PRIVACY POLICY

Last updated: 17, November 2025

Welcome to Empire Minds. We take your privacy seriously. This Privacy Policy describes how we collect, use, share, and protect your personal data in connection with your interaction with Empire Minds (the “eBook”, “Product”, or “Service”), especially when purchased via Digistore24, and how we comply with applicable data protection laws including Digistore24’s data-processing rules.

1. Data Controller & Joint Responsibility

T. O'kelly author/publisher of the eBook 

For purchases, Digistore24 contractual seller / processor.


Joint Controller Relationship


Under data protection law, Digistore24 may be treated as joint controllers for certain personal data. Digistore24’s “Agreement on Joint Responsibility” confirms that both parties (us + Digistore24) jointly determine the purposes and means of processing certain customer data.

As joint controllers, we clarify who is responsible for which data-protection duties, including information obligations to you.

2. What Personal Data We Collect

We may collect the following types of personal data, either directly or through Digistore24:

  1. Order / Transaction Data


When you buy Empire Minds via Digistore24: name, email address, billing address, country, phone number (if provided) is collected. Digistore24 may collect additional fields depending on how their order form is configured. 

Payment data: Digistore24 processes payment through its providers; we do not store your full payment credentials.


  1. Usage & Analytics Data


If you visit our website, we may collect: IP address, browser type, device, pages visited, time stamps. We may also use cookies or similar tracking technologies to understand and improve how people interact with our site.


  1. Communications

If you contact us (via email, contact form), we collect the information you provide (name, email, message content). If you sign up for updates, newsletters, or related communications, we collect your email (and any optional data you provide).


  1. Cookies and Tracking Scripts (including via Digistore)


On our website: we may use cookies for functionality, analytics, marketing.


On Digistore24 order forms: if we (or affiliates) enable tracking (affiliate tracking, conversion tracking), certain cookies will be placed, consent is required for non-essential tracking.


Digistore24 also allows third-party tracking (if pre-approved) on its order forms; data processed by such tracking is based on your consent




3. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Performance of a Contract

    To fulfill your order of the eBook, process payments, deliver the product, and manage your access.


  • Legitimate Interests

    For running and improving our website (analytics), preventing fraud, and ensuring a smooth user experience.


  • Consent

    For non-essential cookies, affiliate or conversion tracking on Digistore24 order forms, and marketing communications.


  • Legal Obligations:

    To retain certain data for accounting, taxation, and compliance with applicable laws.




4. How We Use Your Personal Data

We use your data for the following main purposes:

  • Order Processing & Delivery: To process your purchase, deliver your eBook, and confirm the transaction.


  • Communication: To reply to your messages, send updates, customer support, or information about new editions or related products.


  • Fraud Prevention & Security: To detect and prevent fraudulent transactions and protect our customers and our business.


  • Analytics & Website Improvement: To analyze how our website is used, optimize user experience, and improve our marketing.


  • Marketing (optional): If you consent, to send newsletters, promotional offers, or related communications.


  • Legal Compliance: To fulfill obligations under financial, tax, or consumer-protection law.




5. Data Sharing & Third Parties

We may share your personal data in these situations:

  1. With Digistore24:

    As part of processing your order, Digistore24 receives your personal and billing data.
    Under our joint-controller arrangement, Digistore24 also processes certain data on its own systems (e.g., for customer records, fraud checks, order history)



  2. Service Providers / Processors:

    Email service providers (for sending updates or support).
    Analytics providers or tools to help us understand website usage.
    Other third-parties that help us run our business (hosting, security).


  3. Legal Disclosures:

    When required by law (e.g., tax authorities, law enforcement), or to protect our legal rights.


6. Cookies, Tracking & Third-Party Tools

  • We use cookies and similar tracking technologies on our website to ensure it works properly, to gather analytics, and (only with consent) for marketing.


  • For tracking on Digistore24’s order form: if we use external tracking (affiliate, pixel, conversion), data collection is only done with your explicit consent as required by Digistore24


  • You can manage your cookie preferences in your browser settings, and you may refuse or delete cookies though this might limit certain functionalities.


  • If you disable non-essential cookies or refuse tracking, we will still process essential data necessary for fulfilling your order.


7. Data Retention

  • We retain your order data (name, email, billing address) for as long as needed to fulfill our contractual obligations, handle potential refunds, and meet legal record-keeping obligations (e.g., for accounting).


  • Communications (emails, support requests) may be retained as long as needed for support history.


  • Analytics data may be stored in aggregated or anonymized form to analyze trends, or if tied to specific users, only for as long as justified by our legitimate interest, unless you ask us to delete it.


8. Your Rights as a Data Subject

Depending on your location, you may have the following rights:

  • Right of Access: You can request a copy of the personal data we hold about you.


  • Right to Rectification: If your data is inaccurate or incomplete, you can ask us to correct it.


  • Right to Erasure: Under certain conditions, you can request deletion of your data.


  • Right to Restrict Processing: You may ask us to restrict how we process your data under certain circumstances.


  • Right to Data Portability: You can request your data in a structured, commonly used format.


  • Right to Object: You may object to certain processing (e.g., tracking, marketing) if we rely on legitimate interests.


  • Right to Withdraw Consent: If you gave us consent (e.g., for cookies or marketing), you can withdraw it at any time.


9. Security Measures

We take data protection seriously. We have implemented reasonable technical and organizational safeguards to protect your personal data, such as:

  • Encryption for data in transit (HTTPS / SSL)


  • Secure servers and restricted access to personal data


  • Regular review of our security practices


10. International Data Transfers

Because Digistore24 and our service providers operate in multiple jurisdictions, your data may be transferred across borders. We ensure such transfers comply with applicable data protection laws (e.g., via standard contractual clauses or other lawful mechanisms) to maintain appropriate safeguards.

11. Email Communications & Unsubscribe Rights

We may send you emails related to your purchase of Empire Minds, such as product delivery, updates, or relevant promotional content. You can opt out of marketing emails at any time.
Every email we send includes a clear “Unsubscribe” link at the bottom that allows you to stop receiving non-essential communications immediately.

If you prefer, you may also request removal from our mailing list by contacting us at:

empireminds@outlook.es

Please note:

  • You will continue to receive essential transactional emails related to your purchase (such as receipts or access links), as these are required to deliver the product.

  • Unsubscribing from emails does not cancel your product access or your 60-Day Refund Policy rights.

12. Changes to This Privacy Policy

  • We may update this Privacy Policy from time to time (for example, if Digistore24 changes its practices, or we introduce new features).


  • When we make changes, we will post the updated policy on our website with a new “Last updated” date.


Your continued use of our service after changes means you accept the new terms.