DEEPER PRIVACY POLICY
Deeper Group Ltd ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our wellness community platform, courses, and services.

**Company Details:**
- Company Name: Deeper Group Ltd
- Registration: United Kingdom
- Contact: info@deepergroup.org
- Website: www.deeper.group

## 2. INFORMATION WE COLLECT

### 2.1 Personal Information
- Name and contact details (email, phone, address)
- Payment information (processed securely through third-party providers)
- Profile information and preferences
- Course progress and completion data
- Community participation and content contributions

### 2.2 Technical Information
- IP addresses and device information
- Browser type and version
- Usage data and analytics
- Cookies and similar tracking technologies
- Log files and error reports

### 2.3 Communication Data
- Messages sent through our platform
- Email communications
- Support inquiries and feedback
- Marketing preferences

## 3. HOW WE USE YOUR INFORMATION

### 3.1 Service Provision
- Manage your membership (Explorer, Pathfinder, Wayfinder tiers)
- Provide access to courses and community features
- Process payments and manage subscriptions
- Facilitate connections between members and practitioners

### 3.2 Communication
- Send service-related notifications
- Provide customer support
- Share wellness content and course updates
- Marketing communications (with consent)

### 3.3 Platform Improvement
- Analyze usage patterns and preferences
- Improve our services and user experience
- Develop new features and content
- Ensure platform security and prevent fraud

## 4. LEGAL BASIS FOR PROCESSING (GDPR)

We process your personal data based on:
- **Contract Performance**: To provide our services and fulfill membership agreements
- **Legitimate Interests**: To improve our services, prevent fraud, and ensure security
- **Consent**: For marketing communications and optional features
- **Legal Obligations**: To comply with applicable laws and regulations

## 5. DATA SHARING AND DISCLOSURE

### 5.1 Third-Party Service Providers
We may share data with trusted partners:
- **Mighty Networks**: Community platform hosting
- **ConvertKit**: Email marketing and automation
- **Payment Processors**: Secure payment handling
- **Analytics Providers**: Usage analysis and insights

### 5.2 Practitioners and Thought Leaders
- Course enrollment and progress data (with consent)
- Community interaction data relevant to their services
- Contact information for direct communication (with permission)

### 5.3 Legal Requirements
We may disclose information when required by law, court order, or to protect our rights and safety.

## 6. DATA RETENTION

We retain your personal data for:
- **Active Members**: Duration of membership plus 7 years for financial records
- **Former Members**: Up to 3 years for legitimate business purposes
- **Marketing Data**: Until consent is withdrawn or data becomes outdated
- **Legal Requirements**: As required by applicable laws

## 7. YOUR RIGHTS (GDPR)

You have the right to:
- **Access**: Request copies of your personal data
- **Rectification**: Correct inaccurate or incomplete data
- **Erasure**: Request deletion of your data ("right to be forgotten")
- **Portability**: Receive your data in a structured format
- **Restriction**: Limit how we process your data
- **Objection**: Object to processing based on legitimate interests
- **Withdraw Consent**: For consent-based processing

To exercise these rights, contact us at [Insert contact email].

## 8. COOKIES AND TRACKING

### 8.1 Cookie Types
- **Essential Cookies**: Required for platform functionality
- **Analytics Cookies**: Help us understand usage patterns
- **Marketing Cookies**: For targeted advertising and content

### 8.2 Cookie Management
You can control cookies through your browser settings. Note that disabling certain cookies may affect platform functionality.

## 9. DATA SECURITY

We implement appropriate security measures including:
- Encryption of data in transit and at rest
- Regular security assessments and updates
- Access controls and authentication
- Staff training on data protection
- Incident response procedures

## 10. INTERNATIONAL TRANSFERS

If we transfer data outside the UK/EU, we ensure adequate protection through:
- Adequacy decisions
- Standard contractual clauses
- Binding corporate rules
- Other approved mechanisms

## 11. CHILDREN'S PRIVACY

Our services are not intended for children under 16. We do not knowingly collect personal data from children. If we become aware of such collection, we will delete the information promptly.

## 12. MARKETING COMMUNICATIONS

### 12.1 Consent
We only send marketing emails with your consent. You can:
- Opt-out using unsubscribe links
- Update preferences in your account settings
- Contact us directly to modify communications

### 12.2 Types of Communications
- Wellness tips and educational content
- New course announcements
- Community updates and events
- Special offers and promotions

## 13. MEMBER AND PRACTITIONER SPECIFIC PROVISIONS

### 13.1 Members (Explorer, Pathfinder, Wayfinder)
- Course progress tracking and recommendations
- Community interaction data
- Personalized wellness content
- Connection facilitation with practitioners

### 13.2 Practitioners and Specialists
- Professional credentials and background check data
- Course creation and management tools
- Revenue and performance analytics
- Member interaction data (anonymized where possible)

## 14. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. We will:
- Notify you of significant changes via email
- Post updates on our platform
- Maintain previous versions for reference
- Provide reasonable notice before changes take effect

## 15. COMPLAINTS AND CONCERNS

If you have concerns about our data handling:
1. Contact us directly at [Insert contact email]
2. Contact the UK Information Commissioner's Office (ICO)
3. Seek legal advice if necessary

## 16. CONTACT INFORMATION

**Data Protection Officer/Privacy Contact:**
Deeper Group Ltd
[Insert full address]
Email: [Insert privacy email]
Phone: [Insert phone number]

**Regulatory Authority:**
Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113

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## APPENDIX: DEFINITIONS

- **Personal Data**: Any information relating to an identified or identifiable person
- **Processing**: Any operation performed on personal data
- **Controller**: The entity that determines purposes and means of processing
- **Processor**: The entity that processes data on behalf of the controller

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