1. Who are we?
Divine Footprint is a trade name of Thoughts Reflections, the sole proprietorship of Deariel Maynard, based in Capelle aan den IJssel, the Netherlands.
Contact details:
- Name: Deariel Maynard, t/a Divine Footprint (Thoughts Reflections)
- Email: thedivinefootprint@gmail.com
- Website: thedivinefootprint.com
- Chamber of Commerce (KVK) number: 81371829
- Establishment number: 000047673028
Deariel Maynard is the data controller within the meaning of the General Data Protection Regulation (GDPR).
2. What personal data do we process?
Divine Footprint processes personal data when you use our services, visit our website, or contact us. Our services include, among others, The Divine Footprint Method™, The Divine Step, the Seven Prints Framework, the e-books (Seven Prints series), the Seven Prints App platform (including Tree of Lives), coaching programmes, and merchandise.
2.1 Data you provide to us
| Category | Data | When |
|---|---|---|
| Contact details | Name, email address | Newsletter sign-up, contact form |
| Account data | Name, email address, password (encrypted) | Seven Prints App registration |
| Order data | Name, address, payment details | Purchase of e-books, courses, merchandise |
| Communications | Message content | Email or contact form |
2.2 Data collected automatically
| Category | Data | Purpose |
|---|---|---|
| Technical data | IP address, browser type, device, operating system | Website functionality and security |
| Usage data | Pages visited, click behaviour, session duration | Improving the website experience |
| Cookies | Functional and analytical cookies | See Cookie Policy |
2.3 Data from AI Character Chats
| Category | Data | Purpose |
|---|---|---|
| Chat messages | Text you enter in the Character Chat | Generating an AI response |
| AI responses | Responses generated by AI | Displaying the conversation, quality improvement |
| Session metadata | Selected character, timestamp, session duration | Technical operation and analysis |
Important: Your chat conversations are not used to train the AI model. Conversations are not shared with third parties unless required by law. See also the AI Disclaimer.
2.4 Data within the Seven Prints App platform
| Category | Data | Purpose |
|---|---|---|
| Profile data | Name, profile photo (optional) | User profile |
| Progress data | Progress in programmes/prints | Personalised experience |
| Community contributions | Posts, replies in Tree of Lives | Community interaction |
| Reflection data | Personal notes (if available) | Visible only to the user |
3. Why do we process your data?
| Purpose | Legal basis (GDPR) |
|---|---|
| Performance of the contract (delivery of e-books, courses, platform access) | Article 6(1)(b) |
| Communication about your order or account | Article 6(1)(b) |
| Sending the newsletter (opt-in only) | Article 6(1)(a) — consent |
| Improving the website and platform | Article 6(1)(f) — legitimate interest |
| Security of the website and platform | Article 6(1)(f) — legitimate interest |
| Legal obligations (e.g. tax administration) | Article 6(1)(c) — legal obligation |
| Community functionality (Tree of Lives) | Article 6(1)(b) |
| AI Character Chats (generating responses, quality improvement) | Article 6(1)(b) & (f) |
4. How long do we retain your data?
| Category | Retention period |
|---|---|
| Account data | As long as your account is active, plus 1 year after deletion |
| Order data | 7 years (statutory retention obligation) |
| Newsletter data | Until consent is withdrawn |
| Communications | Up to 2 years after the last contact |
| Technical/analytical data | Up to 26 months |
| Community contributions | As long as the account is active; anonymised upon deletion |
| Reflection data | As long as the account is active; immediately deleted upon account deletion |
| AI Character Chat conversations | Up to 90 days after the conversation; then anonymised or deleted |
5. With whom do we share your data?
Divine Footprint never sells your data to third parties.
We may share data with the following parties, solely for the purposes described above:
| Party | Purpose | Safeguard |
|---|---|---|
| Hosting provider | Website and platform storage | Data processing agreement |
| Payment provider | Payment processing | Data processing agreement, PCI-DSS |
| Email provider | Newsletter delivery | Data processing agreement |
| Accountant | Financial administration | Confidentiality obligation |
| Government authorities | Only when legally required | Legal basis |
Transfers outside the EU/EEA: If a processor is established outside the European Economic Area, such transfer is only carried out on the basis of an adequacy decision or with appropriate safeguards (Standard Contractual Clauses).
6. Your rights
Under the GDPR, you have the following rights:
| Right | Explanation |
|---|---|
| Right of access (Art. 15) | You can request which data we process about you |
| Right to rectification (Art. 16) | You can have incorrect data corrected |
| Right to erasure (Art. 17) | You can request that your data be deleted |
| Right to restriction (Art. 18) | You can request that processing be temporarily restricted |
| Right to data portability (Art. 20) | You can receive your data in a structured format |
| Right to object (Art. 21) | You can object to processing based on legitimate interest |
| Right to withdraw consent (Art. 7) | You can withdraw previously given consent at any time |
How do you exercise these rights? Send an email to thedivinefootprint@gmail.com with your request. We will respond within 30 days.
Filing a complaint: If you believe we are not handling your personal data correctly, you may file a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl, tel: +31 88 1805 250) or with your local data protection authority.
7. Security
Divine Footprint takes appropriate technical and organisational measures to protect your personal data:
- Encrypted connections (SSL/TLS) on all websites and platforms
- Encrypted storage of passwords
- Restricted access to personal data
- Regular evaluation of security measures
8. Cookie Policy
For detailed information about the cookies we use, please refer to our Cookie Policy.
9. Data breaches
In the event of a data breach, Divine Footprint acts in accordance with the GDPR:
- The data breach will be reported to the relevant supervisory authority as soon as possible, and where feasible within 72 hours.
- If the data breach poses a high risk to your rights, you will be notified without undue delay.
- Divine Footprint maintains a register of all data breaches, including the facts, consequences, and remedial measures taken.
10. Changes
This privacy policy may be amended. The most current version is always available on this page. In the event of material changes, we will inform you by email or through the platform.
11. Contact
For questions about this privacy policy or about the processing of your personal data:
- Email: thedivinefootprint@gmail.com
- Website: thedivinefootprint.com