1)(c) GDPR). Where we keep the Service secure and run its basic technical operation, the legal basis is our legitimate interest (Article 6(1)(f) GDPR). If you share information about your health or other special category data with us during coaching or a survey, the legal basis is your explicit consent (Article 9(2)(a) GDPR), and we treat that information as sensitive.

If you live in the United Kingdom, the UK GDPR and the Data Protection Act 2018 apply in the same way.

Withdrawing consent does not affect processing carried out before you withdrew it.

5B. Surveys and research

We may invite you to take part in surveys or interviews about how people experience success, life choices and change. Taking part is voluntary. We collect your answers and, only if you choose to give them, your name and email address.

We use your answers to understand people’s experiences and to develop our coaching services. We report them only in aggregate or anonymised form. We will not publish identifiable responses or quote you without your permission.

Your name and email address are used only for the follow-up options you select, such as a follow-up research conversation or updates about future coaching programmes. Providing contact details does not subscribe you to newsletters or marketing emails.

Survey research may lead to an invitation to a coaching programme. Taking part does not commit you to anything.

Please do not include sensitive health information or identifying details about other people in your answers.

We collect survey answers using Google Forms and store them in Google Drive, as described in section 12.

The survey may ask about your age range, gender, professional situation, role or field, and approximate income. Gender is optional, and you can choose “Prefer not to say”. We use these details only to analyse results for our own research and to develop our coaching services. We do not identify individuals in our analysis. If we publish findings, we will use aggregated figures only.

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6. Retention of data

We keep personal data only for as long as needed for the purposes described in this Privacy Policy.

Survey answers without contact details are anonymised and may be kept for analysis without a time limit, because they can no longer be linked to you.

Survey answers that include your name or email address are deleted within 12 months, or once any follow-up you chose is complete, whichever comes first.

Contact requests and enquiries sent by email are deleted within 12 months after our last contact.

Newsletter subscriber data is kept until you unsubscribe.

Booking, invoice and payment records are kept for 10 years, as required by German tax law.

Website analytics data collected through Google Analytics is kept for 14 months, which is the retention period we have set in Google Analytics.

Usage data for security purposes is kept only as long as needed to protect the Service.

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7. Transfer of data

Your information may be transferred to, and processed on, computers located outside your country of residence, where data protection laws may differ.

Our website and our data are hosted and processed in Germany and by service providers within the EU. Some of our service providers process data in the United States, as described in section 12. Where data is transferred outside the EU or the UK, we rely on the safeguards those providers offer, such as the EU-US Data Privacy Framework or Standard Contractual Clauses.

Your consent to this Privacy Policy, followed by your submission of information, represents your agreement to that transfer, where consent is the legal basis.

We take reasonable steps to make sure your data is treated securely and in accordance with this Privacy Policy.

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8. Disclosure of data

We may disclose personal data:

to comply with a legal obligation or a valid request from a public authority;

if our business is involved in a merger, acquisition or sale of assets, in which case your data may be transferred under the same protections;

to our service providers listed in section 12, only to the extent needed for the services they provide to us;

to protect our rights, property or safety, or that of our clients or others; or

with your consent in any other case.

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9. Security of data

The security of your data is important to us, but no method of transmission over the internet or method of electronic storage is 100% secure. We use commercially reasonable measures to protect your personal data, and our website is accessed over an encrypted connection.

10. Your data protection rights

If you live in the United Kingdom, the European Union or the European Economic Area, you have the following rights under the UK GDPR, the EU GDPR and related laws:

the right of access (Article 15 GDPR), to receive a copy of the personal data we hold about you;

the right to rectification (Article 16 GDPR), to have inaccurate or incomplete data corrected;

the right to erasure (Article 17 GDPR), to have your data deleted in certain circumstances;

the right to restriction of processing (Article 18 GDPR);

the right to data portability (Article 20 GDPR), to receive your data in a structured, machine-readable format;

the right to object to processing (Article 21 GDPR), including direct marketing; and

the right to withdraw consent at any time, where we rely on your consent.

To use these rights, email us at javier.penalba@transmuteyourself.com. We may ask you to verify your identity first.

If you gave us an email address when taking part in a survey, we can find and delete your response. Survey responses submitted without contact details are anonymous, so we cannot identify them afterwards and cannot delete them on request.

You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, this is the Information Commissioner’s Office (ico.org.uk). In Germany, the authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information (datenschutz.hessen.de). You can also contact the authority in your country of residence.

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11. Cookies

We use cookies and similar technologies on our website. Cookies are small files that a website stores on your device. Some are necessary for the website to work. Others are used for analytics, marketing or embedded content, and are set only if you accept them.

When you first visit the website, a cookie banner asks for your choice. Choose Accept all to allow analytics and marketing cookies, or Decline all to use only the cookies the website needs. You can change your choice at any time in Cookie Settings, which you can open from the website. Where your choice is “Decline all”, we do not set analytics or marketing cookies, except those the Service needs to work.

Necessary cookies are needed for the Service to work, for example for security and to remember your cookie choice. These do not require consent.

Analytics cookies are set by Google Analytics, connected through Wix, to show us how the Service is used. These are set only if you accept analytics cookies. Google Analytics cookies include cookies such as _ga and ga[ID].

Marketing cookies are set by Meta (Facebook) through its pixel, which we have installed to measure the effectiveness of future advertising. These are set only if you accept marketing cookies. Meta cookies include cookies such as _fbp and _fbc.

Embedded content includes:

the newsletter sign-up forms from AWeber on our Home, Contact and Work With Me pages, which may set cookies from AWeber, as described in section 12;

the booking calendar from Calendly, embedded on our pages, which sets its own cookies, as described in section 12;

videos from YouTube, embedded on our About and Video Library pages, which may set YouTube and Google cookies when the video loads, such as cookies named VISITOR_INFO1_LIVE and YSC; and

any reviews we display through third-party widgets, such as Trustpilot or Wix reviews, which may set cookies from those services.

Some of these cookies may be set as soon as the page loads, before you have made a choice in the cookie banner. The cookie banner does not control these cookies. You can block them in your browser settings at any time, but some parts of the website may not work as intended.

You can also control cookies in your browser settings. Blocking all cookies may affect how the website works.

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12. Service providers

We use the following service providers to run our business. Each processes personal data only on our instructions and under a contract that meets the requirements of the GDPR.

Wix.com (website hosting, website builder, cookie banner and built-in analytics). Wix processes data in accordance with its privacy policy, which you can read at wix.com.

Google (Google Analytics, Google Forms and Google Drive). Google may process data in the United States and other countries, using the safeguards it provides. You can read Google’s privacy policy at policies.google.com.

AWeber Systems, Inc. (newsletters and sign-up forms). AWeber is based in the United States and complies with the EU-US Data Privacy Framework. AWeber sets cookies on pages where its sign-up forms are embedded. These cookies fall into the categories of necessary, analytics and service providers, advertising and social media, as described in AWeber’s privacy policy. You can read AWeber’s privacy policy at aweber.com/privacy.htm.

Calendly (booking calls). Calendly sets session and persistent cookies on pages where its calendar is embedded, and asks EU visitors for consent. You can read Calendly’s privacy notice at calendly.com/legal/privacy-notice.

Meta Platforms, Inc. (Facebook marketing pixel). Meta is based in the United States. We use its pixel only if you accept marketing cookies. You can read Meta’s privacy policy at facebook.com/privacy.

YouTube and Google (embedded videos). Embedded videos may set YouTube and Google cookies when they load, as described in section 11. You can read YouTube’s privacy policy at youtube.com/t/privacy.

Trustpilot (customer reviews). If we display Trustpilot reviews or a Trustpilot widget, Trustpilot may set cookies and process data as described in its privacy policy at trustpilot.com/privacy-policy.

Stripe (card payments), described in section 13.

PayPal (payments). PayPal processes payment data under its own privacy statement, and it may process data outside the EU using the safeguards it provides. You can read PayPal’s privacy statement at paypal.com/privacy.

We may also use other service providers in future, and we will update this Privacy Policy when we do.

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13. Payments

We accept card payments through Stripe, payments through PayPal, and bank transfers. Card and PayPal payment details are entered and processed directly by Stripe or PayPal, and we do not store them. Stripe and PayPal may process your payment data outside the EU, using the safeguards they provide. You can read Stripe’s privacy policy at stripe.com/privacy and PayPal’s privacy statement at paypal.com/privacy. For bank transfers, we keep the details needed to match your payment to your booking and to meet our tax and accounting obligations, as described in section 6.

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14. Links to other sites

Our Service may contain links to other websites that we do not operate. If you click a third-party link, you will be taken to that site, and its privacy policy will apply. We strongly advise you to read the privacy policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies or practices of third-party sites or services.

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15. Children’s privacy

Our Service and coaching services are intended only for people aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, please contact us at javier.penalba@transmuteyourself.com, and we will delete it.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the new version on this page and update the effective date at the top. Where a change is significant, we will tell you by email or with a prominent notice on the Service before it takes effect.

17. Contact us

If you have any questions about this Privacy Policy, please contact us at javier.penalba@transmuteyourself.com.

Javier Andres Penalba Barreto, trading as Transmute Yourself Coaching, Mühlwiese 14, 65779 Kelkheim (Taunus), Germany.