Last Updated: 28.11.2025
Introduction
We, Kamila Unfiltered GmbH, are responsible for the processing of personal data within the meaning of applicable data protection laws. We take the protection of your information seriously. This privacy policy explains what personal data we collect, how we use it, and which rights you have. When we decide how and why personal data is processed, we are required to provide information on the type of data involved, the purpose of processing, the legal basis, and the storage period. This document gives you an overview of how data is handled when you visit our website, purchase digital products, join our email list, or interact with our services.
I. General
Scope of application
This privacy policy explains how we collect, use, and handle personal data that you provide or that is collected when you visit our website or use our services. It describes the situations in which personal data may be shared with service providers and informs you about your rights.This document applies together with any other notices or terms that appear on our website. It covers the use of the kamilaunfiltered.com website as well as services and content offered under the Kamila Unfiltered brand, operated by Kamila Unfiltered GmbH.
Definitions
The terms used in this privacy policy follow the definitions in Art. 4 of the EU General Data Protection Regulation.
Name and address of the data controller
The controller responsible for processing your personal data within the meaning of Art. 4 No. 7 EU-GDPR is us: Kamila Unfiltered GmbH Dammstrasse 16 6300 Zug E-Mail address: support[at]kamilaunfiltered.com You can find further information about our company in the imprint section on our website at www.kamilaunfiltered.com/imprint
Contact details of the data protection officer (cf. Art. 37 EU-GDPR)
For all questions and as the contact person regarding data protection at our company, our data protection officer is available to you. Her contact details are: Kamila Michalkiewicz Data Protection Officer c/o Kamila Unfiltered GmbH, Dammstrasse 16, 6300 Zug E-Mail address: support[at]kamilaunfiltered.com
Legal bases for data processing
By law, in principle, every processing of personal data is prohibited and only allowed if the data processing falls under one of the following justifications:
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Art. 6 para. 1 lit. a EU-GDPR (“consent”): If the data subject has voluntarily, in an informed manner and unambiguously given his or her consent through a declaration or other clear affirmative action to the processing of the personal data concerning him or her for one or more specific purposes;
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Art. 6 para. 1 lit. b EU-GDPR: If the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
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Art. 6 para. 1 lit. c EU-GDPR: If the processing is necessary for compliance with a legal obligation the controller is subject to (e.g. a legal retention obligation);
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Art. 6 para. 1 lit. d EU-GDPR: If the processing is necessary in order to protect the vital interests of the data subject or of another natural person;
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Art. 6 para. 1 lit. e EU-GDPR: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
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Art. 6 para. 1 lit. f EU-GDPR (“legitimate interests”): If the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. For the processing activities carried out by us, we will indicate the applicable legal basis for each of them below. A processing activity may also be based on several legal bases.
Data deletion and storage period
We store personal data only for as long as it is needed for the purpose for which it was collected or for as long as we are required to keep it by law. If a specific storage period is mentioned in another part of this policy, that period applies; otherwise, data is deleted or blocked once the purpose for processing or the legal basis no longer applies. Data may be kept for a longer period when required to meet legal obligations, maintain tax or accounting records, or manage possible legal claims. When these obligations end, the data is deleted unless further storage is permitted or required by law. Our service providers may store data on servers located in the European Union, Switzerland, or the United States. If you would like to know how long we keep data for a particular purpose, you can contact us at any time. Information about storage periods for cookies is provided in the relevant cookie section of this policy.
Data security (cf. Art. 32 EU-GDPR)
We take appropriate technical and organizational measures to protect personal data from loss, misuse, or unauthorized access. This includes using SSL or TSL encryption on our website and applying security practices that reflect current technology, reasonable implementation costs, and the nature and purpose of the processing. These measures are reviewed and updated regularly as technology develops. If you would like more information about our security practices, you can contact us at any time.
Collaboration with processors (see Art. 28 EU-GDPR)
We work with external service providers who support us in areas such as website hosting, payment processing, email delivery, marketing, and course access. These providers handle personal data only on our instructions and are bound by contractual agreements that require them to follow applicable data protection laws. When personal data is shared with these partners, or received from them, it is done for the purpose of delivering our services and is covered by the relevant processing agreements.
Requirements for the transfer of personal data to third countries
Your personal data may be transferred to service providers or partners located outside the European Economic Area when this is needed to deliver our services. Transfers may include countries that the European Commission considers to have an adequate level of data protection or countries where additional safeguards are required. When data is transferred to a country without an adequacy decision, we ensure appropriate protection through measures such as standard contractual clauses approved by the European Commission or other legally accepted safeguards. Data may also be transferred when it is necessary to establish, exercise, or defend legal claims. If you would like further information about international transfers and the safeguards used, you can contact us at any time.
No automated decision-making
We do not intend to use personal data collected from you for any automated decision-making process.
Profiling
Profiling may occur when personal data is processed automatically for marketing and analytics purposes, for example when tools record user behavior, interactions, or preferences. This type of processing uses basic data such as email address, IP address, cookies, or activity within our site or emails, and it never involves special-category information. Profiling is used only to understand how users engage with our content, improve communication, and adjust marketing efforts. It does not create legal or significant effects for the data subject.
No obligation to provide personal data
We do not make the conclusion of contracts with us dependent on you providing us with personal data beforehand. As a customer, you are not generally under a legal or contractual obligation to provide us with your personal data; however, it may be that we can only provide certain offers to a limited extent or not at all if you do not provide the required data. If this should exceptionally be the case within the scope of the products or services offered by us and presented below, you will be notified separately.
Legal obligation to transmit certain data
Under certain circumstances, we may be subject to a special legal or regulatory obligation to provide lawfully processed personal data to third parties, especially public authorities (cf. Art. 6 para. 1 lit. c EU-GDPR).
Your rights
You may exercise your rights regarding the personal data we process by contacting us at any time using the details provided in this policy. You have the right to request access to the personal data we hold about you, including information about the purpose of processing, the categories of data involved, the recipients of that data, the planned storage period, your rights to rectification, erasure, restriction or objection, the source of the data if it was not collected from you, and the existence of automated processing. You may request correction of inaccurate or incomplete data and request erasure of your data unless the processing is required to meet a legal obligation or to establish, exercise, or defend legal claims. You may request that the processing of your data be restricted, for example if you contest its accuracy or if the processing is unlawful. You may request a copy of the data you provided to us in a structured and commonly used format or ask us to transfer it to another controller. You may object to processing that is based on legitimate interests; if your objection does not relate to direct marketing, we may ask you to explain your reasons and will review whether our interests override your request. You may withdraw any consent you have given us at any time, and this will affect future processing based on that consent. You may also lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) if you believe your data has been processed in violation of applicable law. If you contact us with a request about your data, we may ask for additional information to confirm your identity. If we cannot identify you, we may have to decline your request. We aim to respond within one month, but this period may be extended when necessary due to the complexity or volume of requests. We do not charge fees for handling these requests unless they are obviously unfounded or excessive, in which case we may charge a reasonable administrative cost or decline to process the request.
Changes to the Privacy Policy
As part of the ongoing development of data protection law and technological or organizational changes, our privacy policy will be regularly reviewed for any necessary adjustments or additions. You will be informed about any changes, in particular on our website at www.kamilaunfiltered.com/privacy-policy. This privacy policy is valid as of November 2025.
II. Visiting the website, social media presence
Explanation of function
You can obtain information about our companies and the services we offer, in particular at www.kamilaunfiltered.com including the associated subpages (hereinafter together referred to as “website”). When you visit our website, personal data may be processed by us.
Personal data processed
A. Overview of data we collect
We collect the following categories of personal data when you interact with our website, join our lists, or make a purchase:
• Name and surname
• Billing address
• Email address
• Products purchased
• Payment information (processed by Stripe, PayPal, or Twint; we do not store full payment details)
• Optional company details for invoicing
• IP address and device usage information
• Email sign ups for waiting lists and lead forms
• Abandoned cart data when you enter your name and email before completing checkout
• Data collected through Meta Pixel for analytics and advertising
• Data collected through Google Analytics
• Data collected through WooCommerce and CartFlows during checkout
• Log files (technical data related to your device and browser)
B. How we use your data
We use your data for the following purposes:
• To process your purchase
• To deliver digital products
• To send transactional emails and access instructions
• To send marketing emails if you have opted in
• To manage user accounts and customer support
• To recover abandoned carts
• To operate analytics, advertisements and retargeting
• To improve our website and services
• To comply with accounting and legal obligations
C. Detailed categories of data
When you use our website or interact with our services, we may collect and process the following categories of personal data:
Log data:
When you visit our website, technical information is automatically collected and stored in server log files. This may include the referrer URL, requested files, date and time of access, browser type and version, operating system, shortened IP address, data volume, access status, and time zone information. This data is needed to operate the website and ensure its security.
Purchase and access data:
If you buy a digital product or sign up for course access, we collect the information you provide during checkout. This may include your name, surname, email address, billing address, payment information, and details about the product you ordered. We use this data to process your order, deliver digital content, create your course account, and manage communication related to your purchase.
Newsletter and marketing data:
If you subscribe to our email list or request information, we collect the data you provide, usually your email address and name. We use this data to send updates, marketing messages, and content that matches your interests. With your consent, we may also process information about how you interact with our emails.
Communication data:
If you contact us by email, we process the information you send so that we can respond to your message. This may include your name, contact details, and any other information you choose to share.
Purpose and legal basis of data processing
We process personal data only when it is necessary and in line with the legal bases set out in the GDPR and other applicable laws. The data described in this policy is processed to operate our website, deliver digital products, manage purchases, provide course access, send newsletters, and respond to inquiries. When processing is based on the performance of a contract, it includes activities such as handling orders, processing payments, delivering digital content, creating course accounts, and managing communication related to your purchase. When processing is based on legitimate interests, it includes ensuring the security and functionality of our website, maintaining business records, analyzing how our website is used, improving user experience, sending service updates, preventing fraud, and protecting our rights. We always consider the impact on your privacy and apply safeguards such as access restrictions, retention limits, and appropriate security measures. If data is processed because you have given consent, you may withdraw that consent at any time. When required by law, we process personal data to meet obligations such as accounting, tax requirements, or responding to lawful requests. If you choose not to provide data needed for a specific service, we may not be able to offer that service. Access to the public parts of our website is not affected by this. If you would like more information about the legal basis for any specific processing activity, you can contact us.
Duration of data processing
1. Overview of how long we keep your data
We keep personal data only for as long as needed for the purposes described in this policy or for as long as required by law. Purchase records are stored for the legally required accounting and tax retention periods. Email information is stored until you unsubscribe or request deletion. Analytics data is stored according to the retention limits of the tools we use. Course access is provided through WebToLearn, where an account is created using the email address you provide at checkout; you set your password during activation. We remain the administrator of this account and can manage or delete it when needed. Access to the platform is available for the duration of the course availability period, and account information may remain stored for support or documentation needs unless you request deletion. WebToLearn processes this information only to operate the course platform. Log files are stored for short technical and security periods. Marketing and tracking data is kept according to your cookie choices and the retention settings of the respective tools.
2. Legal retention rules and detailed explanation
Your personal data is processed only for as long as needed to fulfill the purposes described in this policy or for as long as required by applicable law. The legal bases for processing apply for the entire duration of storage. Third-party providers that support our services store data only for the period required to deliver their functions. Information about the duration of cookie storage and similar technologies can be found in the cookie section of this policy.
D. Third-party services and course delivery platform
We use external service providers to operate our website, manage payments, deliver online courses, and run email and marketing systems. These providers process data on our behalf in accordance with Art. 28 EU-GDPR and only under our instructions.
1. Website hosting and infrastructure
We use the following tools to run and display our website:
• HostMark – hosting and server infrastructure
• WordPress / WooCommerce – website system and online shop
• Wix.com – external landing pages that redirect to checkout
2. Course delivery platform
We deliver our online courses through an external platform:
• WebToLearn (academy.kamilaunfiltered.com)
This service hosts our course videos, audio files, PDFs.
3. Checkout and payment processing
For secure payment processing and checkout functions, we use:
• Stripe
• PayPal
• Twint
• WooCommerce and CartFlows – structure and processing of orders
We do not store full payment data. All payment information is processed directly by the respective payment provider.
4. Email communication and automations
To send transactional emails, product access, and marketing communication (with consent), we use:
• ActiveCampaign – email marketing and automations
• WP Mail SMTP / Gmail – outgoing transactional emails
5. Analytics, advertising and tracking
To analyze website performance and run advertising campaigns, we use:
• Meta Pixel (Meta Platforms Inc.) – analytics, ad measurement, retargeting
• Google Analytics – website usage analytics
• PixelYourSite – installation and management of tracking pixels
These services may process device identifiers, IP addresses, cookie data, and behavior data based on your cookie consent.
Legal basis for disclosure
The disclosure of personal data to these providers is based on:
• Contract performance – Art. 6 para. 1 lit. b EU-GDPR
• Consent (for analytics and marketing tools) – Art. 6 para. 1 lit. a EU-GDPR
• Legitimate interests – Art. 6 para. 1 lit. f EU-GDPR
• Legal obligations – Art. 6 para. 1 lit. c EU-GDPR
Transfers outside the EU/EEA may occur. In such cases, appropriate safeguards such as standard contractual clauses apply.
We only disclose personal data to third parties when required or when you have given explicit consent under Art. 6 para. 1 lit. a EU-GDPR.
Transmission of personal data to third parties; legal basis
We share personal data only when necessary to operate our website, deliver our services, or meet legal requirements. This may include trusted service providers that support functions such as hosting, payment processing, email delivery, security, analytics, or course access. These providers act on our instructions and are bound by data protection agreements. Data may also be shared with public authorities when required by law. In some situations, data may be shared with professional advisers such as auditors, banks, insurance providers, or legal representatives when this is needed to manage our business activities. If data is transferred to countries outside the European Economic Area, we ensure appropriate safeguards in line with legal requirements. We share personal data with other parties only when we are allowed to do so by law or when you have given your consent.
Use of Cookies, Plugins, and other services on our website
We use cookies and similar technologies on our website to operate essential features, understand how visitors use the site, and offer marketing functions when you consent to them. Cookies are small text files stored by your browser. Some cookies are required for the website to function, while others help us improve performance or show content that fits your interests. You can manage your preferences at any time through our cookie banner or your browser settings. Turning off certain cookies may reduce the functionality of the site.
Essential cookies
These cookies are needed for the website to work and to keep it secure. They do not gather information for marketing and cannot be disabled through the cookie banner.
Analytics cookies
With your consent, we may use analytics tools such as Google Analytics to understand how visitors use our website. These tools help us see which pages are visited, how users move through the site, and where improvements are needed. The information may be stored on servers operated by the analytics provider. You can withdraw your consent at any time through the cookie banner or your browser settings.
Marketing and retargeting cookies (including Meta Pixel)
With your consent, we use marketing and retargeting tools such as Meta Pixel. These technologies help us understand how visitors interact with our website and allow us to show ads that match your interests on other platforms. They also help us measure the results of our marketing. The data collected may be used by the respective providers according to their own policies. You may withdraw your consent at any time through our cookie banner.
Social media links
Our website may include links to social media platforms. These links do not connect to the platform unless you click on them. If you choose to share content through a social network, that platform may process your data under its own privacy policy.
Your choices
You can control cookies using the cookie settings on our website or by adjusting your browser preferences. You may also delete cookies already stored on your device.
III. Contact by email
If you contact us by email, we process the information you send so that we can respond to your request. The data you provide is given voluntarily and you choose what to share. We may ask for additional details if this is needed to answer your message or provide support. The legal basis for this processing is our interest in handling your inquiry. You can object to this processing at any time by contacting us using the details in this policy.
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