Privacy Policy

Last updated: 16 July, 2026.

Lennart Nacke, operating as The Acagamic, a business registered in Ontario, Canada ("Company," "we," "us," or "our"), operates the website lennartnacke.com and related services, including our newsletter, online courses, membership community, and coaching services (collectively, the "Service"). This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, how long we keep it, and the rights and choices you have.

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Person in charge of the protection of personal information / Privacy Officer:
Lennart Nacke
Email: legal@lennartnacke.com
Mail: ℅ Lennart Nacke, 330 Av Avro, Pointe-Claire, QC H9R 5W5, Canada

This Privacy Policy is designed to meet the requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25), Canada's Anti-Spam Legislation (CASL), and — where they apply to you — the EU General Data Protection Regulation (GDPR) and UK GDPR.

1. Information We Collect

1.1 Information You Provide Directly

We collect personal information you provide when you:

• Subscribe to our newsletter — name and email address;
• Purchase a product, membership, or coaching package — name, email address, billing address, and transaction details (your full payment card details are collected and processed by our payment processors, not by us);
• Join our membership community — profile information you choose to provide (name, photo, bio) and the posts, comments, and messages you share;
• Book or attend a coaching or discovery call — scheduling details, information you share on intake forms, and the content of the session itself, including notes, session recordings, and transcripts (see Section 1.4);
• Contact us — the contents of your message and your contact details;
• Provide a testimonial — only with your separate, express consent.

1.2 Information Collected Automatically

When you use the Service, we and our service providers may automatically collect:

• Log and usage data — IP address, browser type, operating system, pages visited, referring pages, and time spent;
• Device information — hardware model, operating system version, and unique identifiers;
• Cookies and similar technologies — see Section 7.

1.3 Information from Other Sources

We may receive information from third-party platforms you interact with us through — for example, the platform profile you use in our community (Skool), your subscription status from our email platform (Kit) or publishing platforms (Ghost, Substack), purchase confirmations from our checkout providers, and public social media interactions. We combine this with information we hold to administer your purchases and improve the Service.

1.4 Coaching Sessions, Recordings, and Transcripts

Coaching and discovery calls are recorded and transcribed by default (including using automated/AI transcription tools) for the purposes of delivering the coaching engagement, preparing session notes and action plans, and quality assurance. This is disclosed here and in your booking confirmation; by booking and attending a session, you consent to recording and transcription. If you do not wish a session to be recorded, tell us before the session starts and we will accommodate where practicable; you may also request deletion of a recording after the fact (Section 9). Session recordings, transcripts, and coaching notes are treated as confidential, are accessible only to us and the service providers that process them on our behalf, and are never used for marketing or published without your separate, express consent. Because coaching conversations may include information you consider sensitive, we apply heightened care to this data (see Sections 5 and 6).

1.5 What We Do Not Collect

We do not knowingly collect government identifiers, health records, biometric data, or precise geolocation. Please do not share information in coaching sessions or community posts that you are not comfortable being processed as described in this Policy.

2. Purposes and Legal Bases

We collect and use personal information for the following purposes. Where GDPR/UK GDPR applies, the corresponding lawful basis is noted.

We identify our purposes at or before the time of collection and do not use your personal information for new, incompatible purposes without your consent, except where permitted or required by law.

We do not sell your personal information, and we do not share it with third parties for their own advertising purposes.

3. Consent

Where consent is our basis for collecting, using, or disclosing your personal information, we seek consent that is specific to the purpose, and we ask for it separately from other terms where the law requires (for example, recording consent for coaching sessions and express consent for testimonials). You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting legal@lennartnacke.com or using the mechanisms described in this Policy (for example, unsubscribe links). Withdrawal does not affect processing that occurred before withdrawal, and some services cannot be provided without certain information.

4. Email and CASL Compliance

We send commercial electronic messages (such as our newsletter and promotional emails) only with your express or implied consent as permitted by Canada's Anti-Spam Legislation (CASL). Every marketing email we send identifies us, includes our contact information, and contains a working unsubscribe link that takes effect promptly (and in any event within 10 business days). If you unsubscribe from marketing, we may still send you non-promotional, transactional messages related to your purchases or account (receipts, renewal notices, service announcements).

5. Sharing of Information

We share personal information only as described below. We do not sell it.

5.1 Service Providers (Processors)

We use third-party providers to operate the Service. They process personal information on our behalf, under contracts that restrict their use of it to providing services to us. Categories and current providers include:

• Email and newsletter delivery: Kit (ConvertKit); Ghost; Substack
• Community and course hosting: Skool
• Payments and checkout: Stripe; Payhip; ThriveCart (your card details go to the payment processor, not to us; where a platform such as Payhip acts as merchant of record, it is an independent controller of your purchase data under its own privacy policy)
• Scheduling and events: Calendly; Luma
• Website hosting and analytics: our web host and privacy-respecting analytics tools
• Video conferencing, recording, and transcription: the conferencing and AI-transcription tools used to deliver and document coaching sessions
• Business operations: accounting, tax, and (where needed) legal or professional advisors

The specific providers may change over time; this section describes the categories, and you can request the current list at legal@lennartnacke.com.

5.2 Business Transfers

If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction. We will require the recipient to honour commitments materially consistent with this Policy, and we will notify you of any transfer that results in a materially different policy applying to your information.

5.3 Legal Requirements and Protection

We may disclose personal information where required by law, subpoena, or court order; to respond to lawful requests from public authorities; or where reasonably necessary to enforce our Terms of Service, protect our rights or property, or protect the safety of any person.

5.4 With Your Consent

We share your information for any other purpose only with your consent or at your direction.

6. Security

We use technical and organizational measures appropriate to the sensitivity of the information we hold, including encryption in transit, access controls, and least-privilege access to coaching records. No method of transmission or storage is completely secure, and we cannot guarantee absolute security — but we commit to the breach-response obligations in Section 10.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Operate the site (strictly necessary cookies — logins, checkout, security);
• Measure usage (analytics cookies — pages visited, aggregate traffic patterns);
• Improve marketing (only where used, and only with consent where required — for example, advertising pixels).

By continuing to use the Service after seeing this Policy, you consent to our use of cookies as described above, to the extent permitted by applicable law. You can withdraw or manage this consent at any time through your browser settings — including refusing all or some cookies, deleting stored cookies, or receiving an alert when cookies are set. Some parts of the Service may not function properly without strictly necessary cookies. Our email provider may use open- and click-tracking in newsletters; you can opt out of all tracking by unsubscribing, or contact us for alternatives.

8. Retention

We keep personal information only as long as needed for the purposes identified, then securely delete or anonymize it. Our standard retention practices:

• Newsletter data: until you unsubscribe, plus a suppression record (email address only) kept to honour your opt-out;
• Purchase and transaction records: 7 years, to meet Canadian tax and accounting requirements;
• Coaching session recordings, transcripts, and notes: 6 months after the engagement ends by default; longer on a case-by-case basis where the engagement requires it, where you and we agree (for example, for a continuing coaching relationship), or where the law requires retention. You may request earlier deletion at any time (Section 9);
• Community content: for as long as your membership is active; on departure you may request removal or anonymization of your identifiable posts (Section 9);
• Support correspondence: 6 months after resolution by default; longer case by case where a matter remains open or the law requires it.

Where information is subject to a legal hold or an ongoing dispute, we retain it until the matter concludes.

9. Your Rights

9.1 All Users (PIPEDA and Quebec Law 25)

You have the right to:

• Access the personal information we hold about you and be informed of how it has been used and to whom it has been disclosed;
• Correction of inaccurate, incomplete, or ambiguous information;
• Withdraw consent (Section 3);
• Deletion / de-indexing (Quebec): request that we cease disseminating your personal information or de-index it where dissemination breaches the law or a court order, or causes you serious injury;
• Data portability (Quebec): receive computerized personal information you provided to us in a structured, commonly used technological format, or have it transferred to another organization where technically feasible;
• Complain: challenge our compliance by contacting our Privacy Officer (details above). If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, for Quebec residents, the Commission d'accès à l'information du Québec (cai.gouv.qc.ca).

9.2 EU/UK Users (GDPR / UK GDPR)

If you are in the European Economic Area or the United Kingdom, you additionally have the rights of access, rectification, erasure, restriction of processing, data portability, and objection (including an absolute right to object to direct marketing), and the right not to be subject to solely automated decisions with legal or similarly significant effects (we do not make such decisions). You may lodge a complaint with your local supervisory authority. Where we rely on consent, you may withdraw it at any time.

9.3 How to Exercise Your Rights

Email legal@lennartnacke.com with your request. We will verify your identity (to protect your information from fraudulent requests) and respond within 30 days (PIPEDA/Law 25) or one month (GDPR), extendable where the law permits, in which case we will tell you. Exercising your rights is free of charge except where the law allows a reasonable fee for excessive or repetitive requests.

10. Breach Notification

If a breach of security safeguards involving your personal information creates a real risk of significant harm to you, we will report the breach to the Office of the Privacy Commissioner of Canada, notify you as soon as feasible, and keep records of the incident, as required by PIPEDA. For incidents involving Quebec residents, we will also notify the Commission d'accès à l'information and affected individuals where there is a risk of serious injury, and record the incident in our confidentiality-incident register, as required by Law 25.

11. International Data Transfers

We are based in Canada. Some of our service providers (Section 5.1) store or process personal information in the United States or other countries, where privacy laws may differ from those of your jurisdiction. Before communicating personal information outside Quebec/Canada, we assess the sensitivity of the information, the purposes of its use, and the protections in place — including contractual safeguards with our providers — as required by Quebec Law 25. For transfers of EU/UK personal data, we and our providers rely on appropriate safeguards such as adequacy decisions and standard contractual clauses. You may contact us for more information about these safeguards.

12. Children's Privacy

The Service is intended for adults and is not directed to anyone under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has provided us personal information, contact legal@lennartnacke.com and we will delete it promptly.

13. Third-Party Links and Platforms

The Service contains links to third-party websites and operates on third-party platforms (for example, Skool, Substack, YouTube, LinkedIn, X). Those parties have their own privacy policies, and we are not responsible for their practices. When you interact with us on a third-party platform, that platform independently collects data about you under its own policy; this Policy covers only the information we receive.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated policy here with a new "Last Updated" date and, for material changes (such as new purposes or new categories of sharing), we will provide prominent notice on the Service or by email before the change takes effect and obtain fresh consent where the law requires it.

15. Contact Us

Questions, requests, or complaints about this Privacy Policy or our data practices:

Privacy Officer / Responsable de la protection des renseignements personnels: Lennart Nacke
Email: legal@lennartnacke.com
Mail: ℅ Lennart Nacke, 330 Av Avro, Pointe-Claire, QC H9R 5W5, Canada

AVIS AUX RÉSIDENTS DU QUÉBEC: Vous pouvez exercer vos droits d'accès, de rectification, de retrait de consentement, de désindexation et de portabilité en écrivant au responsable de la protection des renseignements personnels à l'adresse ci-dessus. Une version française de la présente politique est disponible sur demande.