PRIVACY POLICY
Last updated: 20/02/2026
# Privacy Policy
Last updated: [20/02/2026]
## 1. Introduction
Welcome to Divine Alchemy.
We are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable French data protection laws.
This Privacy Policy explains how we collect, use, store and protect your information when you use our website, enroll in our online programs, access the student platform hosted on Ivorey, or participate in 1:1 coaching sessions.
By using this website or our services, you agree to this Privacy Policy.
## 2. Data Controller
Data controller: Divine Alchemy
Email: [email protected]
Country: France
## 3. Data We Collect
### Information you provide directly
When you register, purchase, or contact us, we may collect:
- Name and surname
- Email address
- Billing information
- Payment confirmation details (payment data is processed securely by external payment providers — we do not store card numbers)
- Messages you send us
- Information voluntarily shared during coaching sessions or community participation
### Information related to program participation
When accessing the student platform and community space, we may collect:
- Login credentials
- Course progress and activity
- Comments, posts and interactions within the community
### Automatically collected data
When visiting the website:
- IP address
- Browser and device type
- Pages visited and navigation data
- Cookies and analytics data
## 4. Purpose of Processing
We process your personal data only when legally permitted and for the following purposes:
- Provide access to purchased programs
- Deliver coaching sessions
- Manage your student account
- Communicate service and program information
- Provide customer support
- Improve the learning experience and website performance
- Prevent fraud or misuse
- Comply with legal and accounting obligations
We never sell your personal data.
## 5. Legal Basis (GDPR Article 6)
Your data is processed under the following legal bases:
- Contractual necessity — to provide purchased services
- Legitimate interest — to ensure platform security and improve services
- Consent — for optional communications such as newsletters
- Legal obligation — accounting and tax compliance
## 6. Coaching Confidentiality
During 1:1 sessions you may voluntarily share personal information.
This information is treated as confidential and is never shared with third parties unless required by law.
Coaching services provided through Divine Alchemy are educational and supportive in nature and do not replace psychological, medical or therapeutic care. Please seek apprpriate help if needed by contacting Mental Health Services or Medical Services around you.
## 7. Hosting of Programs & External Platforms
Our courses and community are hosted on the learning platform Ivorey.
When you enroll in a program, your data (such as name, email address, login activity, course progress and community interactions) is processed and stored on Ivorey servers for the sole purpose of delivering the service you purchased.
Ivorey acts as a data processor under Article 28 GDPR and processes personal data only on our documented instructions necessary to operate the training platform.
By enrolling in our programs, you acknowledge that your data may be processed by this external platform for service delivery purposes.
## 8. Third-Party Service Providers
We use trusted third-party providers to operate our services, including:
- Payment processors (e.g. Stripe, PayPal or equivalent)
- Email communication services
- Website hosting and analytics services
- The Ivorey learning platform
These providers act as data processors and process personal data only as required to provide their services in compliance with GDPR.
## 9. Data Retention
We retain personal data only as long as necessary:
- Customer account: duration of service relationship
- Billing information: up to 10 years (French accounting law)
- Support communications: up to 3 years after last contact
You may request deletion at any time unless legal obligations require retention.
## 10. Your Rights
Under GDPR, you have the right to:
- Access your personal data
- Rectify inaccurate data
- Request erasure
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent at any time
To exercise your rights, contact: [email protected]
You may also lodge a complaint with the CNIL (French Data Protection Authority).
## 11. Cookies
Cookies are used to ensure proper website functionality and analyze traffic.
You can control or disable cookies through your browser settings.
## 12. Data Security
We implement appropriate technical and organizational measures provided by Ivorey to protect your personal data.
However, no method of online transmission can be guaranteed fully secure.
## 13. Changes to this Policy
We may update this Privacy Policy at any time.
The latest version will always be available on this page.
## 14. Contact
For any privacy-related questions:
