Effective date: 18 September 2025

We respect your privacy. This notice explains what we collect, why, how long we keep it, and the choices you have. We do not sell personal data.

1) Who we are (Controller)

Controller: DIVERSITY WHISPERER S.L., trading as “Diversity Whisperer”
Public-facing brand/persona: Dr. Yasi Herbich
Contact (privacy requests): info@diversitywhisperer.com • WhatsApp: +34 643 62 42 48

By creating an account, booking, or using our services, you acknowledge this Privacy Policy.

2) What we collect

• Account/booking & support: name, email, phone/WhatsApp, preferred language, messages, session logistics, time zone.

• Billing: invoice details (name, address if an invoice requires it, tax/VAT IDs if applicable), payment status/IDs (managed by Stripe, Payoneer, PayPal, or Wix Payments). We do not store full card data; providers may store tokens/wallets for your convenience.

• Session context (optional, consent-based): goals, preferences, accessibility/sensory needs, communication preferences, and (only if you choose) information about challenges or neurotype that you wish to share for coaching.

• Transcripts & notes (consent-based): text transcripts/structured notes for action steps and progress tracking. No video recordings.

• Technical data: IP address, device/browser info, general location (city/country), pages viewed, and similar via essential cookies/logs.

• Analytics (consent-based): Wix Analytics (and any additional tools you opt into).

• Social & marketing (optional): interactions with our social pages or newsletters (if you subscribe).

3) Why we process data & legal bases (GDPR)

• Contract: provide coaching, schedule sessions, communicate, and deliver resources you request.

• Legal obligation: tax, accounting, and compliance record-keeping.

• Legitimate interests: site operation/security, fraud prevention, internal planning, defending legal claims—balanced against your rights.

• Consent: non-essential cookies/analytics, newsletters, testimonials, optional session profiles for minors, and transcripts/notes if they may include special-category information. You may withdraw consent at any time.

Special-category (“sensitive”) data

Under GDPR, special-category data includes health-related information (e.g., details about neurodivergence). We do not require this. If you choose to share it because it helps coaching, we will process it only with your explicit consent, keep it minimal, protect it, and you can withdraw consent any time. Withdrawing doesn’t affect prior lawful processing; we’ll delete/minimize those fields unless a law requires retention.

4) Children’s data

Where parental consent is legally required for young users, the parent/guardian must provide it. Coaching for minors is contracted with and consented by a parent/guardian.

5) Cookies & analytics

• Essential cookies run for security and core functions.

• Non-essential analytics (opt-in): We use Wix Analytics. We show a cookie banner before setting non-essential cookies and provide a preference center where you can change choices at any time.

• If we add tools later (e.g., Google Analytics), we will list them with purposes, lifetimes, and providers.

6) Sharing & processors

We share data only with trusted providers under GDPR-compliant contracts (processing on our instructions):

• Hosting & website: Wix.

• Payments: Stripe, Payoneer, PayPal, Wix Payments (we don’t store full card data; providers may store wallet tokens).

• Scheduling/video: Zoom; WhatsApp (for messaging and, if agreed, video).

• Email & communications: email provider, WhatsApp.

• Analytics: Wix Analytics (consent-based).
  (Company identity, CIF, and registered address per Spanish registry.)

7) International transfers

Some providers may process data outside your region. Where transfers occur, we rely on legally appropriate safeguards (e.g., adequacy decisions or Standard Contractual Clauses with additional measures where needed). You can contact us for information about safeguards.

8) Security, third-party policies & data incidents

We use reasonable technical/organizational measures (encryption in transit, access controls, least-privilege access). No system is 100% secure.

• Your responsibilities: protect your devices, passcodes, and accounts; keep software up to date; be cautious with what you send via chat; log out on shared devices.

• Third-party policies: Your use of WhatsApp is governed by WhatsApp’s Terms and Privacy Policy; your use of Zoom is governed by Zoom’s Terms and Privacy Notice.

• Incident response: If a personal-data breach likely risks your rights and freedoms, we will notify you without undue delay and, where required, notify authorities. We will also take steps to mitigate harm.

• Liability note: Nothing here waives rights you have under applicable data-protection law. To the extent permitted by law, we’re not responsible for indirect or consequential losses arising from third-party platform failures or account compromise due to user-side security issues.

9) Not for emergencies

Our channels (WhatsApp, email, Zoom) are not emergency services. If someone is in danger, contact local emergency services immediately.

10) Your rights (GDPR)

You can: access, rectify, erase, restrict, object (especially to processing based on legitimate interests), and port your data; and withdraw consent at any time.
To exercise rights: info@diversitywhisperer.com.

11) Retention

• Client records/invoices: generally up to 6 years after last interaction (or as the law requires).

• Transcripts/notes (consent-based): by default up to 2 years after your last session, unless you ask us to delete earlier or consent to longer retention for longitudinal coaching.

• Support emails/messages: up to 2 years (unless we must keep them).

• Marketing (consent-based): until you unsubscribe/withdraw consent.
  When no longer needed, we delete or anonymize.

12) Marketing preferences

Marketing is sent only with your consent or where permitted by law. Unsubscribe any time via the email footer or by contacting us.

13) Service availability & planned breaks

We aim to respond within the WhatsApp support window above. Messages on weekends/holidays are handled the next working day. We may take leave in December and during summer, with advance notice and rescheduling options.

14) Changes

We may update this notice; we’ll post the new version with a new effective date and, if material, provide extra notice.

15) Contact

DIVERSITY WHISPERER S.L. (trading as “Diversity Whisperer”) — CIF B19761634 — CL DIPUTACION NUM.301 P.PR PTA.1, BARCELONA.
info@diversitywhisperer.com • WhatsApp: +34 643 62 42 48