Legal

Privacy Policy

Last updated: March 2026

1. Data Controller

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

Driftless OÜ
Sepapaja 6
10415 Tallinn, Estonia

Represented by: Christopher Sorg
Contact: [email protected]

2. What Data We Collect

When you submit a coaching request through our website, we collect the following personal data:

  • First name and last name
  • Email address
  • Business name or professional role
  • Information you provide about your current challenges

We also collect standard technical data through our website infrastructure, including IP addresses, browser type, and pages visited, for the purpose of maintaining site security and performance.

3. Purpose and Legal Basis for Processing

We process your personal data for the following purposes:

  • Responding to coaching inquiries — to evaluate whether our coaching is a good fit for your situation and to schedule a consultation call. Legal basis: legitimate interest (Article 6(1)(f) GDPR) and pre-contractual measures (Article 6(1)(b) GDPR).
  • Communication — to respond to your messages and follow up on your inquiry. Legal basis: legitimate interest.
  • Website analytics — to understand how visitors use our site and improve the user experience. Legal basis: legitimate interest. Analytics data is anonymized and does not identify individual users.

4. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this policy. Inquiry data is retained for a maximum of 24 months from the date of submission, unless a coaching relationship is established, in which case data is retained for the duration of the engagement plus 3 years for legal and accounting purposes.

5. Data Sharing

We do not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of service providers who assist in operating our website and business:

  • Email and communication tools (e.g., email service providers)
  • Website hosting and infrastructure providers
  • Scheduling tools used to arrange coaching calls

All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6. International Data Transfers

Driftless OÜ is registered in Estonia, a member state of the European Union. Your data is processed within the EU/EEA. Where any service provider processes data outside the EU/EEA, we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR.

7. Your Rights

Under the General Data Protection Regulation (GDPR), you have the following rights:

  • Right of access — to obtain a copy of the personal data we hold about you
  • Right to rectification — to correct inaccurate or incomplete data
  • Right to erasure — to request deletion of your personal data
  • Right to restriction — to request that we limit how we use your data
  • Right to data portability — to receive your data in a structured, machine-readable format
  • Right to object — to object to processing based on legitimate interest

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or the supervisory authority in your country of residence.

8. Cookies

Our website uses minimal cookies necessary for site functionality and anonymous analytics. We do not use advertising or tracking cookies. By using our website, you consent to the use of these functional cookies.

9. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or disclosure. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised date. We encourage you to review this policy periodically.

11. Contact

For any questions or requests regarding this Privacy Policy or your personal data, contact:

Driftless OÜ — ADHD Growth Lab
Sepapaja 6, 10415 Tallinn, Estonia
Christopher Sorg
[email protected]