Privacy Policy

Last updated: 8 October 2026

1. Who we are

This website, nyzeal.com, is operated by NyZeal ("NyZeal", "we", "us", "our"), run by Paul Nicholson and Calum Revfem. We design and deliver personal development programmes and in-house training for individuals and organisations in Scandinavia.

For the purposes of data protection law, including the EU General Data Protection Regulation (GDPR) as applied in Norway through the EEA Agreement, NyZeal is the data controller of the personal data described in this policy.

Contact for all privacy matters: enquiries@nyzeal.com

2. What this policy covers

This policy explains what personal data we collect when you visit nyzeal.com, contact us, subscribe to our newsletter, or enquire about or take part in our programmes. It also explains why we use it, who we share it with, how long we keep it, and what rights you have.

3. What data we collect, why, and our legal basis

a) Enquiries through the contact form, email or phone

Data: your name, email address, phone number (if provided), organisation (if provided) and the content of your message.

Purpose: to reply to your enquiry and discuss how we can help.

Legal basis: our legitimate interests in responding to enquiries (Article 6(1)(f) GDPR), or steps taken at your request before entering into a contract (Article 6(1)(b)).

Retention: up to 24 months after our last contact with you, unless we start working together (see c below).

b) Newsletter subscription

Data: your email address and, if you give it, your name.

Purpose: to send you news, insights and information about our programmes.

Legal basis: your consent (Article 6(1)(a)). You can withdraw consent at any time by using the unsubscribe link in any newsletter or by emailing us. Withdrawing consent does not affect the lawfulness of processing before withdrawal.

Retention: until you unsubscribe. We then keep a minimal record (your email address and the date of unsubscription) so that we do not email you again.

c) Programme registration, clients and invoicing

Data: contact details, organisation and role, programme or booking details, and payment and invoice records. Where relevant, information you choose to share with us so we can run a programme well (for example accessibility needs or dietary requirements).

Purpose: to deliver programmes and training, communicate with participants, and keep accounting records.

Legal basis: performance of a contract (Article 6(1)(b)); compliance with legal obligations, including bookkeeping law (Article 6(1)(c)). Where you give us health-related information such as accessibility or dietary needs, we rely on your explicit consent (Article 9(2)(a)).

Retention: accounting records are kept for the period required by law (in Norway, five years after the end of the financial year, under the Norwegian Bookkeeping Act). Other programme data is kept for up to 3 years after the programme ends, then deleted or anonymised.

d) Website use, cookies and technical data

Data: technical information such as IP address, browser type, device, pages visited and time of visit, collected through cookies and similar technologies.

Purpose: to make the website work securely and reliably, and to detect abuse.

Legal basis: our legitimate interests in operating and securing the website (Article 6(1)(f)) for strictly necessary cookies; your consent for any non-essential cookies (Article 6(1)(a)). See section 7 for details on cookies.

e) Legal claims and compliance

We may keep and use data where needed to establish, exercise or defend legal claims or to comply with the law (Article 6(1)(c) and (f)).

We do not sell your personal data. We do not use it for automated decision-making or profiling that has legal or similarly significant effects on you.

4. Who we share your data with

We only share personal data where necessary, and with providers who process it on our behalf under data processing agreements:

Wix.com Ltd. and its affiliates (website hosting, contact forms, email and newsletter tools, and website security).
Our accountancy and invoicing providers, where needed to keep accounting records.
Professional advisers (for example legal or accounting advisers) and public authorities, where required by law.
Partner organisations or co-facilitators, where you join a programme run with them. We share only the details needed to run that programme.

If you contact us on behalf of an organisation, we may share your details with our facilitators so they can prepare and deliver the work.

5. Transfers outside the EU/EEA

Some of our providers, including Wix.com Ltd. (Israel) and its sub-processors, may process data outside the EU/EEA. Where this happens, transfers rely on an EU adequacy decision (Israel is recognised as providing an adequate level of protection), on the European Commission's Standard Contractual Clauses, or on another safeguard permitted by Chapter V of the GDPR. You can contact us for more information about the safeguards in place.

6. How long we keep your data

We keep personal data only for as long as needed for the purposes in section 3, as set out there. When the retention period ends we delete or anonymise the data.

7. Cookies and similar technologies

Cookies are small text files stored on your device. Our website, built on Wix, uses strictly necessary cookies and similar technologies that are needed for the site to function and stay secure (for example XSRF-TOKEN, which protects forms against cross-site request forgery, and bSession, which supports site performance and session handling). These do not require consent.

We do not currently use advertising or marketing cookies. If we introduce analytics or other non-essential cookies, we will ask for your consent first through a cookie banner and update this policy.

You can control and delete cookies through your browser settings. Blocking strictly necessary cookies may stop parts of the site from working.

8. Your rights

Under the GDPR you have the right to:

access the personal data we hold about you and receive a copy;
have inaccurate data corrected;
have your data erased in certain circumstances (the right to be forgotten);
restrict how we use your data in certain circumstances;
object to processing based on our legitimate interests;
data portability: to receive data you gave us in a structured, commonly used format and have it transmitted to another controller, where processing is based on consent or contract;
withdraw consent at any time, where we rely on consent.

To use any of these rights, email enquiries@nyzeal.com. We will respond within one month. We may need to verify your identity first.

9. Right to complain

If you believe we have handled your personal data unlawfully, please contact us first so we can try to put it right. You also have the right to lodge a complaint with a supervisory authority, in particular in the country where you live or work. In Norway this is Datatilsynet (www.datatilsynet.no). A list of EU/EEA authorities is available at edpb.europa.eu.

10. Providing data, security and children

You are not required to give us personal data, but if you do not, we may not be able to answer your enquiry or deliver a programme. We use appropriate technical and organisational measures to protect personal data, including secure hosting, encryption in transit (HTTPS) and limited access. Our website and programmes are intended for adults and businesses, and we do not knowingly collect data from children under 16.

11. Links to other websites

Our site may link to other websites. We are not responsible for their privacy practices, so please read their policies.

12. Changes to this policy

We may update this policy from time to time. The latest version is always on this page, with the date at the top. If we make material changes, we will let you know in a suitable way, for example by email if you are a subscriber.

13. Contact us

NyZeal | Email: enquiries@nyzeal.com | Website: www.nyzeal.com