PRIVACY POLICY

Last Updated: January 20, 2026

This Privacy Policy describes how Tracey Sonneborn, DBA THÉLEMA LIFE COACHING ("Company," "we," "us," or "our"), based in California, USA, collects, uses, discloses, and protects personal information obtained through our website and virtual coaching services (the “Services”).

This Privacy Policy applies to users located in the United States and internationally, including individuals in the European Union (EU), United Kingdom (UK), and other jurisdictions where data protection laws may apply.

By accessing or using our website or Services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

a. Information You Provide Directly

We may collect personal information you voluntarily provide, including:

  • Name

  • Email address

  • Phone number

  • Billing and payment information (processed via third-party providers)

  • Intake forms, questionnaires, and communications related to coaching services

Communications occur via standard email correspondence and through third-party scheduling or service platforms used to provide coaching services.

b. Automatically Collected Information

When you visit our website, certain information may be collected automatically, including:

  • IP address

  • Browser type and device information

  • Pages visited and usage data

  • Date and time of access

This information is collected through cookies and similar technologies provided by our website hosting platform (e.g., Squarespace).

2. How We Use Your Information

We use personal information for the following purposes:

  • To provide and administer coaching services

  • To communicate with you regarding sessions, inquiries, and support

  • To process payments and manage transactions

  • To operate, maintain, and improve our website

  • To comply with legal and regulatory obligations

  • To protect against fraud, misuse, or unauthorized access

3. Legal Bases for Processing (GDPR)

For individuals located in the EU or UK, we process personal data under the following legal bases:

  • Your consent

  • Performance of a contract

  • Compliance with legal obligations

  • Legitimate business interests, where not overridden by your rights

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to support website functionality and analyze site usage.

Cookies are primarily set by our website hosting platform (Squarespace) and may include:

  • Essential cookies required for website operation

  • Limited analytics cookies

Cookie usage is governed by the Squarespace cookie banner, which allows you to accept, decline, or manage cookie preferences. You may also control cookies through your browser settings. Disabling cookies may affect website functionality.

5. How We Share Information

We do not sell or rent your personal information.

We may share information with:

  • Payment processors

  • Scheduling or coaching software platforms

  • Website hosting providers (including Squarespace)

  • Analytics and website performance providers

  • Legal, accounting, or professional advisors

  • Government or regulatory authorities when required by law

All third parties are required to maintain appropriate safeguards.

6. International Data Transfers

Your information may be transferred to and processed in the United States or other countries where our service providers are located.

For individuals in the EU or UK, appropriate safeguards (such as standard contractual clauses) are used where required.

By using the Services, you acknowledge and understand that your information may be transferred and processed in the United States.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

8. Your Privacy Rights

a. General Rights
Depending on your location, you may have the right to:

  • Access your personal information

  • Request correction or deletion

  • Object to or restrict processing

  • Request data portability

b. California Privacy Rights (CCPA/CPRA)
California residents have the right to:

  • Know what personal information is collected, used, or disclosed

  • Request deletion of personal information

  • Opt out of the sale or sharing of personal information
    (We do not sell or share personal data for cross-context behavioral advertising)

  • Not be discriminated against for exercising privacy rights

Requests may be submitted using the contact information below. Authorized agents may submit requests on your behalf, subject to verification.

c. EU/UK Privacy Rights (GDPR)
EU and UK residents may withdraw consent at any time and have the right to lodge a complaint with a supervisory authority.

9. Data Security

We implement reasonable administrative, technical, and organizational safeguards to protect personal information. However, no method of transmission or storage is completely secure, and absolute security cannot be guaranteed.

10. Children’s Privacy

Our website and Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors.

11. Third-Party Links and Services

Our Services may rely on third-party platforms, including website hosting providers, payment processors, scheduling tools, or coaching software. We are not responsible for the privacy practices of third parties, which are governed by their own privacy policies.

12. California Online Privacy Protection Act (CalOPPA)

In accordance with the California Online Privacy Protection Act (CalOPPA):

  • This Privacy Policy is accessible via a link on our website homepage

  • Users are notified of material changes by updating the “Last Updated” date

  • We do not respond to “Do Not Track” signals

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last Updated” date. Continued use of the website or Services constitutes acceptance of the updated Privacy Policy. Where required by law, your continued use constitutes consent to the updated Privacy Policy.

14. Contact Information

If you have questions or wish to exercise your privacy rights, contact:

Tracey Sonneborn, DBA theléma Life Coaching
Email: tracey@thelemalifecoaching.com
Business Location: California, USA

Mailing address: 317 N El Camino Real, Suite 306, Encinitas, CA 92024 United States