Privacy Policy

Lena Aspette LTD ("we", "us", "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains what personal data we collect, how we use it, and your rights.

This policy applies to the websites lenaaspette.com and smartshoppingacademy.com, and to any products, services, or communications provided through them.

1. Who we are

We are the "data controller" responsible for your personal data.

• Company name: Lena Aspette LTD
• Company number: 14759781
• Registered office: 128 City Road, London, United Kingdom, EC1V 2NX
• Contact email: [email protected]
• ICO registration number: ZB715625

We are registered with the UK Information Commissioner's Office (ICO).

2. The personal data we collect

Information you give us — for example when you buy a product, create an account, sign up to our email list, fill in a form, or contact us:

• Name
• Email address
• Telephone number
• Billing information (your card details are processed directly by our payment provider, Stripe — we do not see or store your full card number)
• Account login details
• Any content you submit to us, such as homework or assignments (for example, images of clothing) sent to a coach as part of a coaching programme
• The content of messages you send us

Information we collect automatically when you use our websites:

• IP address, device, and browser information
• Pages you visit and how you interact with our site
• Data collected through cookies and similar technologies (see section 5)

3. How we use your personal data and our legal bases

• To provide the products and services you buy. Legal basis: performance of our contract with you.
• To take payment. Legal basis: performance of our contract with you.
• To send you service messages about your account and purchases (order confirmations, access links, programme logistics). Legal basis: performance of our contract with you.
• To send you marketing emails about our products and offers. Legal basis: your consent, which you give when you sign up to our list or ask to hear from us. If you are already a customer, we may also rely on the "soft opt-in" to email you about our own similar products. You can opt out at any time.
• To respond to your enquiries and provide customer support. Legal basis: performance of our contract and/or our legitimate interests.
• To operate, secure, and improve our websites, including analytics. Legal basis: our legitimate interests and, for non-essential cookies, your consent.
• To meet our legal and regulatory obligations, such as keeping financial records. Legal basis: compliance with a legal obligation.

4. Marketing

Where you have agreed, we send marketing emails about our products, offers, and content. You can opt out at any time by clicking "unsubscribe" in any marketing email, or by emailing [email protected]. Opting out of marketing does not stop service messages about a purchase you have made. We do not currently send marketing text messages (SMS).

5. Cookies and tracking technologies

Our websites use cookies and similar technologies to function, to understand how the site is used, and to deliver and measure advertising. These include:

• Essential cookies necessary for the website and checkout to work, including cookies set by GoHighLevel, the platform that powers our websites and funnels.
• Analytics cookies that help us understand how visitors use our site.
• Advertising cookies, including the Meta (Facebook) Pixel, which lets us measure ad performance and show relevant ads to you on Meta platforms. This involves sharing certain data with Meta.

Where required by law, we ask for your consent before setting non-essential cookies, and you can manage your preferences through our cookie banner or your browser settings.

6. Who we share your data with

We do not sell your personal data for money. However, when we use advertising cookies such as the Meta Pixel, this may be treated as a "sale" or "sharing" of personal information under some US state privacy laws — see section 11.

We share data with third parties who help us run our business, including:

• Stripe — to process payments
• Klaviyo — to manage and send our email marketing
• GoHighLevel — for our customer relationship management, funnels, and website functionality
• Meta (Facebook) — for advertising and measurement, where you have consented to advertising cookies. For these advertising purposes, Meta acts as a controller (or joint controller) in its own right, not only as our processor.
• Our website hosting and IT providers
• Professional advisers such as accountants and lawyers, where necessary
• Regulators, law enforcement, or other authorities where we are required to by law

Providers who process data on our instructions (such as Stripe, Klaviyo and GoHighLevel) do so under data processing terms and are required to keep your data secure.

7. International transfers

Some of our providers (including Stripe, Klaviyo, GoHighLevel, and Meta) are based outside the United Kingdom, including in the United States. Where your personal data is transferred outside the UK, we rely on appropriate safeguards — such as a UK adequacy decision (including the UK Extension to the EU–US Data Privacy Framework for certified providers) or the International Data Transfer Agreement / Standard Contractual Clauses.

8. How long we keep your data

We keep your personal data only for as long as necessary for the purposes set out in this policy. For example:

• Account and marketing data: until you close your account, unsubscribe, or withdraw your consent, and for a reasonable period afterwards.
• Order and financial records: typically for six years, to meet tax and legal requirements.

9. How we protect your data

We use appropriate technical and organisational measures to keep your personal data secure. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

10. Your rights (UK and EU)

Under UK and EU data protection law, you have the right to:

• Access the personal data we hold about you
• Have inaccurate data corrected
• Have your data erased in certain circumstances
• Restrict or object to our processing of your data
• Receive your data in a portable format
• Withdraw your consent at any time, where we rely on consent

To exercise any of these rights, email us at [email protected]. You also have the right to complain to the ICO at ico.org.uk or by calling 0303 123 1113.

11. Your US State Privacy Rights

If you live in a US state with a comprehensive privacy law (for example California, and states such as Virginia, Colorado and Connecticut), you may have rights including the right to: access the personal information we hold about you; correct it; delete it; and opt out of the "sale" or "sharing" of your personal information and of targeted advertising. We will not discriminate against you for exercising these rights.

We share certain identifiers and online activity with advertising partners such as Meta in order to deliver and measure advertising. Under some US state laws this may be considered a "sale" or "sharing" of personal information.

To opt out, or to exercise any of the rights above, email us at [email protected] and tell us what you would like to do. We may need to verify your identity before we respond.

12. Children

Our products and websites are intended for adults aged 18 and over. We do not knowingly collect personal data from children.

13. Third-party links

Our websites may contain links to third-party websites. We are not responsible for the privacy practices of those websites.

14. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top shows when it was last revised.

15. Contact us

If you have any questions about this policy or how we handle your data, contact us at:

Lena Aspette LTD, 128 City Road, London, United Kingdom, EC1V 2NX Email: [email protected]