Privacy Notice

1. Who Is Responsible for Your Personal Information?

The data controller is:

HU BY COACH BRUNO ANJOS, LDA
Trading as Holistic-U

NIF: 517378639

Rua Cidade de Portimão, n.º 15, R/C Esquerdo
5000-050 Vila Real
Portugal

Email:

[email protected]

For privacy-related questions or requests, please contact us using this email address.

2. Who This Privacy Notice Applies To

This Privacy Notice may apply to you if you:

• visit the Holistic-U website;
• contact Holistic-U;
• subscribe to emails or content;
• apply for or enquire about coaching;
• become an Areté coaching client;
• participate in S.O.U.L.Print or another Holistic-U experience;
• complete assessments, questionnaires or forms;
• purchase a Holistic-U product or service;
• participate in a coaching session;
• communicate with Coach Bruno;
• provide a testimonial or Story of Becoming;
• otherwise interact with Holistic-U.

3. What Information We May Collect

Depending on your relationship with Holistic-U, we may collect different types of personal information.

Identification and Contact Information

This may include:

• name;
• email address;
• telephone number;
• address;
• country or location;
• preferred method of communication.

Coaching and Personal Development Information

Where relevant to the service you choose to receive, this may include information about:

• goals and ambitions;
• challenges;
• habits and routines;
• lifestyle;
• performance;
• work or career;
• relationships;
• personal priorities;
• reflections;
• assessments;
• progress;
• actions and outcomes;
• information voluntarily shared during coaching.

Health, Fitness and Well-Being Information

Where relevant to coaching, you may choose to provide information concerning:

• health;
• medical conditions relevant to coaching;
• injuries;
• medications relevant to coaching;
• fitness;
• body composition;
• nutrition;
• sleep;
• recovery;
• exercise;
• physical or emotional well-being.

Health information receives additional protection under applicable data-protection law.

Holistic-U does not ask you to disclose sensitive information that is not reasonably relevant to the service being provided.

Other Sensitive Information

Because holistic coaching can involve personal reflection, you may sometimes voluntarily share information relating to other specially protected areas, such as philosophical or religious beliefs.

Holistic-U does not intentionally request such information unless it is genuinely relevant and appropriate to the coaching relationship.

Communications

We may retain relevant communications exchanged through:

• email;
• Kajabi;
• mutually agreed messaging platforms;
• forms;
• coaching platforms;
• other agreed communication channels.

Session Recordings

Where you explicitly consent, Areté coaching sessions may be recorded through Kajabi for the private use of you and Coach Bruno.

You may ask for a particular session not to be recorded and may withdraw consent to future recordings.

Financial and Transaction Information

We may process information connected with:

• purchases;
• invoices;
• payments;
• payment status;
• billing information.

Holistic-U does not intentionally store full payment-card details where those details are processed directly by an external payment provider.

Website and Technical Information

When you use the Holistic-U website, technical information may be processed automatically, such as:

• IP address;
• device type;
• browser;
• pages visited;
• date and time of access;
• cookie or similar technology information;
• website-security and performance data.

4. Why We Use Your Information

We process personal information only where there is an appropriate legal basis.

To Respond to Enquiries

We use information you provide to:

• answer questions;
• discuss potential coaching;
• arrange discovery conversations;
• provide information about Holistic-U services.

This processing may be necessary to take steps at your request before entering a contract or may be based on our legitimate interest in responding to enquiries.

To Provide Coaching and Other Services

We use relevant information to:

• deliver Areté coaching;
• deliver S.O.U.L.Print or other Holistic-U experiences;
• understand your goals and circumstances;
• personalize coaching;
• communicate with you;
• track agreed progress;
• provide relevant resources;
• administer the client relationship.

Where this information is necessary to deliver the service you purchased, processing is generally based on performance of our contract with you.

Health and Other Special-Category Information

Where the provision of coaching involves health information or another category of personal information that requires additional protection, Holistic-U will use an appropriate lawful condition under applicable data-protection law.

Where explicit consent is relied upon, you will be asked for that consent separately.

You may withdraw consent for future processing at any time.

Withdrawal does not make processing that occurred lawfully before withdrawal unlawful.

Depending on the information involved, withdrawing consent may limit Holistic-U's ability to provide particular elements of coaching safely or effectively.

Session Recordings

Coaching sessions are recorded only where you have provided explicit consent.

Recordings are used for private coaching-related purposes and client access.

A coaching recording will not be used for advertising, testimonials, social media or other promotional purposes without separate permission.

Payments, Accounting and Legal Obligations

We may process and retain information to:

• issue invoices;
• receive payment;
• maintain accounting records;
• comply with tax obligations;
• meet other legal requirements.

Processing is based on the performance of our contract and/or compliance with applicable legal obligations.

Email Marketing and Newsletters

Where required, marketing communications are sent on the basis of your consent.

You may unsubscribe at any time through the unsubscribe mechanism in the email or by contacting Holistic-U.

Unsubscribing from marketing does not prevent Holistic-U from sending administrative communications necessary for an active service or contractual relationship.

Testimonials and Stories of Becoming

Holistic-U will not use your:

• name;
• photograph;
• video;
• testimonial;
• transformation story;
• coaching recording;
• case study;
• before-and-after material

for promotional purposes simply because you are a client.

Separate permission will be obtained.

Where consent is the basis for such use, that consent may be withdrawn for future use, subject to reasonable practical limitations relating to material that has already lawfully been published or distributed.

Business Administration, Security and Legal Claims

Some information may be processed where reasonably necessary to:

• administer Holistic-U;
• maintain service security;
• prevent misuse;
• establish, exercise or defend legal claims;
• comply with lawful requests.

Where appropriate, this may be based on legal obligations or legitimate interests, taking your rights and privacy into account.

5. Sensitive Information and Data Minimisation

Holistic-U follows a principle of collecting what is useful and necessary, rather than everything that could possibly be collected.

You are not expected to disclose your entire medical, psychological or personal history.

Where sensitive information is relevant, we aim to collect only what is reasonably necessary to understand your circumstances and provide the service responsibly.

6. Session Notes

Coach Bruno may maintain limited coaching notes where helpful for continuity, progress and preparation.

These notes are intended to support the coaching relationship and should contain only information reasonably relevant to that purpose.

They are not medical or psychological records.

7. Who May Receive Your Information?

Holistic-U does not sell your personal information.

Information may be accessed or processed where reasonably necessary by service providers that help us operate the business, including categories such as:

• Kajabi, for website, coaching, digital products, communications and client delivery;
• payment providers;
• email and communication providers;
• accounting and invoicing professionals or systems;
• IT, hosting, cloud-storage or security providers;
• professional advisers where reasonably necessary;
• public authorities where disclosure is legally required.

Service providers are given access only to information relevant to the services they provide and are expected to process personal data in accordance with applicable privacy and security obligations.

8. International Data Transfers

Some of the technology used by Holistic-U may involve personal information being processed outside Portugal or outside the European Economic Area.

Where international transfers occur, Holistic-U will seek to ensure that an appropriate legal mechanism is used as required by applicable data-protection law.

Depending on the destination and provider, this may include:

• an adequacy decision recognized under European data-protection law;
• appropriate contractual safeguards;
• another lawful transfer mechanism.

You may contact Holistic-U if you would like further information about international transfers relevant to your personal data.

9. How Long We Keep Information

Holistic-U does not intend to retain personal information indefinitely.

Different information may be retained for different periods depending on why it was collected.

Enquiries That Do Not Become Clients

Information relating to an enquiry will normally be retained for up to 24 months after the last meaningful interaction, unless there is a reason to retain it for longer or you request deletion earlier where applicable.

Coaching and Client Records

Relevant coaching and client administration records will normally be reviewed after the coaching relationship ends and retained only for as long as reasonably necessary.

Non-financial coaching records will normally be deleted or anonymised no later than five years after the end of the coaching relationship, unless:

• they are no longer needed sooner;
• a legal requirement requires longer retention;
• they are reasonably required in connection with a legal claim;
• another legitimate reason applies.

Particularly sensitive information should be deleted earlier where it is no longer reasonably necessary.

Session Recordings

Areté recordings are intended primarily to support the active coaching relationship.

Unless otherwise agreed or reasonably necessary, recordings will normally be deleted from Holistic-U's active records within 90 days after completion or termination of the coaching relationship.

Clients are responsible for retaining any personal copies they wish to keep where the platform permits this.

Accounting and Transaction Information

Invoices, transaction records and other information subject to accounting, tax or other legal retention requirements will be retained for the period required by applicable law.

Marketing Information

Marketing contact information is retained while you remain subscribed or until it is no longer reasonably necessary.

A limited suppression record may be maintained after you unsubscribe so that Holistic-U can respect your request not to receive further marketing.

Consent Records

Where Holistic-U relies on consent, records demonstrating that consent was obtained may be retained for as long as reasonably necessary to demonstrate compliance.

10. How We Protect Your Information

Holistic-U takes reasonable organisational and technical measures to protect personal information against:

• unauthorised access;
• accidental loss;
• inappropriate disclosure;
• alteration;
• misuse;
• destruction.

Information may be stored through Kajabi and locally on devices used by Holistic-U.

Reasonable safeguards should include measures such as:

• password-protected accounts and devices;
• access restrictions;
• appropriate software and system updates;
• secure account authentication where available;
• responsible handling of sensitive information;
• limiting access to those who genuinely need it.

No electronic system can be guaranteed to be completely secure.

If Holistic-U becomes aware of a personal-data breach, it will assess and respond to the incident in accordance with applicable data-protection requirements.

11. Your Privacy Rights

Depending on the circumstances and applicable law, you may have the right to:

Access

Ask whether Holistic-U processes personal information about you and obtain access to that information.

Rectification

Ask for inaccurate or incomplete personal information to be corrected.

Erasure

Ask for personal information to be deleted where the legal requirements for erasure apply.

Restriction

Ask for processing to be restricted in certain circumstances.

Data Portability

Receive certain personal information in a structured, commonly used and machine-readable format where the applicable legal requirements are met.

Object

Object to certain processing based on legitimate interests or to direct marketing.

Withdraw Consent

Where processing relies on consent, withdraw that consent at any time for future processing.

Lodge a Complaint

If you believe your personal information has been processed unlawfully, you may lodge a complaint with the Portuguese supervisory authority:

CNPD (Comissão Nacional de Proteção de Dados)

Av. D. Carlos I, 134, 1.º
1200-651 Lisboa
Portugal

Telephone: +351 213 928 400

Email: [email protected]

Website: www.cnpd.pt

12. Exercising Your Rights

To exercise a privacy right, contact:

[email protected]

Please make clear which right you wish to exercise and provide enough information for Holistic-U to identify the relevant records.

Holistic-U may need to verify your identity before disclosing or changing personal information.

Requests are normally handled without charge and within the time limits required by applicable law.

13. Children and Young People

Holistic-U may, in appropriate circumstances, provide coaching to a person under 18.

Where the coaching Client is under 18, Holistic-U requires written consent from a parent or legal guardian as a matter of service policy.

Additional arrangements concerning:

• privacy;
• communication;
• parental involvement;
• session recording;
• confidentiality;
• safety

will be established through the Areté Parent/Guardian Consent & Minor Coaching Addendum.

Holistic-U aims to explain privacy practices to young clients in language appropriate to their age and understanding.

14. Cookies and Similar Technologies

The Holistic-U website may use cookies or similar technologies.

Cookies that are strictly necessary for the operation, security or functionality of the website may be used where permitted without consent.

Where consent is legally required for analytics, advertising or other non-essential technologies, they should be activated only in accordance with the applicable consent choices.

Cookie settings may be made available through the website's cookie or privacy controls.

If Holistic-U materially changes the analytics, advertising or tracking technologies used on the website, this Privacy Notice and any related cookie information should be reviewed accordingly.

15. Automated Decision-Making

Holistic-U does not currently make decisions about coaching clients solely through automated processing where those decisions would produce legal or similarly significant effects.

Technology and AI tools may assist administrative, creative or operational work where appropriate, but meaningful coaching decisions remain subject to human judgment.

Sensitive client information should not be entered into external AI systems unless there is an appropriate privacy basis and suitable safeguards.

16. Changes to This Privacy Notice

Holistic-U may update this Privacy Notice when:

• services change;
• technology changes;
• service providers change;
• legal requirements change;
• privacy practices evolve.

The current version will be published through the Holistic-U website with its effective date.

Where a change materially affects how existing client information is used, additional notice will be provided where appropriate.

17. Contact

Questions about this Privacy Notice or the way Holistic-U handles personal information can be sent to:

HU BY COACH BRUNO ANJOS, LDA
Trading as Holistic-U

Rua Cidade de Portimão, n.º 15, R/C Esquerdo
5000-050 Vila Real
Portugal

NIF: 517378639

Email:

[email protected]