Privacy Policy - Verve Leaders
Operated by GLEOW LLC
Effective: 22nd June 2025
1. WHO WE ARE
This Privacy Policy explains how we collect, use, and protect your personal data when you visit our website, use our services, or interact with Verve Leaders.
Legal Entity: GLEOW LLC
Registered Address: 2410 Hill Street, Santa Monica, CA 90405, USA
Email Contact: connect@verveleaders.com
By providing us with your data, you confirm you are over 13 years old and accept the terms of this policy.
2. WHAT PERSONAL DATA WE COLLECT – AND WHY
“Personal data” means any information that can identify you. We may collect and process the following categories:
a) Communication Data- Includes emails, form submissions, social media messages.
Why: To respond to your enquiries and maintain records.
Legal basis: Legitimate interest.
b) Customer & Transaction Data. Includes name, email, address, Stripe details, purchase history.
Why: To deliver services and fulfil contracts.
Legal basis: Contract performance + legal obligation.
c) Marketing Data. Includes opt-ins, email preferences, campaign interaction.
Why: To send you relevant updates, offers, and content.
Legal basis: Consent or legitimate interest.
d) Technical & Website Data. Includes IP address, browser, time zone, pages visited, and cookies (via Meta Pixel or similar).
Why: To protect our site, analyse traffic, and serve relevant ads.
Legal basis: Legitimate interest.
3. SENSITIVE DATA. We may collect limited sensitive personal data (such as information about health, trauma, or emotional wellbeing) when it is voluntarily shared by clients in the course of coaching, workshops, or community discussions. We collect and store this information only when necessary to support the services you’ve requested from us.
This data is:
Held securely
Accessed only by those who need it to deliver services
Never shared with third parties without explicit consent, unless required by law
We retain sensitive data only for as long as we work with you, or as required for legal or safeguarding purposes.
By working with Verve Leaders, you acknowledge this use and agree that we may process limited sensitive data to support your experience.
4. HOW WE COLLECT YOUR DATA
We collect data:
When you fill in a form, purchase a service, or contact us.
Automatically via cookies or tracking tools.
From trusted third-party platforms including: STRIPE (payment processing) CONVERTKIT (KIT) (email marketing), SCOREAPP (quizzes and tools), WEBFLOW (website), META PIXEL (advertising)
5. HOW WE USE YOUR DATA
We use your data to:
Deliver coaching, courses, and community services.
Communicate with you
Send newsletters or marketing (if you’ve opted in)
Improve our website and advertising
Comply with legal and financial record keeping
We will only use your data for the purposes collected or for closely related reasons (e.g. audit).
We do not use automated decision-making or profiling.
6. MARKETING AND COMMUNICATION PREFERENCES
You’ll only receive marketing from us if:
You’ve explicitly opted in, or
You’ve purchased from us and haven’t opted out
You can unsubscribe at any time via links in our emails or by contacting connect@verveleaders.com.
We do not sell your data or share it with third parties for their own marketing.
7. COOKIES AND TRACKING
We use cookies and tools like Meta Pixel to:
Understand your behaviour on our site
Improve site performance
Serve relevant ads
Our website is in the process of implementing a cookie banner to comply with UK and EU law. Until then, use of the site implies consent to essential cookies.
You can manage cookies via browser settings.
8. DISCLOSURES OF YOUR PERSONAL DATA
We may share your data with: Trusted service providers (e.g. Stripe, Webflow, ConvertKit, Meta)
Professional advisors (e.g. legal, financial, or tax)
Legal authorities if required by law
Future partners in the event of a business restructure or sale
All third parties must process your data securely and under written agreement with us.
9. INTERNATIONAL DATA TRANSFERS
As a US-based company, your data may be transferred internationally.
We ensure appropriate safeguards (e.g. STANDARD CONTRACTUAL CLAUSES) are in place for transfers from the UK or EU to the US and beyond.
10. DATA SECURITY
We protect your data with: Secure cloud storage
Password protection
Limited access by staff on a need-to-know basis.
In the event of a data breach, we will notify you and any regulator if legally required.
11. DATA RETENTION
We retain data only for as long as necessary:
To deliver services
To meet legal, accounting, or recordkeeping obligations
We may anonymise some data for research or insight after this period.
12. YOUR RIGHTS
You have the right to
:Request access to your data
Request correction or deletion
Object to or restrict processing
Withdraw consent (where applicable)
Request data portability
To exercise these rights, email us at connect@verveleaders.com
We may request ID to confirm your identity before acting on your request.
13. COMPLAINTS
If you are unhappy with how we’ve handled your data, please contact us first.UK clients can also contact the Information Commissioner’s Office (ICO) at www.ico.org.uk.. US clients may have rights under state law (e.g. California Consumer Privacy Act) which we aim to uphold.
14. THIRD-PARTY LINKS
Our website may link to other sites. We are not responsible for their privacy practices. Always review third-party policies before submitting your data.
15. CHANGES TO THIS POLICY
We may update this Privacy Policy periodically. The latest version will always be posted on our website with a new Effective Date.
16. CONTACT
If you have questions about this Privacy Policy or your data:
GLEOW LLC
2410 Hill Street
Santa Monica, CA 90405, USA
connect@verveleaders.com