Privacy Policy
Effective date: 11 October 2026.
1. Who we are (controller)
Spark to a Flame Consulting LLP operating under the brand Find Your Why, 1103–11871 Horseshoe Way, Richmond, British Columbia V7A 5H5, Canada.
Business Number: 709595169 · Registration Number: LL01528
Privacy Officer / contact: Marcel Szenessy — hello@findyourwhy.coach
Website: www.findyourwhy.coach
2. Scope
This policy describes how we process personal data when you use Find Your Why (website and app), including your account, the answers you write during your Values → Purpose → Vision path, your optional Vision Board, connecting your own AI, and the optional newsletter.
3. Data we process
Depending on how you use Find Your Why, we may process:
- Account data: first name, last name, country of residence, email, password/auth identifiers, language, plan/billing status
- Your path content: the answers you write for your Values, Purpose and Vision, and your Vision Board (text and any images you add)
- AI connection data: which AI you connect via MCP (e.g. Claude, ChatGPT, Grok, Perplexity) and the access token that links it to your account
- Technical data: IP address, device/browser info, logs needed for security and operation
- Support: messages you send to us
- Newsletter (optional): email address, language, signup time, IP used for signup, confirmation/unsubscribe status; if Brevo open/click stats are enabled, those engagement metrics
We do not ask you to store secrets (passwords, seed phrases, PINs, private keys, recovery codes). Do not enter them. Find Your Why is designed for clarity, not as a vault.
4. Purposes and legal bases (GDPR Art. 6)
| Purpose | Legal basis (where GDPR applies) |
|---|---|
| Provide the app and save your path (contract) | Art. 6(1)(b) |
| Billing via payment provider | Art. 6(1)(b) / (c) as applicable |
| Connecting your own AI via MCP | Art. 6(1)(b) at your request |
| Security, abuse prevention, logs | Art. 6(1)(f) legitimate interests |
| Legal obligations | Art. 6(1)(c) |
| Newsletter / marketing emails | Art. 6(1)(a) consent (double opt-in) |
You may withdraw newsletter consent at any time (unsubscribe link or email us). Withdrawal does not affect prior lawful processing.
5. Your own AI (MCP connection)
Find Your Why lets you connect an AI tool you already work with (Claude, ChatGPT, Grok or Perplexity) to your account using MCP. This is optional — the path works without AI.
When you connect, your AI reads and writes your answers on your instruction, through your own AI account. In that case the AI provider processes your prompts and content under its own terms and privacy policy. We do not send your content to AI providers ourselves, and we do not sell AI usage. You can disconnect at any time.
6. Processors / recipients
As of the publish date of this policy:
- Website & app hosting: All-inkl (Germany)
- Payments: Stripe (when checkout is live)
- Email / newsletter: Brevo (Brevo SAS, France); data stored in the EU; Art. 28 DPA as applicable. Used for account confirmation mail and newsletter double opt-in.
- Your own AI provider: only if you choose to connect it (see §5), under its own terms.
We do not sell personal data. We share data only as needed to run Find Your Why, comply with law, or with your instructions.
7. International transfers
We are established in Canada. If data is processed in other countries (e.g. payment or email providers), we use appropriate safeguards where required (e.g. SCCs). Details on request.
8. Cookies and similar technologies
Essential storage may be required for login and security (we use a bearer token stored in your browser to keep you signed in). We do not currently use web analytics cookies or analytics services. If that changes, we will update this policy and, where required, obtain consent.
9. Retention
- Account and path content: while your account is active, then deleted or anonymized within a reasonable period after a deletion request or account closure (unless law requires longer)
- Logs: short retention for security
- Newsletter: while subscribed, plus as long as needed to prove consent and honor opt-out
- Billing records: as required by tax/commercial law
10. Your rights
Where applicable (including GDPR), you may have rights to access, rectification, erasure, restriction, portability, and objection, and to lodge a complaint with a supervisory authority. Contact: hello@findyourwhy.coach.
11. Children
Find Your Why is intended for adults. Do not use the service if you are under the age of majority where you live (generally 18).
12. Newsletter
We send the Find Your Why newsletter only with your consent (Art. 6(1)(a)), via double opt-in. Data processed: email address; name if you provide it; signup time; IP address at signup; confirmation and unsubscribe status. Unsubscribe: link in every email, or write to hello@findyourwhy.coach.
13. Check-in (email and Telegram)
If you turn it on, Find Your Why reaches out on its own – at the cadence and on the channel you choose, by email, by Telegram, or both. The message invites you back to revisit your vision and vision board; it contains none of the content of your saved answers.
The default is off. A new account receives no prompts; you switch them on yourself in settings. The legal basis is your consent (GDPR Art. 6(1)(a)), and you can withdraw it at any time – in settings or with one click on the opt-out link that appears in every message and works without signing in.
For this we store, in readable form: your chosen cadence, your chosen channels, the time of the last send, and a random identifier for the opt-out link. We need the time so you are not messaged twice on the same day.
Telegram is a third country. If you choose Telegram, we transmit the identifier of your Telegram chat and the text of the message to Telegram (Telegram FZ-LLC, Dubai, United Arab Emirates). There is no EU Commission adequacy decision for the United Arab Emirates; the transfer takes place on the basis of your explicit consent (GDPR Art. 49(1)(a)), which you give by ticking this box. Telegram is not our processor but independently responsible – like the postal service for a letter. If you do not want this, choose email only; then nothing is transmitted to Telegram.
14. Upgrading to Caminario
Find Your Why can lead on to Caminario, a separate subscription product also operated by Spark to a Flame Consulting LLP. Your Find Your Why data is only transferred to Caminario if you explicitly ask us to when you upgrade (by confirming a transfer checkbox). Without that consent, the two products keep separate data.
15. Changes
We may update this policy. The “Effective date” will change; material changes may be announced in-app or by email.
16. Contact
hello@findyourwhy.coach · Spark to a Flame Consulting LLP · address above.