1. Who we are
We are Ethereal Flow Studios Ltd, a private limited company registered in England and Wales.
Company number: 16462152
Registered office: 47 Portland Road, Hove, England, BN3 5DQ
Email: info@ethereal-flow.co.uk
Website: https://ethereal-flow.co.uk
For the purposes of UK data protection law, Ethereal Flow Studios Ltd is the data controller for the personal data we collect and use.
2. What personal data we collect
Contact and identity details
This may include your name, email address, billing details, order details and messages you send to us.
Purchase and payment-related data
When you buy from us, we may collect order information, payment status, transaction references, purchase history, refund requests and customer support records.
We do not directly store your full card details. Payments are processed by third-party payment providers.
Sleep assessment responses
When you complete the sleep assessment, we collect the answers you provide so we can understand your night-time pattern and, if you purchase, personalise your protocol.
This may include information about your sleep patterns, goals, preferences, current challenges, lifestyle context, emotional state, stress levels and anything else you choose to tell us.
Website and analytics data
This may include IP address, browser type, device type, pages visited, time spent on pages, referral source, approximate location and interactions with the website.
Marketing and advertising data
If we use advertising or tracking tools, we may collect information about how you interact with our website, ads, landing pages, emails, assessment and checkout flow.
3. How we collect your data
We collect personal data when you:
- visit our website
- complete the sleep assessment
- buy from us or complete checkout
- contact us by email or form
- request a refund
- interact with our emails, ads or website
- accept cookies or tracking technologies where required
4. How we use your personal data
We use your personal data only where we have a lawful reason to do so.
To process and deliver your order
We use your name, email address, order details, payment status and sleep assessment responses to process your purchase, prepare your Personalised Sleep Protocol, deliver it to you and contact you about your order.
Lawful basis: contract.
To personalise your Personalised Sleep Protocol
We use your sleep assessment responses to create a personalised digital sleep-support protocol based on the information you provide.
Lawful basis: contract where you purchase the protocol.
To manage assessment leads and customer journeys
If you complete the sleep assessment but do not immediately purchase, we may retain the contact and assessment information you provided so we can manage your customer journey, respond to enquiries and, where permitted, follow up about the Personalised Sleep Protocol.
Lawful basis: legitimate interests, consent where required, and contract where applicable.
To provide customer support
We use your contact details, messages, order details, refund requests and support history to respond to questions, resolve access issues, handle complaints and support your purchase.
Lawful basis: contract and legitimate interests.
To handle refunds, disputes, fraud prevention and business protection
We may use order details, payment status, communications, refund requests, technical data and support records to manage refunds, deal with disputes, protect against fraud or misuse and enforce our Terms & Conditions.
Lawful basis: contract, legitimate interests and legal obligation where applicable.
To comply with legal, tax, accounting and regulatory duties
We use order records, invoices, transaction records, correspondence and related business records where needed for tax, accounting, legal, regulatory or compliance purposes.
Lawful basis: legal obligation and legitimate interests.
To improve our website, products and customer journey
We may use website usage data, analytics data, customer feedback and order journey data to understand what is working, improve the website, improve the offer, fix problems and make the customer experience clearer.
Lawful basis: legitimate interests or consent where required.
To send marketing emails
We may use your name, email address, purchase history and marketing preferences to send marketing emails where you have opted in, where you have bought from us and the law allows a soft opt-in, or where we otherwise have permission to contact you.
Lawful basis: consent or legitimate interests, depending on the context.
You can unsubscribe from marketing emails at any time.
To run advertising and measure performance
If we use advertising, analytics, pixels, tags or similar tracking tools, we may use website usage data, cookie data, ad interaction data and conversion data to measure performance, improve campaigns and show relevant ads.
Lawful basis: consent where required.
5. Sleep assessment and wellbeing information
Your sleep assessment responses may include personal details about your sleep, stress, wellbeing, lifestyle, emotions or personal goals.
We use this information to understand your night-time pattern and, if you purchase, to create, personalise, deliver and support your Personalised Sleep Protocol.
Please do not provide information that is unnecessary, excessive or highly sensitive unless it is relevant to your assessment or order.
7. International transfers
Some of the tools and platforms we use may process personal data outside the UK.
Where this happens, we take reasonable steps to make sure appropriate safeguards are in place, such as UK-approved transfer mechanisms, contractual protections or equivalent safeguards required by data protection law.
8. How long we keep your data
We keep personal data only for as long as reasonably needed for the purposes described in this policy.
As a practical guide:
- order and transaction records may be kept for up to 6 years for tax, accounting, legal and business record purposes
- customer support emails may be kept for up to 6 years where needed for records, disputes or legal protection
- sleep assessment responses may be kept for up to 24 months after submission or delivery unless we need to keep them longer for support, dispute handling, legal reasons or service improvement
- marketing data is kept until you unsubscribe, withdraw consent or ask us to stop contacting you
- analytics and cookie data is kept according to the settings of the relevant analytics or advertising tools
We may anonymise data so it can no longer identify you. Anonymised data may be kept and used for business analysis, service improvement or research into our offer.
10. Marketing emails
We may send you marketing emails if you have opted in, requested updates, purchased from us where soft opt-in rules apply or otherwise given us permission to contact you.
Marketing emails may include updates, offers, educational content, product information and Ethereal Flow news.
You can unsubscribe from marketing emails at any time by using the unsubscribe link in the email or contacting us at info@ethereal-flow.co.uk.
If you unsubscribe from marketing emails, we may still send service emails about your order, delivery, refund request, assessment, access link or customer support issue.
11. Security
We take reasonable steps to protect your personal data from unauthorised access, loss, misuse, alteration or disclosure.
No website, email system, platform or digital service can be guaranteed completely secure. You are responsible for keeping any private links, access details or download links safe and not sharing them publicly.
12. Your data protection rights
Your rights under UK data protection law may include:
Access, correction, deletion, restriction, objection, data portability, withdrawal of consent and the right to complain to the Information Commissioner’s Office.
To make a request, contact us at info@ethereal-flow.co.uk.
We may need to verify your identity before responding.
13. Complaints
If you have a concern about how we use your personal data, contact us first so we can try to resolve it:
You also have the right to complain to the UK Information Commissioner’s Office.
14. Links to other websites
Our website or digital products may contain links to third-party websites, platforms, payment providers, social media pages or services.
We are not responsible for the privacy practices, content or policies of third-party websites or platforms.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time.
The latest version will be published on our website with the updated date shown at the top.