Privacy Policy | Silk Clarity

1. Introduction

Silk Clarity ("Silk Clarity", "we", "us", or "our") is committed to protecting the privacy and personal data of its users, clients, and website visitors ("you", "your"). This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit https://www.silkclarity.com (the "Website") or use our English coaching and communication training services (the "Services").

This Policy is issued in accordance with Regulation (EU) 2016/679 (the "General Data Protection Regulation" or "GDPR") and applicable Spanish data protection legislation, including Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD).

2. Data Controller Information

The data controller responsible for the processing of your personal data is:

Business Name: Silk Clarity
Owner: Darcy Renouf
Country of Registration: Spain
Website: https://www.silkclarity.com
Contact email: privacy@silkclarity.com

3. Personal Data Collected

3.1 Information You Provide

Identification data: full name, preferred name, date of birth (where relevant).
Contact data: email address, telephone number, country of residence, time zone.
Account data: login credentials, profile preferences, language proficiency information.
Professional data: occupation, employer (optional), learning objectives.
Booking and scheduling data: lesson times, attendance records, lesson notes.
Payment data: billing name, billing address, and tax identification number where required. Card details are processed directly by Stripe and are not stored on our systems.
Communication data: messages, support requests, survey responses, feedback.
Marketing preferences: newsletter subscription status and consent records.

3.2 Information Collected Automatically

Device and browser information (IP address, browser type, operating system, device identifiers).
Usage information (pages visited, time on page, referring URLs, session duration).
Log data (timestamps, error logs, access logs).
Approximate geolocation data derived from IP address.
Information collected via cookies and similar technologies (see Section 4).

4. Cookies and Tracking Technologies

We use cookies, pixels, local storage, and similar technologies to operate the Website, remember preferences, measure performance, and (where you consent) deliver marketing. Categories include:

Strictly necessary cookies — required for the Website to function. No consent required.
Functional cookies — remember preferences (e.g. language, time zone).
Analytics cookies — measure usage (e.g. Google Analytics).
Marketing/advertising cookies — personalize and measure marketing (e.g. Meta Pixel).

Non-essential cookies are only set with your prior consent. You may withdraw consent at any time via the cookie settings link in the Website footer.

5. Legal Basis for Processing Under GDPR

Performance of a contract (Art. 6(1)(b)) — to provide the Services you have requested.
Legal obligation (Art. 6(1)(c)) — to comply with tax, accounting, and other legal duties.
Legitimate interests (Art. 6(1)(f)) — to operate, secure, and improve the Website and Services.
Consent (Art. 6(1)(a)) — for non-essential cookies and marketing. You may withdraw consent at any time.

6. How Personal Data Is Used

Create and manage your account.
Schedule, deliver, and manage lessons and coaching sessions.
Process payments and issue invoices.
Communicate with you about your bookings, account, and Services.
Send newsletters and marketing communications (where permitted).
Improve our Services, content, and user experience.
Comply with legal, tax, and regulatory obligations.
Detect, prevent, and address fraud, security, or technical issues.

7. Payment Processing Through Stripe

Payments are processed by Stripe Payments Europe, Ltd. ("Stripe"). When you make a payment, your card details are submitted directly to Stripe and are governed by Stripe's privacy policy (https://stripe.com/privacy). We receive only transaction metadata necessary to deliver and account for the transaction. We do not store full card numbers.

8. Scheduling and Booking Platforms

We may use third-party booking and scheduling tools (such as Calendly) to manage lesson appointments. These providers process your name, email, time zone, and selected appointment times on our behalf as processors under appropriate data protection agreements.

9. Video Conferencing Platforms

Lessons may be delivered through video conferencing tools such as Zoom or Google Meet. These platforms process your name, email, IP address, device data, and audio/video streams during sessions in accordance with their own privacy policies. Lessons are not recorded unless you are informed in advance and have given consent where required.

10. Email Marketing and Newsletters

If you subscribe to our newsletter or consent to marketing, we will send you communications about lessons, courses, content, and offers. You can unsubscribe at any time via the link in any email or by contacting us.

11. Analytics and Website Performance Tools

We use analytics tools (such as Google Analytics) and may use advertising pixels (such as Meta Pixel) to understand how users interact with the Website and to measure marketing performance. Where these tools rely on non-essential cookies, they are loaded only after you provide consent. IP addresses are anonymized where technically feasible.

12. Data Sharing and Third-Party Providers

We do not sell your personal data. We share personal data only with:

Service providers acting as processors on our behalf (hosting, payments, scheduling, video conferencing, email marketing, analytics, support).
Professional advisors (accountants, lawyers, auditors) under duties of confidentiality.
Competent public authorities where required by law.
Acquirers or successors in the event of a business reorganization, merger, or sale.

All processors are bound by written agreements meeting the requirements of Article 28 GDPR.

13. International Data Transfers

Some of our providers are located outside the European Economic Area (EEA), including in the United States. Where personal data is transferred outside the EEA, we rely on appropriate safeguards under Chapter V GDPR, including the European Commission's Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework.

14. Data Retention Periods

Account and lesson records: duration of the client relationship and up to 6 years thereafter.
Invoicing and payment data: 6 years from issuance, in accordance with Spanish commercial law.
Marketing data: until you withdraw consent or object.
Website analytics: typically up to 14 months.
Support communications: up to 3 years from last contact.

When no longer required, personal data is deleted or anonymized.

15. User Rights Under GDPR

Right of access — to obtain confirmation and a copy of your personal data.
Right to rectification — to correct inaccurate or incomplete data.
Right to erasure — to request deletion of your personal data.
Right to restrict processing — to limit processing in certain circumstances.
Right to data portability — to receive your data in a structured, machine-readable format.
Right to object — to object to processing based on legitimate interests or for direct marketing.
Right to withdraw consent — at any time, without affecting prior lawful processing.

To exercise these rights, contact us at privacy@silkclarity.com. We may need to verify your identity before responding.

16. Children's Privacy

The Services are not directed to children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

17. Data Security Measures

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit (TLS), access controls, secure authentication, regular backups, and vendor due diligence. No method of transmission or storage is 100% secure.

18. Complaint Procedures

If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos, AEPD), C/ Jorge Juan, 6, 28001 Madrid — https://www.aepd.es — or with the supervisory authority of your country of residence. We encourage you to contact us first so we can address your concerns.

19. Contact Information

Silk Clarity — Darcy Renouf
Email: privacy@silkclarity.com
Website: https://www.silkclarity.com

20. Updates to this Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top indicates the latest revision. Material changes will be communicated through the Website or by email where appropriate.