Delvvy LTD (“we”, “us”, or “our”) values the trust you place in us when sharing your personal data. We are committed to being transparent and honest about how we collect, use, and protect your information.

The purpose of this policy is to provide our data subjects (“you” or “your”) with clear information about how we handle personal data, including special category data.

This policy applies to our website and services, covering data we process automatically and through direct communication, as well as data handled by third-party processors.

Please read this policy carefully. By using our website or engaging with our services, you are consenting to the terms outlined here. If you do not accept these terms, please kindly refrain from using our website and services.

Company
Delvvy LTD is registered as a limited company in England and Wales, registration number 15760294.

Data Protection
Delvvy LTD is registered with the Information Commissioner’s Office, registration number ZB802272.

Contact
Our registered office address is 85 Great Portland Street, London, England, W1W 7LT. Our email address is hello@delvvy.com

Data subjects are identified or identifiable individuals to whom personal data relates. Data subjects have the right to access their personal data, request rectification, object to processing, and have their personal data erased.

Our data subjects are individuals who use our website and/or engage with our services.

Rights of Our Data Subjects

Our data subjects have the following rights to their personal data:

Right to access: the right to request the information we hold.
Right to correct: the right to rectify Data if it is inaccurate or incomplete.
Right to erase: the right to request that we delete or remove Data from our systems.
Right to object: the right to object to our use of Data.

Underage Data Subjects

We do not market our website or offer services to underage individuals. We require all individuals engaging with our services to declare they’re over the age of the 18, as outlined in our Safety Policy.

The GDPR defines personal data as any information associated with an individual who can be identified directly or indirectly. This term does not apply to data that has been anonymised.

Personal data encompasses a variety of categories, including:

Identity: Title, name, date of birth.
Profile: Website username, password, and preferences.
Contact: Billing address, email address, telephone numbers.
Financial: Card payment information, bank account details.
Service: Details of services or products purchased.
Technology: IP address, Cookies data.

Our personal data collection includes but is not limited to:

Signing up for an email newsletter on our website:
Creating an account on our website:
Registering for a digital product or service on our website:
Paying for a digital product or service on our website.
Online communication with us.

We use trusted data processors to collect, process, and store personal data. Each processing partner is listed here with a description of our use and a link to their privacy policy.

Squarespace
- Purpose: Website hosting platform that we use to sell digital products and services, run email campaigns, and analytics.
- Privacy Policy: Read here.
Google Workspace
- Purpose: Software that we use for online communication, client scheduling, cloud-based storage, and analytics.
- Privacy Policy: Read here.
Xero
- Purpose: Accounting software that we use for business operations, including bookkeeping, payments, and payroll.
- Privacy Policy: Read here.
Monzo
- Purpose: Online bank that we use for banking operations.
- Privacy Policy: Read here.
Stripe
- Purpose: Payment processing service that we use for digital products and services.
- Privacy Policy: Read here.
WhatsApp
- Purpose: Messaging platform that we use for online communication.
- Privacy Policy: Read here.
LinkedIn
- Purpose: Social media platform that we use for online communication.
- Privacy Policy: Read here.
Instagram
- Purpose: Social media platform that we use for online communication.
- Privacy Policy: Read here.

The UK GDPR designates certain personal data as "special category data," which is more sensitive and requires extra protection. Processing this data requires a valid legal basis and explicit, informed consent from the individual to protect their rights and freedoms.

Special category data includes:

Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Genetic data
Biometric data (used for identification)
Health information
Sex life information
Sexual orientation

What is explicit consent?
Special category data requires explicit consent. Explicit consent must be a clear, specific indication of the individual’s wishes, given through words or written confirmation. This includes but is not limited to signing a document or ticking a consent box.

We may collect special category data to provide sex education and coaching services. In all cases, we will obtain explicit consent before collecting any special category data.

We will only request this data when it is relevant and necessary for the service. Records will only be kept for as long as it is necessary to fulfill the purpose for which it was collected, or as required by law. After that, your data will be securely deleted or anonymized.

We do not share your special category data with third parties unless it is essential for the services we provide or required by law.

You reserve the right to access, correct, or delete your data.

In compliance with the GDPR, we will report any unlawful data breach within 72 hours if we determine that personal data under our control has been compromised or potentially compromised.

In the event of a 'high risk' breach, we will inform all affected data subjects through an appropriate communication method.

We reserve the right to change this Privacy Policy at any time and will inform our data users when we update this policy.

If you disagree with the modified policy, please kindly refrain from using our website and services.

We will always require a written statement of consent when providing services or products that may result in processing personal data and special category data.

All individuals and organizations who book our services or purchase our products must agree to our Privacy Policy and Terms of Service.

If engaging in an interactive community orientated service, such as workshops or events, all participants must sign a confidentiality statement upon registration. If engaging with our coaching services, all clients must sign a client agreement and provide explicit consent for the processing of special category data.

As our data users, you have the right to withdraw your consent at any time. If you no longer wish for us to process your personal data or special category data, please contact us and we will delete all of your data we have on record.

If you do not agree to the terms outlined in this policy, please do not engage with our website, services, or products.

If you have questions about this policy, you can contact us via email:

hello@delvvy.com