Privacy Policy
PRIVACY POLICY
Last updated: 20 July 2026
This Privacy Policy explains how personal data is processed when you visit www.adwoatheresa.com, create an account, purchase digital content, enrol in an online programme, subscribe to a digital offering or submit a private inquiry.
Personal data means any information relating to an identified or identifiable natural person.
1. CONTROLLER
The controller responsible for processing personal data on this website is:
Adwoa Theresa Adu-Sanyah
c/o Postflex #7630
Emsdettener Str. 10
48268 Greven
Germany
Email: info@adwoatheresa.com
Website: www.adwoatheresa.com
A data protection officer has not been appointed because there is currently no legal obligation to appoint one.
2. WEBSITE PLATFORM AND HOSTING
This website is created and hosted through the Wix platform.
Wix.com Ltd.
5 Yunitsman Street
Tel Aviv, Israel
Wix and its affiliated companies provide the technical infrastructure, hosting, security, content delivery, member-account functions, online programmes, digital commerce, pricing plans, customer administration and related website services.
When you access this website, Wix may process technical information necessary to deliver and secure the website. This may include:
- IP address
- date and time of access
- requested page or file
- browser type and version
- operating system
- device information
- referring page
- language and display settings
- technical security and error information
The legal basis is Article 6(1)(f) GDPR. The legitimate interest is the secure, stable and functional operation of the website.
Wix may process information through affiliated companies and service providers in Israel, the European Economic Area and other countries. Israel is recognised by the European Commission as providing an adequate level of data protection. Where no adequacy decision applies, Wix states that it uses recognised safeguards for international transfers.
Further information:
https://www.wix.com/about/privacy
3. COOKIES AND SIMILAR TECHNOLOGIES
This website uses cookies, local storage and similar technologies.
Some technologies are technically necessary for:
- website security
- fraud prevention
- page delivery
- member login
- shopping and checkout functions
- account and programme access
- saving privacy preferences
- maintaining essential sessions
Technically necessary cookies and technologies are used on the basis of Section 25(2) TDDDG and, where personal data is processed, Article 6(1)(b) or Article 6(1)(f) GDPR.
Non-essential cookies, including analytics cookies, are activated only after consent. The legal basis is Section 25(1) TDDDG and Article 6(1)(a) GDPR.
The cookie banner allows visitors to:
- accept all optional cookies
- decline all optional cookies
- select individual cookie categories
- change or withdraw consent later
Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
Detailed information about the cookies currently in use, their purposes, providers and durations is available through the Cookie Settings function displayed on the website.
4. WIX ANALYTICS
This website uses Wix Analytics to understand website traffic and the general use of the website.
Depending on the visitor’s consent, Wix Analytics may process information such as:
- visited pages
- approximate visit duration
- navigation paths
- referring source
- general device and browser information
- approximate location derived from the IP address
- interactions with website elements
- purchases, account registrations or programme enrolments
Traffic and behaviour analytics that rely on non-essential analytics cookies are activated only after consent.
The legal basis is Article 6(1)(a) GDPR and Section 25(1) TDDDG.
Essential transaction, member and sales information may also appear in Wix reports where this information is generated through an account, purchase or contractual interaction. The legal basis for that processing is Article 6(1)(b) GDPR or Article 6(1)(f) GDPR.
Wix Session Recordings are not enabled.
5. MEMBER ACCOUNTS
Certain digital programmes, subscriptions and purchased materials require a Wix member account.
When an account is created, the following information may be processed:
- name
- email address
- login and authentication information
- account settings
- purchased content
- subscription status
- programme enrolment and progress
- communications relating to the account
- technical security information
The legal basis is Article 6(1)(b) GDPR because the account is required to provide the purchased or requested digital content.
Account information is retained while the account remains active and afterwards where legal retention obligations or the establishment, exercise or defence of legal claims require continued storage.
Users may request deletion of their account by contacting info@adwoatheresa.com. Deletion may be restricted where information must be retained to meet legal obligations.
6. DIGITAL PURCHASES, PRICING PLANS AND ONLINE PROGRAMMES
When you purchase a digital work, join a pricing plan, begin a subscription or enrol in an online programme, the following information may be processed:
- name
- email address
- billing information
- country and tax-related information
- product, programme or subscription selected
- order and transaction information
- payment status
- member-account information
- programme access and progress
- cancellation and refund information
- communications relating to the purchase
Processing is necessary to conclude and perform the contract, provide access to the purchased material, administer payments and subscriptions, meet accounting obligations and respond to contractual inquiries.
The legal bases are:
- Article 6(1)(b) GDPR for contractual processing
- Article 6(1)(c) GDPR for legal accounting and tax obligations
- Article 6(1)(f) GDPR for fraud prevention, security and the establishment or defence of legal claims
Programme enrolment provides access to the selected digital work. It does not create personal consultation, coaching, messaging or private-access rights unless a separate written agreement expressly provides otherwise.
7. PAYMENT PROCESSING
Payments may be processed through Wix Payments and the payment method selected at checkout.
Depending on the chosen payment method, payment information may be processed by Wix and one or more payment processors, financial institutions or payment-method providers, including:
- Adyen
- Stripe
- PayPal
- relevant card networks and acquiring banks
- Apple Pay
- Google Pay
The information processed may include:
- name
- billing address
- email address
- payment method
- transaction amount and currency
- payment status
- transaction identifiers
- fraud-prevention and authentication information
- information required by financial and regulatory obligations
Full card details are entered through the relevant payment environment and are not independently stored by Adwoa Theresa Adu-Sanyah.
The legal basis is Article 6(1)(b) GDPR. Processing required to comply with accounting, tax, anti-fraud or financial-regulatory obligations is based on Article 6(1)(c) GDPR or Article 6(1)(f) GDPR.
Wix Payments may allocate transactions to processors including Adyen, Stripe or PayPal. The payment provider selected at checkout may process information under its own privacy notice.
Further information:
Wix:
https://www.wix.com/about/privacy
PayPal:
https://www.paypal.com/de/legalhub/paypal/privacy-full
Apple:
https://www.apple.com/legal/privacy/
Google:
https://policies.google.com/privacy
8. PRIVATE INQUIRIES AND DIRECT COMMUNICATION
When you submit a private inquiry or contact the controller by email, the information you provide is processed to review and respond to the communication.
This may include:
- name
- email address
- subject of the inquiry
- information voluntarily included in the message
- date and time of communication
- subsequent correspondence
Where the inquiry concerns a possible contractual engagement, the legal basis is Article 6(1)(b) GDPR. For other legitimate business communications, the legal basis is Article 6(1)(f) GDPR.
Please do not submit medical records, diagnostic information, financial account information, legal documents or other unnecessary sensitive personal data through the inquiry form.
Submitting an inquiry does not guarantee acceptance, availability or the formation of a contract.
Inquiry information is generally deleted within six months after the communication has concluded, unless a contract follows, consent supports longer retention, legal obligations require storage or the information is required for the establishment, exercise or defence of legal claims.
9. EMAIL COMMUNICATIONS
Email is used for:
- responding to inquiries
- providing purchase confirmations
- delivering account and programme information
- sending security or administrative notices
- communicating changes affecting an active purchase or subscription
Transactional and administrative emails are sent because they are necessary to provide the requested service or perform a contract. The legal basis is Article 6(1)(b) GDPR.
No promotional newsletter is offered at launch. If a newsletter is introduced later, this Privacy Policy and the relevant consent process will be updated before newsletter data is collected.
10. SOCIAL-MEDIA LINKS
The website may contain links to external social-media profiles.
A simple external link does not transmit information to the linked platform merely because this website is visited. Information may be processed by the external platform after the visitor chooses to open the link.
The privacy practices of external platforms are governed by their own policies. No social-media tracking pixel is used on this website at launch.
11. RECIPIENTS OF PERSONAL DATA
Personal data is disclosed only where necessary for the purposes described in this Privacy Policy.
Recipients may include:
- Wix and its affiliated companies
- hosting and technical-service providers
- payment processors
- banks, card networks and acquiring institutions
- accounting and tax advisers
- professional advisers
- public authorities where disclosure is legally required
Service providers acting on instructions are used as processors where legally required. Information is not sold.
12. INTERNATIONAL DATA TRANSFERS
Some service providers may process information outside Germany or the European Economic Area.
Where information is transferred to a country for which the European Commission has issued an adequacy decision, the transfer is based on Article 45 GDPR.
Where no adequacy decision exists, transfers are made subject to an appropriate safeguard under Article 46 GDPR, such as approved standard contractual clauses, or another legally recognised transfer mechanism.
Further information about provider-specific transfers is available in the privacy notices of Wix and the relevant payment provider.
13. RETENTION
Personal data is retained only for as long as required for the relevant purpose.
The following criteria generally apply:
- inquiry information: normally up to six months after completion of the communication
- member-account information: for the duration of the account and afterwards where legal obligations or claims require retention
- programme and subscription information: for the duration of access and the applicable contractual relationship
- order, billing and transaction records: for the statutory periods required under German commercial and tax law
- consent records: for as long as necessary to demonstrate valid consent
- technical security logs: for the period reasonably required for security, troubleshooting and abuse prevention
- analytics information: according to the consent settings and retention periods implemented through Wix
Information may be retained for longer where this is required to establish, exercise or defend legal claims or comply with a binding legal obligation.
14. LEGAL AND CONTRACTUAL REQUIREMENTS
Information marked as required during checkout, account creation or programme enrolment is necessary to provide the selected service or conclude the relevant contract.
Without this information, the purchase, subscription, account or programme access may not be completed.
There is no general legal obligation to provide information through the Private Inquiry form.
15. AUTOMATED DECISION-MAKING
Adwoa Theresa Adu-Sanyah does not use personal data to make decisions based solely on automated processing that produce legal or similarly significant effects.
Payment and fraud-prevention providers may use automated systems to verify transactions, prevent fraud or meet financial-regulatory obligations. Further information is available in the relevant provider’s privacy notice.
16. RIGHTS OF DATA SUBJECTS
Subject to the requirements and limitations of the GDPR, you have the right to:
- obtain access to your personal data under Article 15 GDPR
- request correction under Article 16 GDPR
- request erasure under Article 17 GDPR
- request restriction of processing under Article 18 GDPR
- receive certain data in a portable format under Article 20 GDPR
- object to processing based on legitimate interests under Article 21 GDPR
- withdraw consent at any time under Article 7(3) GDPR
- lodge a complaint with a competent supervisory authority under Article 77 GDPR
To exercise your rights, contact:
info@adwoatheresa.com
Reasonable information may be requested to confirm identity before responding to a data-protection request.
17. RIGHT TO OBJECT
Where personal data is processed on the basis of Article 6(1)(f) GDPR, you have the right to object at any time on grounds relating to your particular situation.
If personal data were ever processed for direct marketing, you would have the right to object to such processing at any time.
18. RIGHT TO LODGE A COMPLAINT
You have the right to lodge a complaint with a data-protection supervisory authority.
The supervisory authority responsible for the controller’s location is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2–4
40213 Düsseldorf
Germany
Telephone: +49 211 38424-0
Email: poststelle@ldi.nrw.de
Website: https://www.ldi.nrw.de/
19. SECURITY
Appropriate technical and organisational measures are used to protect personal data against accidental or unlawful loss, alteration, disclosure or access.
No method of internet transmission or electronic storage can provide absolute security. Security measures are therefore reviewed and adjusted where appropriate.
20. EXTERNAL SYSTEMS
Penumbrata and The Lattice are separate digital systems currently under development. They are not covered by this Privacy Policy until they are made operational through their respective environments.
Each system will have its own privacy information reflecting its actual hosting, storage, payment and data-processing structure before user data is collected.
21. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be updated when the website, legal requirements or processing activities change.
The version and date displayed on this page apply.