Privacy Policy

1. Who We Are

Data Controller: Karolina Sky Rafalski, operating as PIVOT Blueprint™ / Identity Architecture™

Website: karolinasky.com

Contact: info@karolinasky.com

Address: Bruzdowa 56, Warsaw, 02-991, Poland

Karolina Sky Rafalski is the data controller responsible for your personal data collected through this website. If you have any questions about how your data is used, please contact us at the email address above.

2. What Data We Collect

We may collect and process the following categories of personal data:

Data you provide directly

• Identity data — your first name, last name
• Contact data — your email address
• Application data — responses you provide when applying for the PIVOT Blueprint Cohort or VIP Identity Reinvention programme, including information about your current situation, professional context and what brings you to this work
• Communication data — any messages you send via email or contact forms

Data collected automatically

• Technical data — IP address, browser type, operating system, pages visited, time on site. This data is collected anonymously through Google Fonts (which loads from Google servers) and any analytics tools used on this site

We do not collect sensitive personal data such as information about your race, ethnicity, religious beliefs, health, sexual orientation or political opinions. We do not carry out automated decision-making or profiling.

3. How We Collect Your Data

• Directly from you — when you complete an application form, subscribe to The Pivot Point newsletter, take the Free Pivot Assessment or contact us by email
• Automatically — through cookies and similar technologies when you browse this website. See Section 9 on Cookies for more detail
• Through third-party platforms — Kajabi (email marketing, programme delivery and form submissions) and Mailchimp (newsletter)

4. How We Use Your Data

We use your personal data for the following purposes:

• To respond to your enquiries and communicate with you about your application or interests
• To deliver the services you have requested — the PIVOT Blueprint Cohort, VIP Identity Reinvention programme, or Free Pivot Assessment
• To send The Pivot Point newsletter and related marketing communications, where you have opted in
• To process payments securely for any programmes or products purchased
• To manage our business operations and maintain records
• To comply with legal obligations
• To improve the website and understand how visitors use it

5. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data on the following legal grounds:

• Consent — where you have actively ticked a consent checkbox when submitting an application form or subscribing to the newsletter. You may withdraw your consent at any time by emailing info@karolinasky.com
• Contract — where processing is necessary to deliver a service you have purchased or requested
• Legitimate interests — where we have a genuine and proportionate business reason to process your data, such as responding to enquiries or maintaining business records, and where these interests are not overridden by your rights
• Legal obligation — where we are required by law to process your data

6. Third-Party Service Providers

We share your personal data with the following third-party platforms solely to deliver our services. Each is bound by its own privacy policy and processes data only as instructed:

• Kajabi (kajabi.com) — email marketing, programme delivery, application form processing and lead management. Kajabi is based in the United States and participates in data protection frameworks for international transfers. Kajabi Privacy Policy →
• Stripe (stripe.com) — payment processing for programme purchases. Stripe is based in the United States and is PCI-DSS compliant. We do not store your full card details. Stripe Privacy Policy →
• Mailchimp / Intuit — newsletter delivery for The Pivot Point. Based in the United States. Mailchimp Privacy Policy →
• Google — Google Fonts are loaded from Google servers, which may collect technical data about your visit. Google Calendar is used for booking discovery calls. Google Privacy Policy →

We do not sell your personal data to any third party. We do not share your data with third parties for their own marketing purposes.

7. International Data Transfers

Some of our third-party service providers are based outside the European Economic Area (EEA), including in the United States. Where we transfer your data outside the EEA, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the European Commission or participation in recognised data protection frameworks.

If you would like more information about the safeguards in place for any specific transfer, please contact us at info@karolinasky.com.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

• Application data and client records are retained for up to 7 years for tax and legal compliance purposes
• Newsletter subscriber data is retained until you unsubscribe or request deletion
• Enquiry and communication data is retained for up to 3 years unless a longer period is required

When your data is no longer needed, it is securely deleted or anonymised.

9. Cookies

This website uses cookies — small text files stored on your device — to ensure the site functions correctly and to understand how visitors use it.

Essential cookies are necessary for the website to function. They cannot be switched off.

Third-party cookies may be set by Google (via Google Fonts) when you visit this site. These may collect your IP address and browser information.

A cookie notice banner appears on your first visit to this site. You can manage or withdraw your consent at any time by adjusting your browser settings. Please note that disabling certain cookies may affect how the site functions.

10. Your Rights Under GDPR

As a resident of the European Economic Area, you have the following rights regarding your personal data:

• Right of access — you may request a copy of the personal data we hold about you
• Right to rectification — you may ask us to correct inaccurate or incomplete data
• Right to erasure — you may request that we delete your personal data where there is no compelling reason to continue processing it
• Right to restrict processing — you may ask us to pause processing your data in certain circumstances
• Right to data portability — you may request your data in a structured, machine-readable format
• Right to object — you may object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please email info@karolinasky.com. We will respond within one month. We will not charge a fee for reasonable requests, though we may ask you to verify your identity.

If you are not satisfied with how we handle your data, you have the right to lodge a complaint with your national data protection authority. In Poland, this is the Urząd Ochrony Danych Osobowych (UODO).

11. Marketing Communications

We will only send you marketing communications — including The Pivot Point newsletter and updates about our programmes — if you have actively opted in by ticking the consent checkbox on a form, or by subscribing to the newsletter.

You can unsubscribe at any time by clicking the unsubscribe link in any email, or by emailing info@karolinasky.com. Opting out of marketing does not affect data held for other purposes, such as programme delivery.

12. Data Security

We take appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, alteration or disclosure. Our third-party service providers are selected for their commitment to data security and are required to process your data only as instructed.

In the event of a data breach that is likely to affect your rights and freedoms, we will notify you and the relevant supervisory authority as required by law.

13. Children’s Privacy

This website and all services offered through it are intended for adults aged 18 and over only. We do not knowingly collect personal data from children under the age of 16. If you believe a child has provided us with their data, please contact us immediately at info@karolinasky.com and we will delete it promptly.

14. Third-Party Links

This website contains links to third-party websites including LinkedIn, Facebook, Instagram and external service providers. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies when you visit them.

15. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. When we do, we will update the “Last updated” date at the top of this page. If you are subscribed to The Pivot Point newsletter, we will notify you of significant changes by email.

Your continued use of this website after any changes constitutes your acceptance of the updated policy.

16. Contact

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

Karolina Sky Rafalski
Bruzdowa 56, Warsaw, 02-991, Poland
Email: info@karolinasky.com
Website: karolinasky.com