Privacy Policy

This Privacy Policy explains how REVIVAL OF LIFE FZE collects and processes personal data in connection with the Website (www.eugeniugurin.com), applications, enquiries, pre-contractual communications and related marketing. It is drafted primarily by reference to the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and the Company’s current data flows.

SCOPE: This Policy covers the Website and pre-contractual / website-related processing. Where a person becomes a client and additional sensitive information is processed in connection with a particular Service, the Client Agreement and any specific informed consent or privacy notice supplied for that Service may also apply. Any capitalised terms used herein and not separately defined shall have the meaning assigned to them in the Terms & Conditions.

1. Controller and Contact Details

1.1 REVIVAL OF LIFE FZE, Licence No. 4431352.01, Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates, is the controller responsible for the personal data described in this Policy unless another controller is expressly identified.

1.2 Privacy and data-rights requests may be sent to support@eugeniugurin.com. Telephone: +353 89 946 1853.

1.3 References to "you" mean the individual to whom the personal data relates, including a Website visitor, applicant, prospective client, former applicant or marketing recipient.

2. Personal Data We Collect

2.1 Information you provide through the application form:

• name and surname
• email address and telephone number
• professional role
• preferred contact method
• selected service or programme interest
• areas you wish to develop (for example public speaking, communication, voice and speech, presentation skills, storytelling, leadership communication or camera delivery)
• the free-text description of your objective
• the status of any consent or acknowledgement selected in the form

2.2 Information collected during follow-up communications

• communications and correspondence with us by email, telephone, WhatsApp, Telegram or other agreed channels
• information about your objectives, professional context, planned public appearances, presentations, scripts, videos or other materials you choose to provide
• information required to prepare a proposed Client Agreement, Service Schedule/Appendix, invoice or payment instruction
• records reasonably necessary to manage your enquiry, demonstrate communications or comply with legal obligations

2.3 Technical and security data

2.3.1 The Website does not currently use Google Analytics, Meta Pixel, Google Ads tags or other non-essential analytics or advertising tracking technologies. However, the hosting, serverless, security and network infrastructure used to deliver the Website may generate limited technical logs, such as timestamps, request metadata, IP addresses, browser or device information and security events, where technically necessary for transmission, troubleshooting, abuse prevention, system integrity or security.

2.3.2 We do not use such technical logs to build advertising profiles unless this Policy and, where required, the Website consent mechanism are updated before that processing begins.

3. Sensitive and Highly Personal Information

3.1 The standard Website application is not intended to collect medical diagnoses, medication details, clinical records or other medical history or sensitive information. You should not submit such information through the general Website form unless it is genuinely necessary to explain your request and you choose to do so.

3.2 A free-text field allows a user technically to disclose information of a highly personal nature. During subsequent communications, a prospective client may also voluntarily discuss fears, nervousness, tension, emotional experiences, childhood or past experiences, perceived internal barriers or bodily sensations which are relevant to communication and performance issues. Applicants are asked not to include medical, diagnostic or other sensitive information in free-text fields, which are not intended to collect it. Where such information is nonetheless provided, it is minimised and deleted or isolated as soon as it is no longer necessary for the specific request.

3.3 Where information qualifies as sensitive personal data or otherwise attracts enhanced protection under applicable law, we will process it only where a lawful basis exists and only to the extent necessary for the relevant purpose. We do not treat voluntary disclosure as authority to use sensitive information for unrelated marketing or profiling.

3.4 If a person becomes a client and the agreed non-clinical Service may involve discussion of particularly sensitive matters or use of techniques or exercises for which an express informed acknowledgement is appropriate, the Company may provide a separate consent or notice. That document does not convert the Service into medical or psychological treatment.

4. How Website Applications Are Processed

4.1 The Website application form is processed through hosting infrastructure located in Frankfurt, Germany.

4.2 Information submitted through the application form, including the information you provide and the status of relevant consent checkboxes, is transmitted to the Company through Telegram for the purpose of reviewing and handling your application.

4.3 Access to application data is restricted to authorised persons who require such access for the relevant business purpose.

4.4 After an application is received, communications may continue through WhatsApp, Telegram, email or telephone depending on your preference and the practical arrangements agreed with you.

4.5 The use of Telegram, WhatsApp, hosting and other third-party infrastructure may involve processing by those providers under their own terms and may involve processing or storage in countries determined by their infrastructure. We address international transfers in section 10.

5. Purposes of Processing

Handle an application or enquiry — receive, review and respond to your request; identify the requested format; communicate with you; decide whether we can offer a suitable Service. Legal basis: your request and consent where required; processing necessary to take requested pre-contractual steps; and other lawful grounds available under applicable law.

Prepare and conclude a Client Agreement — prepare proposed terms, service scope, schedules, invoices and payment instructions; maintain pre-contractual records. Legal basis: steps requested before contracting; performance or preparation of a contract; compliance with legal obligations.

Operate and secure the Website — transmit forms, maintain availability, diagnose errors, prevent abuse, protect systems and preserve security evidence. Legal basis: our lawful operational and security interests and legal obligations, to the extent recognised by applicable law.

Legal and compliance — maintain records required by law, respond to lawful authority requests, establish, exercise or defend legal claims, and protect rights. Legal basis: applicable legal obligations and lawful processing exceptions, including legal-claim related processing where available.

Marketing — send optional news, programme information, discounts, updates or other commercial/informational communications. Legal basis: your separate marketing consent where consent is required.

Under the UAE PDPL, processing is based on the grounds set out in this section (including your consent and the recognised exceptions). Where the EU GDPR or UK GDPR applies to a particular individual, the corresponding lawful basis is relied upon instead.

6. Consent and Pre-Contractual Processing

6.1 Where we rely on consent, consent must be specific to the processing for which it is requested and may be withdrawn using the methods described in this Policy. Withdrawal does not make prior lawful processing unlawful.

6.2 Submitting an application requires us to process the information necessary to receive and respond to that application. Consent to receive marketing is separate and optional.

6.3 We do not use a general "use of the Website equals consent" formula as a substitute for a legally required specific consent.

6.4 Where applicable law permits processing without consent, including for the establishment, exercise or defence of legal claims or other statutory exceptions, we may rely on that ground to the extent the legal conditions are satisfied.

7. Marketing Communications

7.1 If you separately opt in, we may send informational or commercial communications concerning programmes, services, offers, discounts, updates, project news or related content.

7.2 Marketing consent is not required to submit an application or receive a response to that application.

7.3 You may withdraw marketing consent at any time by using an unsubscribe mechanism included in the message, where available, or by contacting support@eugeniugurin.com. We will retain only the minimum suppression information reasonably required to respect the opt-out and demonstrate compliance.

7.4 We do not currently use automated profiling or behavioural advertising based on Website analytics. If this changes, we will update this Policy and implement any required consent mechanism before the relevant tracking begins.

8. Recipients and Service Providers

8.1 We may disclose personal data only to recipients that reasonably need it for the relevant purpose, subject to appropriate legal and organisational safeguards. Current or potential categories include hosting/serverless providers; Telegram in connection with the application transmission flow; WhatsApp/Meta where communications occur through WhatsApp; email and messaging infrastructure; payment providers and banks where a transaction proceeds; professional advisers; and public authorities where disclosure is legally required.

8.2 A third party may act as our processor, independent controller or both for different processing activities. Its own privacy notice may apply to processing it determines independently.

8.3 We do not sell personal data.

9. Payment Data

9.1 If you proceed to payment through a third-party payment provider, payment-account or card details entered directly into that provider’s interface are processed by that provider. We may receive transaction status, payer identity, amount, currency, reference, invoice information and other data needed for accounting and contract administration.

9.2 Payment may also occur by bank transfer. Banking and payment records may be retained as required for accounting, tax, audit, anti-fraud, dispute or other legal purposes.

10. International Transfers

10.1 The Company is established in the United Arab Emirates and uses service providers whose infrastructure may process personal data outside the UAE. The current Website form is processed through infrastructure located in Frankfurt, Germany before transmission through the Telegram API.

10.2 Where UAE law requires conditions or safeguards for transferring personal data outside the UAE, we will rely on a permitted transfer mechanism or legal exception and will take reasonable steps appropriate to the nature of the data, the recipient and the processing.

10.3 Where an additional data-protection regime applies to a particular individual or transfer, we will apply any mandatory transfer requirement of that regime to the extent legally applicable to us.

11. Retention

Applications that do not become clients — normally up to 12 months after the last substantive communication, unless a shorter period is appropriate or longer retention is required for a legal claim, complaint, compliance issue or explicit ongoing request.

Marketing contact and consent records — for as long as marketing consent remains active; after opt-out, minimal suppression/consent evidence may be retained for as long as needed to honour the opt-out and for a reasonable compliance period.

Client and transaction records — for the period required by the Client Agreement and applicable accounting, tax, limitation, dispute and other legal retention requirements. The specific retention period may therefore exceed the active Service period.

Sensitive information disclosed before contracting — only for as long as reasonably necessary to evaluate or handle the request, unless it forms part of a legally necessary client, safety, complaint or claims record. Unnecessary sensitive detail should be deleted or minimised earlier where practicable.

Technical/security logs — for a limited period proportionate to security, troubleshooting and abuse-prevention needs, unless an incident requires longer preservation.

Retention periods are subject to legal holds, active disputes, mandatory statutory periods and technical backup cycles. When personal data is no longer required, we will delete, anonymise or securely isolate it as appropriate to the system and legal context.

12. Security and Confidentiality Measures

12.1 We apply reasonable technical and organisational measures proportionate to the nature of the personal data and our current operating model, including access restriction, account security, secure device practices, confidentiality controls and review of the systems used to transmit and store applications.

12.2 No internet or messaging system can be guaranteed to be completely secure. You should avoid sending unnecessary sensitive information through ordinary messaging channels and should notify us if you believe information has been sent to the wrong recipient or an account may be compromised.

12.3 If a personal data breach occurs, we will assess and manage the incident and make any notification required by applicable law.

13. Your Data Protection Rights

Subject to the conditions, exceptions and verification requirements of applicable law, you may:

• obtain information about the types of personal data processed and the purposes of processing
• request access to personal data and, where legally available, obtain a copy or transfer of data
• request correction or updating of inaccurate personal data
• request deletion where the legal conditions are met
• request restriction or cessation of processing in circumstances provided by applicable law
• object to certain processing or automated decisions where such right applies
• withdraw consent for future consent-based processing
• raise a complaint or exercise another statutory right with the competent authority (such as the UAE Data Office) where available under applicable law

13.1 – 13.2 Verification and Limits

13.1 A right to deletion does not require us to erase information that we must retain for legal obligations, legal claims, fraud prevention, suppression records or another lawful purpose.

13.2 To protect personal data, we may request reasonable information to verify identity before acting on a rights request. We will respond within the period required by applicable law.

14. EU/EEA and UK Users — Additional Mandatory Rights Where Applicable

14.1 The Company does not represent that EU GDPR or UK GDPR applies to every Website visitor merely because the Website can be accessed from outside the UAE. However, where either regime applies to a specific processing activity, the Company will comply with the mandatory obligations applicable to that activity.

14.2 Where such law applies, the relevant lawful basis may include steps requested before entering a contract, performance of a contract, compliance with a legal obligation, legitimate interests that are not overridden by the individual’s rights, or consent. Special-category data will be processed only where an additional lawful condition is available.

14.3 Applicable rights may include access, rectification, erasure, restriction, portability, objection and the right to lodge a complaint with a competent supervisory authority. International transfers will be handled using an applicable lawful transfer mechanism where required.

15. Children

15.1 The current Website services are intended for adults and the application form should not be used by children. We do not knowingly solicit applications from persons under 18 for the currently advertised mentorship services.

15.2 If the Company later launches a programme for minors, it will implement a separate age-appropriate, parental/guardian consent and safeguarding process before collecting data for that programme.

16. Cookies and Similar Technologies

16.1 The Website does not currently use Google Analytics, Meta Pixel, Google Ads tracking or other non-essential analytics/advertising cookies according to the current Website implementation.

16.2 Strictly necessary or technically generated storage, request data or security mechanisms may be used where required for the Website to function securely. We do not characterise a technology as a "cookie" if it is not in fact used.

16.3 Before introducing non-essential analytics or marketing trackers, the Company will review the technology, update the relevant notice and implement any consent or preference mechanism required by applicable law. A separate Cookie Policy may be introduced at that stage if appropriate.

17. Automated Decision-Making, AI, Call Recording and Transcription

17.1 The Company does not currently use AI or automated services to record, transcribe or automatically analyse introductory calls, applications, speech or video for Website applicants.

17.2 We do not currently make solely automated decisions through the Website that produce legal or similarly significant effects on applicants.

17.3 If either practice changes materially, we will update this Policy and provide any additional notice or consent required before the new processing begins.

18. Changes to this Policy

18.1 We may update this Policy to reflect changes in law, technology, service providers or processing. The current version and effective date will be published on the Website. If a change materially affects a consent-based use of personal data, we will obtain new consent where required by law.

19. Contact and Data Rights Requests

19.1 Privacy and data rights requests should be sent to:

REVIVAL OF LIFE FZE

Email: support@eugeniugurin.com

Phone: +353 89 946 1853

Address: Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates