Privacy Policy
Last updated: December 31, 2025
1. Who we are – Welkin Kft. t/a Uplift Crew (“we”, “us”, “our”) is an EU‑based virtual wellness‑coaching business located at Attila utca 12‑18, 1047 Budapest, Hungary. Contact: richard@upliftcrew.com.
2. Scope – This policy describes how we process personal data of all users (including EU residents) and adds the specific rights of California residents under CalOPPA and the CCPA.
3. Data we collect – When you order, fill a form or email us we collect name, email address, IP address, and payment information.
4. Legal basis – Processing is based on (a) your explicit consent for marketing and wellness‑related advice, (b) performance of a contract for the paid coaching service, and (c) a legal obligation for bookkeeping and tax records.
5. Purpose limitation & data‑minimization – Data are used only to (i) deliver coaching services, (ii) manage payments, (iii) communicate with you, (iv) comply with fiscal duties, and (v) improve our website. We retain only data necessary for each purpose and delete or anonymize them when no longer needed.
6. Retention – Personal data are kept while the service relationship exists and for one additional year to reference prior wellness plans.
7. Third‑party sharing – HubSpot, Gumroad and Stripe receive the full data set to provide marketing, sales and payment processing. They act as processors under written contracts that obligate them to protect your data.
8. Cookies & tracking – We place cookies only after you accept the banner or exercise Global Privacy Control (GPC). We honor “Do‑Not‑Track” signals and disclose this on our homepage as required by CalOPPA.
9. International transfers – All transfers are made to processors that provide adequate safeguards in line with GDPR Chapter V (standard contractual clauses).
10. Your rights (EU) – You may access, rectify, erase, restrict, port or object to processing. Requests are handled via our Data‑Privacy‑Request page (click here); verification may be required.
11. California‑specific rights (CCPA & CalOPPA) – California residents can request disclosure of collected categories, request deletion, and opt‑out of any sale (we do not sell data). Requests are accepted via our Data-Privacy-Request page (click here). A conspicuous link to this policy is posted on our homepage as mandated by CalOPPA.
12. Security & breach response – We implement appropriate technical and organizational measures (encryption, access controls, regular audits) and will notify the relevant supervisory authority and affected individuals without undue delay if a breach occurs.
13. Direct marketing – We send marketing emails only with prior explicit consent; every message includes an unsubscribe link automatically placed in the footer.
14. Changes to this policy – We will update this page for any material changes and indicate the effective date at the top.
For any questions or to exercise your rights, please contact us at richard@upliftcrew.com.