DRAFT | NOT FOR PUBLICATION | NOT APPROVED FOR CHECKOUT USE

DRAFT | NOT FOR PUBLICATION | NOT APPROVED FOR CHECKOUT USE

This purchase Privacy Notice is incomplete. Provider roles, data flows, transfers, cookies and retention periods still have to be verified. Do not publish or rely on this draft.

Purchase Privacy Notice for The Trust Loop

Private draft dated 10 August 2026

This draft notice explains how personal information is proposed to be handled when you view the order page, buy The Trust Loop, receive the live programme and toolkit, ask for support or are assessed for Fast Track. It replaces any webinar-registration notice for purchase processing. It does not cover the future Founding Beta data flow.

1. Who is responsible for your information

DIGITALLY MARKETING MENTORING LIMITED is the controller for the personal information it uses to sell and deliver The Trust Loop.

Registry: Companies Registration Office (Ireland). Company number: 614548.

Geographic contact address: 46 St Mary’s Road, Midleton, Co. Cork, Ireland.

Phone: 085 873 2726

Privacy contact: jvwithanthony@gmail.com

2. Information we collect or receive

Depending on the purchase and your use of the programme, we may receive or create:

  • Your name, email address and account or contact details
  • The payment option you selected
  • Whop order, transaction and payment-status identifiers
  • The price, currency, order date and billing country or tax information Whop makes available to us
  • Attendance, scheduling, access and fulfilment records
  • The successful-purchase timestamp used to calculate your common access expiry and the resulting expiry timestamp
  • Support, complaint, cancellation and refund correspondence
  • The Terms version and any valid early-performance request or acknowledgement
  • Fast Track eligibility evidence, notification and fulfilment records
  • Order-page technical information such as request time, IP address or security log data, device and browser information, page or referral source, time zone and error records where the configured services collect them

We do not need your full payment-card number. Whop handles the checkout and payment process.

3. Where the information comes from

  • Information you enter on the order page, in Whop, in an email, in a support request or during programme fulfilment
  • Order and payment-status information received from Whop
  • Attendance, access and fulfilment information created when the programme is delivered
  • Technical and security information generated by the website, hosting and configured service providers

4. Why we use information and our legal bases

  • Take and administer your order, calculate and provide the approved 36 months of access to recordings, toolkit and Founding Beta, schedule and deliver the live sessions and clinic, provide support and send important service information.

    Legal basis Necessary to perform the contract or take requested steps before the contract.

  • Keep invoices, tax, accounting, cancellation, refund, consumer-rights and compliance records.

    Legal basis Necessary to comply with legal obligations. Contract and legal-claims interests may also apply where relevant.

  • Protect the order process, investigate suspected fraud, manage disputes, secure accounts and establish or defend legal claims.

    Legal basis Our legitimate interests in operating and protecting the service, or a legal obligation where applicable. A final legitimate-interest assessment is required before publication.

  • Assess and administer the first-five Fast Track allocation.

    Legal basis Necessary to perform the approved Fast Track part of the contract. The final rules and data flow must be confirmed.

  • Send optional promotional email unrelated to delivery.

    Legal basis A separate valid marketing basis. Purchase acceptance is not marketing consent.

5. Information needed to provide the purchase

Identity, contact, order and payment-status information is needed to take the order, confirm payment, provide access, communicate material service information and meet legal obligations.

If the required information is not provided, the order may not be completed or the programme may not be delivered.

Optional marketing information is not required to buy The Trust Loop.

6. Who receives the information

Whop receives and uses information for checkout, payment, account, fraud, tax and legal-compliance purposes. Whop may act as an independent controller for some of that processing. Read Whop's own privacy information in the checkout flow.

We may also use verified providers for website hosting, database storage, email, live sessions, toolkit delivery, support, security, analytics and professional advice where needed.

Providers acting only on our instructions must be subject to appropriate data-processing terms. Other providers may be independent controllers for their own purposes.

7. International transfers

Some providers may process information outside Ireland or the European Economic Area.

Where the GDPR requires a transfer safeguard, the final notice must identify the relevant country or transfer category and the safeguard relied upon, such as an adequacy decision or approved contractual clauses.

8. How long we keep information

We keep personal information only for as long as the relevant purpose and legal basis require.

Necessary invoices, transaction records and tax-linked business records may have to be kept for six years where Irish tax or accounting law requires it. This does not mean that every customer, support, attendance, analytics or marketing record is kept for six years.

Order terms, cancellation information, any early-performance request, acknowledgements and dispute evidence will be kept for a period based on legal obligations and legal-claims risk. That period still has to be approved.

Fulfilment and access records will be kept by reference to the approved 36-month service term, the verified support window, a short justified post-expiry administration period and the deletion process. The 36-month term does not by itself justify retaining every category of personal information for 36 months.

Attendance and routine support records should have a shorter operational period unless a dispute, legal obligation or continuing service requires longer retention.

Optional marketing information is kept only while its lawful basis remains valid and is deleted or suppressed when required after withdrawal or objection.

When information is no longer needed, it will be deleted or irreversibly anonymised, subject to any required tax, legal or dispute hold.

9. Purchase communications and marketing

We may send the confirmation, payment, scheduling, access, delivery, support, cancellation and material service messages needed to provide The Trust Loop.

Buying The Trust Loop does not automatically subscribe you to unrelated promotional marketing.

Any optional marketing must use a separate valid basis and include the required unsubscribe or objection route.

10. Cookies and order-page technical information

The order page, hosting and security services may process request time, IP address or security logs, device and browser details, referral source, time zone, page events and error information where configured.

Strictly necessary technical processing may be used to operate and protect the page. Any optional analytics, advertising or non-essential cookie use requires a completed assessment and the appropriate notice or consent process.

11. Automated decisions

No statement about solely automated decision-making or profiling is approved yet.

The final notice must explain any automated process that has a legal or similarly significant effect, or state that none is used only after this has been verified.

12. Founding Beta privacy

The buyer supplies and pays for their own OpenRouter account, API key and usage credits.

The order page does not ask for or store the OpenRouter API key.

This purchase notice does not describe the future beta's handling of API keys, prompts, files, inputs, outputs, usage or error logs.

Before beta access, buyers must receive a separate, specific beta privacy and security notice. It must identify actual providers, roles, transfers, retention, key handling, user controls, incident handling and any training or improvement use.

13. Your data-protection rights

Depending on the circumstances, you may have the right to access your personal information, correct it, request deletion, restrict processing, object to processing and receive eligible information in a portable form.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect processing already carried out lawfully before withdrawal.

These rights are subject to the conditions and exemptions in applicable law.

To make a request, email jvwithanthony@gmail.com We may ask for information reasonably needed to confirm your identity.

14. Privacy questions and complaints

Please email jvwithanthony@gmail.com if you have a privacy question or concern.

You may also complain to the Irish Data Protection Commission at https://www.dataprotection.ie/ or to another supervisory authority available to you under applicable law.

15. Changes to this notice

The final notice will show its effective date and will be updated when the verified purchase data flow changes.

Material changes will be communicated where applicable law requires it.

Contact: DIGITALLY MARKETING MENTORING LIMITED, 46 St Mary’s Road, Midleton, Co. Cork, Ireland. Phone: 085 873 2726. Email: jvwithanthony@gmail.com

16. This private draft is not ready for publication

The following privacy facts still have to be verified:

  • Every data field received from Whop
  • Website, hosting, database, email, webinar, support, analytics and fulfilment providers
  • Controller and processor roles and required contracts
  • International transfer locations and safeguards
  • Cookie, analytics, security-log and technical-data configuration
  • Purpose-specific retention schedule
  • Fast Track decision and evidence data flow
  • Automated decision-making or profiling status
  • Separate Founding Beta privacy and security notice
  • Final data-protection and legal review

DRAFT | NOT FOR PUBLICATION | NOT APPROVED FOR CHECKOUT USE