Privacy Policy

Who We Are

LeSel OÜ is the data controller for the personal information described in this policy. We are registered in Estonia (registry code 17312637, Tallinn). The brain coaching practice is operated from Portugal by Linda-Lotte Seligman.

For any data-related question, contact hello@lesel.ai.

What We Collect

We only collect what we need to deliver the service you've asked for.

• When you start a free Brain Profile: the first name and age of the person it is about (you or your child), your country, the main concerns you select, the description you write, what you've already tried, and your delivery email. No payment is taken at this step. If you later unlock the full plan for €39, Stripe collects the billing details it needs to take payment.
• When you book a coaching session: your name, email, the topic you'd like to discuss, and your time-zone preference. Calendar and video-call data are handled by Google.
• When you contact us directly: your name, email, and the message you send.
• When you browse the site: standard web-server logs and Google Analytics data (see Cookies & Analytics below).

We don't ask for medical history, contact numbers, addresses, ID documents, or financial information beyond what Stripe needs to process payment.

How the Brain Profile Handles Your Data

Your intake is processed in the European Union. The Brain Profile pipeline runs on our own infrastructure in Germany for the retrieval, database, and report generation. The AI inference itself runs on a vetted EU partner (Germany and Finland), with all relevant GDPR agreements in place. Your data is never used to train an AI model.

• A profile is created when you submit the free intake, and your intake and generated report are stored on a private 90-day link from that moment, whether or not you unlock the full plan. After 90 days, both are automatically deleted from our servers. If you unlock the full plan, the 90-day window resets from the unlock date.
• We do not train any AI model on your data. We do not sell your data, and we share it only with the service providers (subprocessors) listed below, who process it on our behalf to deliver the service.
• If your intake contains wording suggesting you or your child are in immediate danger, the system pauses generation and points you to crisis resources. The intake is held only long enough for Linda-Lotte to review it personally if you ask her to.

Children's Data

A Brain Profile can be completed about a person aged 8 or older. When the subject is under 18, the intake form requires you to confirm you are the child's legal guardian, or that you have the parent's or guardian's permission to share the details.

A profile about a child is created the moment you submit the free intake, before any payment, and is held under the same 90-day retention and deletion rules as any other Brain Profile. We process the minimum information needed for the report. We do not contact the child directly. Guardians can request access, correction, or deletion of a child's data at any time by emailing hello@lesel.ai.

Automated Generation of the Report

The Brain Profile is generated automatically from the information you provide and our curated library of brain-science research. It applies Linda-Lotte's coaching framework to your situation.

The report is an educational coaching document. It is not a medical diagnosis, a clinical assessment, a psychological test, or a prediction about your future. You have the right to a human review of any report: book a session with Linda-Lotte and she will read your report before the call.

How We Use Your Data

• To generate and deliver the free Brain Profile you've requested, and the full plan or coaching session you've paid for.
• To send appointment confirmations, calendar invites, and the operational emails attached to your purchase.
• To detect safeguarding concerns in intake wording and route customers to crisis resources.
• To improve the service, using anonymised aggregate analysis only.
• With your explicit consent, to contact you occasionally about new products or research from LeSel. You can withdraw consent at any time.

Our Lawful Basis

We rely on contract to generate and deliver the free Brain Profile you request and any unlock or coaching session you pay for; consent for optional marketing emails and for analytics cookies (each given separately and freely, and withdrawable at any time); and legitimate interest to keep the free service usable and free from automated abuse, and to understand aggregate site usage, balanced against your rights and freedoms.

Who Else Touches Your Data

We don't sell your data. We use the following service providers (subprocessors) to deliver the service. Each processes data only for the specific purpose we use them for, under their own GDPR-compliant terms.

• EU AI inference provider (Germany / Finland) — runs the AI model that generates your Brain Profile from your intake. EU-located, bound by a data-processing agreement, and does not use your data to train AI models.
• Stripe — payment processing.
• Resend — transactional email (report delivery, calendar invites, support replies). EU-hosted.
• Google — Calendar and Meet, used only for coaching session bookings.
• CoachAccountable — ongoing coaching client management, only for clients in continuing programmes.
• Netlify — static website hosting.
• Web3Forms — relays the contact and schools enquiry forms (your name, email, and message) to us by email. Used only when you submit one of those forms.
• Cloudflare — bot and abuse protection (Turnstile) on the Brain Profile form, and the secure tunnel that serves our report API. Turnstile is privacy-preserving: it does not track you across sites and is not used for advertising.
• Google Analytics 4 — anonymised website-traffic analytics. See Cookies & Analytics below.

International Transfers

Some of our subprocessors (Stripe, Google, Netlify, Google Analytics, Cloudflare) are based in or transfer data to the United States. These transfers are covered by the EU-US Data Privacy Framework or by Standard Contractual Clauses. The Brain Profile generation itself runs entirely on EU-located hardware and never leaves the European Union.

Cookies & Analytics

We use Google Analytics 4 to understand how the website is used in aggregate. GA4 sets cookies to track anonymised traffic patterns. We do not use marketing or advertising cookies, and we do not track you across other websites.

On your first visit, a banner asks whether you want to accept analytics cookies. GA4 only loads after you click Accept. If you click Decline, GA4 never loads on your device. To change your choice at any time, click Cookie preferences in the footer.

The Brain Profile form uses Cloudflare Turnstile to confirm you are a real person before we generate a free report. Turnstile may set a temporary, strictly-necessary token to do that. It is not an advertising or tracking cookie, and it does not follow you across other websites.

How Long We Keep Your Data

• Brain Profile intake and generated report (free or unlocked): 90 days from generation; unlocking the full plan resets the window from the unlock date. Then automatically deleted.
• Marketing-contact email (only if you ticked the optional consent box when you signed up): until you unsubscribe or request deletion.
• Coaching session records (in CoachAccountable): retained for the duration of the engagement, then deleted on request.
• Email correspondence: 2 years.
• Payment and accounting records: 7 years (required by Estonian and EU tax law).

Your Rights Under GDPR

Under the EU General Data Protection Regulation, you have the following rights regarding your personal data:

• Access: a copy of the data we hold about you.
• Rectification: correct anything inaccurate.
• Erasure: have your data deleted.
• Restriction: pause processing while a question is resolved.
• Portability: receive your data in a structured, machine-readable format.
• Objection: object to processing based on legitimate interest.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with your local data protection authority. In Portugal that is the CNPD (cnpd.pt); in Estonia the Andmekaitse Inspektsioon (aki.ee); or your own EU member-state authority.

Email hello@lesel.ai to exercise any of these rights. We respond within 30 days.

Security

• Brain Profile data is stored on our own hardware located in the European Union, with access restricted to the LeSel team. Each report is reachable only through an unguessable private link — it is never publicly listed or searchable.
• Payment data is processed by Stripe (PCI DSS compliant). We never store payment card details.
• Coaching session data is stored in CoachAccountable (GDPR compliant).
• Internal access to customer data is limited to Linda-Lotte and the LeSel founding team.
• Encrypted off-site backups are taken daily and retained for the same retention windows above.

Changes to This Policy

If we make material changes to this policy, we'll publish the updated version here with a new "last updated" date. For any change that materially affects how we process your data, we will notify everyone with an active 90-day Brain Profile link by email.