Privacy Policy
1. Who is responsible for your data?
The controller responsible for the processing of personal data described in this policy is:
Christian Ohm — Liminal Fluency
c/o STARTPLATZ Düsseldorf
Speditionstraße 15A
40221 Düsseldorf
Germany
Email: hello@liminalfluency.com
This policy covers the Liminal Fluency website, purchases, the Liminal Fluency Diagnostic, emails, enquiries and individual coaching or advisory services.
2. Website operation and security
The website and sales pages are provided through systeme.io, operated by ITACWT Limited, 2 Cruise Park Rise, Tyrrelstown, Dublin 15, Ireland.
When you visit, technical information may be processed, including your IP address, browser and device information, requested pages, access times and technical errors. This is used to deliver the website, maintain its security and investigate faults. Systeme.io uses service providers for content delivery and error monitoring as part of this technical operation.
The legal basis is Article 6(1)(f) GDPR. My legitimate interests are operating a reliable website and protecting it against misuse. Where processing is necessary to provide a service you request, Article 6(1)(b) GDPR applies.
Systeme.io also supports forms, customer records, order processing, digital delivery and emails. Further information: systeme.io Privacy Policy.
3. Enquiries and communication
When you contact me, I process your contact details, message and relevant correspondence to respond and manage your enquiry.
For enquiries relating to a prospective or existing contract, the legal basis is Article 6(1)(b) GDPR. For other enquiries, it is Article 6(1)(f) GDPR, based on my legitimate interest in responding to communications.
Google Workspace is used for business communication and document storage.
4. Orders and payments
When you purchase, I process information such as your name, email address, billing details, selected products, order value, payment status and the consents you give at checkout.
This information is needed to conclude and perform the contract under Article 6(1)(b) GDPR. Records required for tax and accounting purposes are retained under Article 6(1)(c) GDPR.
Card payments are processed by Stripe Payments Europe, Ltd., Ireland. Where you choose Klarna, the payment is processed by Klarna Bank AB (publ), Sweden. The providers receive the information necessary to process the payment, verify transactions and prevent fraud, and may process data independently to fulfil their own legal obligations. I do not receive your complete payment-card details.
Further information: Stripe Privacy Policy · Klarna Privacy Notice.
5. The Liminal Fluency Diagnostic and emails
The free Diagnostic is provided through ScoreApp (ScoreApp Ltd, United Kingdom). When you take it, your answers, results and the contact details you enter are processed to calculate and send your result.
Your result and contact details are passed via Zapier (Zapier, Inc., USA) to systeme.io, which I use to send you your result and a short series of follow-up emails about transitions and my services. Where you subscribe to my newsletter, systeme.io is also used to send it.
The legal basis for these emails is your consent under Article 6(1)(a) GDPR. You can unsubscribe at any time using the link in every email, or by writing to me. Withdrawal does not affect the lawfulness of processing before withdrawal.
Further information: ScoreApp Privacy Policy · Zapier Privacy Policy.
6. Booking and video sessions
Bookings are made through a systeme.io booking page and organised in Google Calendar. Sessions normally take place through Google Meet.
Appointment and meeting data may include your name, email address, scheduled time, meeting link, connection information and audio or video transmitted during the session.
The legal basis is Article 6(1)(b) GDPR because the processing is necessary to arrange and deliver the agreed service.
Sessions are not recorded. I do not use session recording, automated transcription or AI-generated meeting summaries. If we agree to use another video platform, I will provide the relevant provider information before the session.
Further information: Google Privacy Policy.
7. Coaching notes
I may make brief notes to support continuity and delivery of the coaching or advisory service. Notes may initially be handwritten and subsequently stored in Google Workspace.
The legal basis is Article 6(1)(b) GDPR. Access is restricted to me, subject to necessary processing by the service providers used for storage and technical operation.
The service concerns careers and professional transitions. Please avoid submitting medical records, diagnoses or other sensitive health information. I do not request or intentionally record such information as part of the service.
8. Withdrawal requests
If you send me a withdrawal notice, I process the information you provide (name, email address, order details) and the time of receipt to handle your withdrawal. The legal basis is Article 6(1)(c) GDPR (statutory obligation) and Article 6(1)(b) GDPR.
9. Substack, LinkedIn and external links
The website links to articles on Substack and to my LinkedIn profile. These are ordinary links; no content from these platforms is embedded. Following a link takes you to that platform, where its own privacy information applies. Purchasing through this website does not subscribe you to Substack.
10. Cookies and similar technologies
This website does not use analytics, advertising or social-media tracking technologies, and therefore does not ask for cookie consent.
Only technologies that are strictly necessary to provide the website and services you request are used (section 25(2) TDDDG). In particular, on checkout pages the payment provider Stripe sets a cookie used for fraud prevention and secure payment processing, and systeme.io may store technical information needed to operate forms and checkouts. The related processing is based on Article 6(1)(b) and Article 6(1)(f) GDPR.
If I introduce optional technologies in future, I will ask for your consent beforehand and update this policy.
11. Recipients and international transfers
Personal data is shared only where necessary with the providers named in this policy, or where disclosure is legally required.
Some providers may process personal data outside the European Economic Area, in particular in the United States (Google, Zapier, and sub-processors of Stripe and systeme.io) and the United Kingdom (ScoreApp). For the United Kingdom, the European Commission has issued an adequacy decision. For transfers to the United States, providers rely on certification under the EU-U.S. Data Privacy Framework where available, and otherwise on the European Commission's standard contractual clauses.
You may contact me for information about applicable transfer safeguards and how to obtain a copy.
12. Retention
I retain personal data only for as long as necessary for the stated purposes or applicable legal obligations:
- General enquiries that do not result in a contract: normally deleted within six months after resolution.
- Coaching notes: normally deleted within 12 months after the final session.
- Email subscriptions: until you unsubscribe; proof of consent is kept for as long as needed to demonstrate it.
- Contract records and material correspondence: normally until the end of the applicable limitation period, generally three years from the end of the relevant calendar year.
- Invoices and accounting records: generally eight years from the end of the year in which they were issued.
Records may be retained longer where necessary for an existing dispute, legal claim or binding retention obligation. Data retained solely for these purposes is restricted from unrelated use.
13. Your rights
Subject to the conditions in the GDPR, you may request access to your personal data, correction, erasure, restriction of processing and data portability.
Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
Where processing is based on legitimate interests, you may object for reasons relating to your particular situation. You may object to processing for direct marketing at any time.
Contact hello@liminalfluency.com to exercise your rights.
You also have the right to complain to a data-protection supervisory authority, particularly in the country of your habitual residence, place of work or the alleged infringement. The authority for North Rhine-Westphalia is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen.
14. Required information and automated decisions
Information needed to handle an order, process payment or arrange a session must be provided for that service to be delivered. Other information is optional unless identified otherwise.
I do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Payment providers may carry out their own fraud-prevention or financing assessments.
15. Updates
This policy may be updated to reflect changes in services, processing activities or legal requirements. Material changes will be communicated where required.