Privacy Policy

Effective date: 3 August 2026

This Privacy Policy (the "Policy") explains how personal data of visitors to linakhegay.com (the "Site") and participants in the educational programme "Zagovori" (the "Programme") is collected, used, stored and protected.

Data controller: Arsen Gugunava, a sole trader based in London, United Kingdom, trading as Lina Khegay (the "Operator").

Contact: hello@linakhegay.com

This Policy explains what we do with your personal data and what rights you have. It applies whether you have subscribed to the newsletter, written to us, or paid to join the Programme.

1. What data is processed

1.1. Identity and contact data: your name and email address, provided when you subscribe to the newsletter or register for the Programme.

1.2. Payment data: processed solely by the payment service Stripe. The Operator does not receive, store or have access to your full card details. We receive only confirmation of successful payment, the amount, your name and email, and the last four digits of the card.

1.3. Billing address: address and country, where needed to calculate tax.

1.4. Programme data: your progress through the materials, and any information you share during live sessions and individual consultations, if you take part in them. Live sessions may be recorded, in which case the recording will contain your image, your voice and anything you say during the session. Where a session is being recorded, you will be told in advance.

1.5. Correspondence: the content of messages you send us.

1.6. Technical data: information about your visits to the Site, collected through cookies and analytics tools.

2. Purposes of processing and legal bases

Personal data is processed for the following purposes:

To give you access to Programme materials after payment, to run live sessions and individual consultations, to communicate with you about your participation, and to send order confirmations, receipts and access details. Legal basis: performance of a contract.

To send newsletters and emails about the Programme. Legal basis: your consent.

To meet tax, accounting and record-keeping obligations. Legal basis: legal obligation.

To improve the Site and the quality of the Programme. Legal basis: legitimate interests.

For Site analytics. Legal basis: your consent, given through the cookie banner.

Where processing is based on your consent, you may withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, and does not stop service emails relating to a Programme you have already paid for.

3. Sharing data with third parties

3.1. The Operator does not sell your personal data and does not share it with third parties for their own marketing purposes.

3.2. To run the Site and the Programme, the Operator uses the following service providers, who process data on the Operator's instructions:

Kit, email newsletters

Squarespace, Site hosting, order processing, hosting of Programme video materials, and the members-only area

Stripe, payment processing and tax compliance

Zoom, delivery of live sessions and individual consultations

3.3. Data may also be shared with our accountant to the extent needed for tax reporting, and with public authorities where disclosure is required by law.

3.4. Each of these services processes data in accordance with its own privacy policy and under a data processing agreement with the Operator.

4. International transfers

Some of the service providers listed above are located outside the United Kingdom, including in the United States and the European Union.

Where your personal data is transferred outside the United Kingdom, it is protected by the safeguards provided for under UK data protection law. These include the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, and the UK Extension to the EU-US Data Privacy Framework, depending on the provider.

5. Retention periods

Orders and payment records: 6 years, as required by HMRC

Programme access records: the 12 months of access plus a further 12 months

Live session recordings: the 12 months of access plus a further 12 months

Newsletter subscription: until you unsubscribe, or after 3 years of no engagement

Correspondence: 2 years

Analytics data: as set by the platform, normally no more than 14 months

After these periods, data is deleted or anonymised.

6. Your rights

Under UK data protection law you have the right to:

6.1. find out what personal data of yours is being processed and obtain a copy of it;

6.2. ask for inaccurate data to be corrected;

6.3. ask for your data to be deleted, where there is no valid lawful ground to keep it;

6.4. restrict the processing of your data;

6.5. object to processing carried out on the basis of legitimate interests;

6.6. receive your data in a portable, machine-readable format;

6.7. withdraw consent at any time and unsubscribe from the newsletter using the link in every email;

6.8. lodge a complaint with a supervisory authority.

To exercise any of these rights, write to hello@linakhegay.com. We will respond within one month.

If you are unhappy with how your request has been handled, you may complain to the Information Commissioner's Office (ICO), the UK data protection supervisory authority: ico.org.uk, telephone 0303 123 1113. We would be grateful for the chance to resolve the matter directly before you approach the ICO.

7. Cookies

The Site uses cookies that are strictly necessary for it to function, including for the cart and checkout. These do not require your consent.

Analytics and other optional cookies are set only with your consent, which you give through the cookie banner on your first visit. You can change your choice at any time through the banner or in your browser settings. Disabling necessary cookies may affect how the Site works.

8. Data security

The Operator takes reasonable organisational and technical measures to protect personal data against unauthorised access, alteration, disclosure or destruction.

9. Children

The Programme and the Site are intended for adults. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with their personal data, contact us and we will delete it.

10. Changes to this Policy

The Operator may amend this Policy. The current version is published on this page with its effective date. We will notify subscribers and Programme participants by email of any significant changes.

11. Contact

For any questions about how your personal data is processed, contact the Operator at hello@linakhegay.com.