Last Updated: 30.1.2025
This Privacy Policy applies to the websites and any related subdomains operated by Elative Solutions OÜ, under the brands CoachSuite Pro, Elative Solutions, ElativeOne, and Karolina Blaszkiewicz - Awakening The Soul's Light, including but not limited to coachsuite.pro, elative.io, elative.solutions, elative.one, karolinab.com, and karolinablaszkiewicz.com, as well as any associated subdomains of these sites.
It also applies to any memberships, services, and/or products offered through these websites (collectively referred to as the "Sites").
Elative Solutions OÜ is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, and protect your data when you visit our Sites or use our services.
By using the Sites, you acknowledge that you have read and accepted this Privacy Policy. If you do not agree, please discontinue using our Sites immediately.
Elative Solutions OÜ, a company registered in Estonia, acts as the Data Controller for personal data collected through our Sites. We are committed to protecting your privacy and ensuring compliance with GDPR (General Data Protection Regulation), CCPA (California Consumer Privacy Act), CPRA (California Privacy Rights Act), and PIPEDA (Personal Information Protection and Electronic Documents Act - Canada).
If you have any questions regarding your privacy, you may contact us at:
We collect personal data, including but not limited to contact information, customer transaction details, user data, technical data, and marketing preferences. We gather this data through direct interactions (such as when you sign up, purchase, or contact support), automated tracking (cookies and analytics), third-party service integrations, and publicly available sources.
Under GDPR, we process data based on contractual necessity, legitimate interest, consent, and legal obligations.
Personal data means any information capable of identifying an individual. It does not include anonymized data.
We may process the following categories of personal data about you:
Communication Data: This includes any communication that you send to us, whether that be through the contact form on our website, email, text, social media messaging, or any other communication method. We process this data for the purposes of responding to inquiries, record-keeping, and legal compliance.
Customer Data: This includes details related to purchases, such as your name, billing address, delivery address, email address, phone number, and payment details. We process this data to supply the goods and/or services you have purchased and to maintain transaction records.
User Data: This includes data about how you use our website, including interactions with content, session history, and engagement levels. We process this data to improve the user experience and platform functionality.
Technical Data: This includes IP addresses, login data, browser details, session lengths, device information, and analytics tracking. This helps us optimize our website and detect security threats.
Marketing Data: This includes preferences regarding marketing communications, promotions, and advertising preferences.
Phone Numbers & AI Communications: If you provide your phone number, we may use it to send SMS messages or WhatsApp Messages or AI-generated outbound communications based on your preferences.
We do not collect sensitive personal data, including race, ethnicity, religious beliefs, biometric data, or criminal records.
3. How We Collect Your Personal Data
We collect data about you in the following ways:
Direct interactions: When you provide data through account registration, purchases, newsletters, or customer support.
Automated tracking: When you interact with our website using cookies, tracking pixels, and analytics tools.
Third-party sources: If you connect third-party platforms (e.g., Google, Facebook, Stripe), we may receive relevant user data.
Publicly available sources: Such as business directories or government records.
Our Sites use cookies and other tracking technologies to enhance functionality, improve user experience, and support marketing and analytics.When you first visit, a cookie consent banner allows you to accept or reject non-essential cookies. You can also manage cookie preferences through your browser settings.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website. They help websites remember your preferences, enhance your browsing experience, and improve functionality.Cookies may be first-party cookies (set by our Sites) or third-party cookies (set by third parties such as advertising or analytics providers).
We use the following categories of cookies on our Sites:
We use cookies to:
Some cookies on our Sites are placed by third-party service providers, including but not limited to:
These third parties may use cookies in accordance with their privacy policies. We do not control these cookies and recommend reviewing their respective policies.
You have the right to manage or disable cookies. You can:
If you disable certain cookies, some parts of our Sites may not function correctly.
We only send marketing communications with explicit consent, and we use double opt-in for email subscriptions. You may opt-out at any time by clicking the unsubscribe link in emails or contacting us directly.
SMS Opt-In: By opting in, you agree to receive text messages from us. You can unsubscribe by replying STOP.
Opting out of marketing communications will not affect essential service-related communications.
6. Third-Party Advertising & Marketing (Meta & Google Ads)
We use third-party advertising services, including Meta (Facebook & Instagram Ads) and Google Ads, to promote our products and services. These platforms may collect and process user data through tracking technologies such as:
Facebook Pixel (used for advertising and remarketing on Facebook & Instagram).
Google Ads & Google Analytics (used for performance tracking and personalized ads).
These technologies help us:
Measure the effectiveness of our ads.
Personalize ads based on user interests and website interactions.
Retarget users who have visited our website.
How to Opt-Out of Targeted Ads
If you prefer not to receive personalized advertising, you can opt out through the following methods:
Google Ads Settings: https://adssettings.google.com/
Facebook Ad Preferences: https://www.facebook.com/settings/?tab=ads
Your Online Choices (EU Users - GDPR Compliant): https://www.youronlinechoices.com/
Network Advertising Initiative (NAI) Opt-Out: https://optout.networkadvertising.org/
For California Residents (CCPA/CPRA): If you are a California resident, you have the right to opt out of data sharing for advertising purposes. You may submit a Do Not Sell or Share My Personal Information request at email us at [email protected].
We may share hashed user data with third-party advertising platforms (Meta, Google) for targeted advertising. You can opt out of targeted ads through Google Ad Settings and Meta Ad Preferences.
We implement industry-standard security measures, including data encryption, controlled access, and routine security audits.
We retain personal data for the following periods:
Account & Transaction Data: 6 years (for tax and legal compliance).
Marketing Data: Retained until you unsubscribe or withdraw consent.
Analytics & Behavioral Data: Retained for 12 months, unless removed earlier.
Inactive Accounts: Deleted after 2 years of inactivity, unless required for legal reasons.
Support/Inquiry Data: Retained for 12 months after last contact.
Security Logs (IP Addresses, Login Data): Retained for 6 months for security monitoring.
AI logs are retained for compliance tracking and deleted after 6 months unless required for security or fraud prevention.
Email logs are retained for up to 2 years for legal compliance.
8. International Data Transfers
We operate globally, and your data may be transferred outside the European Economic Area (EEA) to countries including the US, Canada, Australia, and the UK.
We ensure data protection through:
We transfer data outside the EU under Standard Contractual Clauses (SCCs). Where applicable, we implement additional safeguards such as encryption, pseudonymization, and access controls to comply with GDPR and Schrems II requirements.
Legally binding agreements with third-party service providers to ensure GDPR compliance.
California residents have the following rights under CCPA and CPRA:
We do not sell personal data. However, third-party analytics and advertising services may collect data under CCPA definitions.
California residents may opt out by sending an email request to [email protected] with the subject line "CCPA Opt-Out Request" and providing their full name and email address associated with their account. We will process your request within 30 days and confirm once your data has been removed from applicable third-party tracking systems.
Under PIPEDA, Canadian residents have rights, including:
To exercise your rights under PIPEDA, contact us at [email protected].
11. SMS, WhatsApp, & AI-Generated Communications
We may use SMS, WhatsApp, and AI-generated outbound messages to provide service notifications, reminders, marketing promotions, and updates.
By providing your phone number and opting in, you expressly consent to receive SMS and WhatsApp messages from us at the number provided. This may include:
Appointment reminders, service updates, and transaction notifications.
AI-driven responses based on prior inquiries or interactions.
Marketing and promotional messages (if separately consented to).
WhatsApp Communications
If you provide explicit consent to receive messages via WhatsApp, we may send:
Customer service and support messages.
Transactional updates related to purchases or subscriptions.
Marketing and promotional content (if consented).
We use WhatsApp Business API powered by Meta Platforms, Inc., which processes messages outside the EU. Data transfers are governed by Standard Contractual Clauses (SCCs) under GDPR.
We do not sell or share your WhatsApp number with third-party advertisers.
Consent & Opt-Out for WhatsApp & SMS
You can opt out of receiving WhatsApp or SMS messages at any time by:
Replying STOP to any message.
Updating your preferences in your account settings.
Contacting us at [email protected].
For WhatsApp-specific opt-outs, you may also block our number on WhatsApp.
WhatsApp messages may include encryption for security.
WhatsApp messages sent through our business account may be processed by Meta Platforms, Inc. Meta may collect metadata (timestamps, interaction logs) for analytics and compliance. For details, refer to the Meta Privacy Policy.
Legal Compliance
GDPR (EU & UK Users): We obtain explicit consent before sending WhatsApp messages.
CCPA (California Users): You have the right to opt-out of WhatsApp marketing messages.
TCPA (US Users): We comply with FCC regulations, requiring clear opt-in consent before sending WhatsApp messages.
CASL (Canada Users): WhatsApp messages comply with Canada’s Anti-Spam Law (CASL).
Important Note: By opting in to SMS or WhatsApp messages, you provide express consent to receive automated messages. You can opt out at any time by replying STOP or contacting [email protected]. Message and data rates may apply.
12. Use of AI & Automated Processing
We use Artificial Intelligence (AI) and automated technologies to enhance our services, including:
AI-powered chatbots or AI voice call for customer support and inquiries.
Automated SMS, email, and WhatsApp responses based on user queries.
AI-powered analytics for improving service recommendations and marketing strategies.
Personalization & automated decision-making (e.g., content recommendations, behavioral analysis).
Our AI systems may process user data, but we ensure:
AI is used ethically and complies with GDPR, CCPA/CPRA, and other regulations.
Users are informed when interacting with AI-powered systems.
AI does not make decisions with significant legal or financial consequences (unless explicitly stated).
Automated Decision-Making & User Rights
If we use AI to make automated decisions that affect users, you have the following rights under GDPR Article 22 and CCPA/CPRA:
The right to be informed about AI-driven decisions.
The right to request human intervention in AI decision-making.
The right to object to AI-based profiling.
If you wish to exercise these rights, please contact us at [email protected].
AI & Data Privacy Protections
We ensure AI systems comply with privacy and security best practices:
AI does not store personal data beyond necessary processing.
AI does not make autonomous decisions on pricing, eligibility, or account suspension.
AI-driven marketing messages (email, SMS, WhatsApp) follow GDPR & CCPA opt-in rules.
If AI is used to make significant decisions that impact your rights or access to services, you have the right to request human intervention or review of the decision.
Contact us at [email protected].
Under global data protection laws, you have the right to:
Right to Withdraw SMS & AI Message Consent: You may withdraw consent for SMS or AI-generated communications at any time.
For further details, visit: https://edps.europa.eu/data-protection_en
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the EU supervisory authority for data protection issues (https://edps.europa.eu/edps-homepage_en). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
You may exercise your rights by contacting us at [email protected].
We will process valid requests within 30 days. If additional time is needed due to complexity, we will inform you of the delay and the reason for it.
Identity verification may be required before processing certain requests.
Our Sites may contain links to third-party websites, plug-ins, or applications. These third parties may collect personal data independently. We encourage you to read their respective privacy policies, as we are not responsible for their data handling practices.
14.Third-Party Data Sharing
We share personal data with trusted third-party service providers for payment processing, analytics, and marketing. These include:
Google Analytics (website analytics).
Facebook Pixel (advertising analytics).
Stripe & PayPal (payment processing).
Email Marketing Providers (e.g., Mailchimp, ActiveCampaign).
We have Data Processing Agreements (DPAs) with these providers to ensure compliance with GDPR, CCPA, and PIPEDA.
International Data Transfers & Legal Protections:
Google, Facebook, and Stripe operate in the U.S. and may process data outside the EU.
We ensure Standard Contractual Clauses (SCCs) for data transfers, complying with GDPR regulations.
We do not share or sell personal data to third parties for advertising purposes.
We reserve the right to modify this Privacy Policy at any time. Updates will be reflected in the "Last Updated" date at the beginning of this document. Continued use of our Sites after such modifications constitutes acceptance of the revised terms.
16. Contact Us
If you have any questions about this Privacy Policy or wish to make a complaint, contact us at:
Elative Solutions OÜ
Ahtri tn 12, Kesklinna linnaosa, Harju maakond, 10151 Tallinn, Estonia, EU
Email: [email protected]
By continuing to use our services, you acknowledge and accept the terms of this Privacy Policy.
EFFECTIVE DATE: January 30, 2025