PRIVACY POLICY

Last updated: 4 September 2026

This Privacy Policy explains how Thriveology Paper Company Ltd (Company No. 16000352) (referred to as “I”, “me” or “my”) collects, uses, stores and protects your personal information. Marianne McCourt Coaching is the business brand through which coaching services and products including OWN THIS, Own Your Truth Quest and OWN IT are provided. These brand and product names are operated by Thriveology Paper Company Ltd and are not separate legal entities.

It applies when you use my websites, free resources and guided reflections (including OWN THIS), join my email list, buy a programme or other product, book coaching or another service, attend a call or event, contact me, or otherwise interact with my business.

I am the data controller responsible for your personal information.

Contact email: marianne@mariannemccourt.com

1. The information I may collect

Depending on how you interact with me, I may collect:

Identity and contact information, such as your name, email address, telephone number, postal address and business details.
Account and access information, such as the email address used to create an account, authentication status, product access and usage counts. Passwords are handled by the relevant authentication provider and are not available to me in readable form.
Purchase and transaction information, such as what you bought, the date, price and payment status. Card and bank details are normally collected and processed directly by my payment provider rather than stored by me.
Booking and service information, such as appointment details, coaching information, messages, call notes and information you choose to share while taking part in a programme or service.
Reflection content, including answers you type or dictate into OWN THIS, Own Your Truth Quest or any similar tool, together with generated reflections.
Voice and transcription information, when you choose to dictate an answer. Your audio may be processed by your browser or sent securely to a transcription provider so that it can be converted into text.
Marketing information, such as whether you have asked to receive emails, how you interact with those emails and your communication preferences.
Technical and usage information, such as your IP address, browser, device, approximate location, pages visited, diagnostic information and information stored through cookies or browser storage.
Communications, including emails, form submissions, feedback, testimonials, survey answers and messages you send me.

Please do not include personal information about another person unless you have their permission to share it.

2. Sensitive information

Reflection and coaching answers can be personal. You may voluntarily disclose information about your health, beliefs, sexuality, relationships or other sensitive matters.

I do not require you to provide sensitive information unless it is genuinely relevant to the service you have asked for. Where you deliberately provide it so that I can deliver a reflection, coaching session or programme, I process it with your explicit consent. You can withdraw that consent, although this will not affect processing that has already taken place and may mean I cannot provide that part of the service.

OWN THIS and my other resources are for reflection and education. They are not medical care, therapy, diagnosis or emergency support.

3. How and why I use your information

I only use personal information when I have a lawful reason to do so.

What I use it for	Lawful basis
To provide a free resource, guided reflection, programme, product, coaching or other service you request	To take steps at your request or perform a contract; and, where appropriate, my legitimate interest in running my business
To process reflection answers, generate an AI-assisted response or transcribe an answer you choose to dictate	Your explicit consent where sensitive information may be involved; otherwise your consent and the action you asked me to perform
To process payments, refunds and purchases	To perform a contract and comply with legal obligations
To respond to questions, support requests and feedback	To perform a contract or my legitimate interest in communicating with you and supporting my customers
To send newsletters, offers and marketing	Your consent. You can unsubscribe at any time
To maintain financial, tax and business records	Compliance with legal obligations
To protect my websites, tools, users and business, prevent misuse and diagnose faults	My legitimate interests in security, fraud prevention and reliable operation
To understand and improve my services	My legitimate interests in improving my business, using aggregated or appropriately limited information where possible
To establish, exercise or defend legal claims	My legitimate interests and legal obligations

Where I rely on legitimate interests, I consider whether my interests are necessary and proportionate and whether your rights override them.

I will not use your information for a materially different purpose without telling you and identifying a valid lawful basis.

4. Email marketing

I send marketing emails only where I have permission or another lawful basis to do so. These may include newsletters, reflections, business news, free resources and information about my programmes and services.

You can unsubscribe at any time by using the link in any marketing email or by contacting me. Unsubscribing from marketing will not stop essential messages about something you have bought, booked or requested.

I may retain a minimal suppression record after you unsubscribe so that I can honour your request and avoid adding you back by mistake.

5. AI-generated reflections and voice transcription

Some of my tools use artificial intelligence and speech-to-text technology.

When you ask for a personalised reflection:

the answers you submit are sent securely from the application server to the Lovable AI Gateway, which passes them to Google Gemini, currently using the gemini-3.7-flash model;
the service processes those answers to create the reflection you requested;
your answers and generated reflection are not stored in my application database and remain in your own browser;
where a usage cap applies, my database records only the limited information needed to enforce it. For OWN THIS this may be an anonymous browser identifier, the date and the word “reflection”. For an authenticated paid product such as Own Your Truth Quest, this may be an account identifier, date and generation count. It does not include your answers, reflection or audio;
the result is intended to support personal reflection and may contain mistakes;
it is not used to make a decision that produces legal or similarly significant effects about you; and
you should not include information that is unnecessary for your reflection.

When you choose to dictate an answer, your browser may convert the speech to text without the recording being sent to my server. If browser dictation is unavailable or unsuccessful, the server transcription fallback sends the recording through the Lovable AI Gateway to OpenAI, currently using the gpt-4o-mini-transcribe model. The recording is transcribed and discarded. It is not written to my application database, and I do not use it to identify you or create a voice profile.

Lovable acts as a processor for this information, with Google and OpenAI providing the relevant models through Lovable’s service. Lovable’s Data Processing Agreement states that customer personal data is not used to train, retrain, fine-tune or otherwise develop AI or machine-learning models. I do not use your answers, reflection or audio to train AI models.

These suppliers may process data outside the United Kingdom. See sections 7 and 8 below. Providers and model versions may change as the service develops; this policy will be updated if a change materially affects how your information is processed.

6. Cookies and browser storage

My websites and tools may use cookies and similar technologies.

OWN THIS and Own Your Truth Quest use browser storage to save your progress, answers and generated reflections on the device and browser you are using. This allows you to close the page and return later. You can remove locally saved information by using any reset function provided in the tool or by clearing the relevant browser data.

Essential cookies or storage may be used without consent where they are necessary to provide a feature you request, maintain security or remember essential choices. I will ask for consent before using non-essential analytics, advertising or similar cookies where the law requires it.

Blocking or deleting storage may stop saved progress or other features from working properly.

7. Who I share information with

I do not sell your personal information. I do not share it for cross-context behavioural advertising.

I disclose information only where necessary, including to trusted suppliers that help me operate my business. These may include:

Lovable, for website and application development, hosting and related infrastructure;
Kit, for email forms, subscriber records and email marketing;
Stripe, for payment processing;
Calendly, for appointment scheduling;
Zoom, for online calls and events;
Substack, where you choose to subscribe to or interact with my publication there;
QuickBooks, for bookkeeping, invoices and accounting records;
Google, for services such as email, documents, storage or calendar functions and whose Gemini model generates personalised reflections through the Lovable AI Gateway;
OpenAI, whose transcription model provides server voice transcription through the Lovable AI Gateway;
professional advisers such as my accountant, lawyer or insurer; and
regulators, courts, law enforcement or other parties where disclosure is required by law or reasonably necessary to protect rights, safety, security or prevent fraud.

Each third-party platform also processes information under its own privacy terms when it acts as an independent controller. For example, if you subscribe directly through Substack or pay through Stripe, that platform may collect information from you for its own purposes.

I require service providers acting on my behalf to use personal information only for the agreed services and to protect it appropriately.

8. International data transfers

Some suppliers may process or store information outside the United Kingdom, including in the United States.

Where UK data-protection law requires safeguards, I use providers that rely on a recognised adequacy arrangement, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful transfer safeguard. You may contact me for more information about the safeguard relevant to your data.

9. How long I keep information

I keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, tax, accounting, security and dispute requirements.

In general:

answers and generated reflections stored only in your browser remain there until you reset the session, clear the relevant browser data or the browser removes them;
server voice recordings are transcribed and discarded without being written to my application database;
usage-cap records contain only the limited browser or account identifier, date, feature label and generation count needed to administer the applicable limit, and are retained only for as long as reasonably necessary for that purpose;
email-list information is kept while you are subscribed, followed by a minimal suppression record where needed to honour an unsubscribe request;
customer, transaction and accounting records are generally kept for up to six years where required for UK tax, accounting or legal purposes;
coaching, programme, support and correspondence records are reviewed and deleted or anonymised when no longer needed; and
technical security records are kept only for a proportionate period unless they are needed to investigate misuse or a legal claim.

The AI, transcription, payment, hosting and other suppliers I use may maintain their own limited records under their contracts and privacy policies.

10. How I protect your information

I use reasonable technical and organisational measures designed to protect personal information from accidental loss, misuse, unauthorised access, alteration or disclosure. These include limiting access, using reputable service providers and using secure systems where appropriate.

No online service can promise absolute security. If a personal-data breach creates a risk that requires notification, I will notify the relevant regulator and affected people as required by law.

11. Your privacy rights

Depending on where you live and the law that applies, you may have the right to:

ask for a copy of personal information I hold about you;
ask me to correct inaccurate or incomplete information;
ask me to delete information;
ask me to restrict how information is used;
object to certain processing, including direct marketing;
receive information you provided in a portable format where applicable;
withdraw consent at any time; and
complain to a data-protection regulator.

These rights are not absolute, and a lawful exception may apply. I may need to verify your identity before completing a request. I will not discriminate against you for exercising a privacy right.

To make a request, email marianne@mariannemccourt.com. I normally respond within one month where UK data-protection law applies. If a request is unusually complex or numerous, the law may allow additional time, and I will tell you if that happens.

If you are in the United Kingdom, you may complain to the Information Commissioner’s Office (ICO) at ico.org.uk. I would appreciate the chance to address your concern first, but you do not have to contact me before contacting the ICO.

Residents of other countries or US states may have additional rights under their local laws. You may submit any such request using the same email address. Where required, I will also respond to a properly authorised agent or explain how to appeal a decision about a request.

12. Voice input and transcription

When you choose Speak Your Answer, browser dictation is used where available. If browser dictation is unavailable, your audio recording is sent through Lovable’s AI service to OpenAI for transcription.

We do not store your audio recording or transcript as part of this process. The recording is held temporarily in memory while the transcription request is completed. Only the audio and transcription model name are sent to the transcription service. Your name, email address, written answers and anonymous browser ID are not included in that request.

OpenAI may retain API data temporarily for abuse monitoring in accordance with its own data-retention policies. Audio submitted through the API is not used to train OpenAI’s models.

By choosing Speak Your Answer, you consent to this processing. You can avoid this processing by typing your answer instead.

13. Children

My websites, reflections, coaching and programmes are intended for adults aged 18 and over. I do not knowingly collect personal information from children. If you believe a child has provided information to me, please contact me so that I can investigate and delete it where appropriate.

14. Links and third-party services

My websites and emails may link to other websites, platforms or services. I am not responsible for their privacy practices. Please read their privacy information before giving them personal data.

15. Business changes

If I sell, transfer or reorganise all or part of my business, personal information may be disclosed to advisers and a prospective buyer and transferred as part of that transaction, subject to appropriate confidentiality and data-protection requirements.

16. Changes to this policy

I may update this Privacy Policy when my services, suppliers or legal obligations change. The current version will be posted on my website with its updated date. If a change materially affects how I use information, I will provide additional notice where appropriate.

17. Contact me

Questions, privacy requests and complaints can be sent to:

Thriveology Paper Company Ltd (Company No. 16000352)
Operating Marianne McCourt Coaching and its products
Email: marianne@mariannemccourt.com