Privacy Policy (Driven Publishers Elite)

Effective date: 20th November 2025

1. Who we are (Controller)

Controller: Driven DS Solutions
CY60201417F
Kyriakou Matsi, 46, Office 101, 1082, Nicosia, Cyprus

Contact (Privacy): support@drivenpublishers.com

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use Driven Publishers Elite (DPE) websites and services, including our 1-year membership, course content, coaching calls, and related communications.

2. What data we collect

Account & Membership Data

Identification and contact details (e.g., name, email, phone number).
Membership status (Active/Expired), purchase date, expiration date, access logs, and progress within the course materials.
Service communications (e.g., onboarding emails, expiration warnings, and community announcements).

Billing & Payments

We do not store full credit card details.
All payments are processed by our authorized merchant of record, Whop.
We receive transaction metadata from Whop (e.g., transaction ID, payment status, customer name, and email) to verify your access rights.
Whop acts as an independent controller for billing data and tax compliance.

Website & Platform

Server logs, device and browser information, IP address, timestamps.
Cookies/local storage/session storage (see Cookie section).
Hosting and application functions are provided by GoHighLevel (HighLevel Inc.).

Communications & Support

Messages you send via forms, phone, or email.
Newsletter preferences, unsubscribe actions, and email engagement data (opens/clicks).

Community Calls & Recordings

Participation in live sessions (Q&A/Education/Mastermind).
Video and audio recordings of these sessions, which are posted as replays for the community.
Occasional excerpts used as short highlights for promotional or educational purposes (where permissible).

Marketing & Analytics Identifiers

Google Analytics 4 (GA4) client identifiers, Google Ads conversion identifiers, Meta/Facebook Pixel identifiers, and related events (only where consented).

3. Why we process your data (Purposes & Legal bases)

Under the GDPR, we rely on the following legal bases:

Performance of a Contract (Art. 6(1)(b)): To create/manage your account; provide the DPE 1-year access; deliver course content and live sessions/replays; send service emails (e.g., expiration notices, access credentials); and handle customer support.
Legitimate Interests (Art. 6(1)(f)): Platform security; fraud prevention; diagnosing service issues; measuring core service performance; maintaining a professional community environment; internal business records where proportionate.
Legal Obligations (Art. 6(1)(c)): Tax/accounting records (verifying transaction data from Whop); regulatory disclosures; honoring data subject rights.
Consent (Art. 6(1)(a)): Cookies/trackers (GA4, Google Ads, Meta Pixel), newsletter sign-ups not covered by soft opt-in, and any optional features requiring consent.

You can withdraw consent at any time via the cookie banner (“Cookie Settings”) or the unsubscribe link in emails.

Service vs. Marketing Emails:

Service Emails: (e.g., “Your access credentials,” “Your membership is expiring in 7 days”) are essential to your contract and you cannot opt-out of them while your membership is active.
Marketing Emails: (e.g., new offers, newsletters) can be opted out of at any time via the “Unsubscribe” link in the footer of the email.

4. Hosting, Platform & Key Processors

We use reputable providers to operate DPE. Below are the core services:

GoHighLevel (HighLevel Inc.): Hosting, CRM, mailing, and website infrastructure (USA). Used for course delivery and communication.
Whop: Merchant of Record for payments, access management, and software licensing. Whop is a US-based company that utilizes Stripe for payment processing.
Bunny.net (CDN): Video delivery and site performance.
Font Awesome: Webfonts and icons.
Google reCAPTCHA: Spam/bot protection on forms.

We may add/replace providers over time while preserving substantially equivalent protections.

5. Provision of the website (Web Hosting) & Logs

Our site is hosted on GoHighLevel infrastructure. When you visit, standard server logs are collected (e.g., IP, device, OS, browser, timestamp, requested file).
Legal bases: Legitimate interests (secure, reliable service).

6. Contact Channels

If you contact us via form, phone, or email, we process your submitted data to handle your request.
Legal bases: Contract/pre-contract where applicable; otherwise legitimate interests.

7. Membership Model Specifics (Fixed Term)

We process your purchase date and expiration date to strictly enforce the 1-year access window. We process data to automatically revoke access 365 days after purchase unless a manual renewal is processed.

Recordings: We process attendance and recordings of live sessions to make replays available to the community.

8. Payments & Invoices (Whop)

Purchases are processed by Whop, which acts as the Merchant of Record.

Whop handles payment authorization, fraud prevention, tax calculation (VAT/Sales Tax), and invoicing as an independent controller.
Whop transmits the status of your payment to us so we can grant access to the community.
Whop infrastructure is hosted in the United States. Transfers rely on standard adequacy decisions or Standard Contractual Clauses (SCCs).

Please review Whop’s Privacy Policy for details on how they handle your financial data.

9. Cookies & Consent (Real Cookie Banner)

We use cookies to keep the site functional and secure (Necessary). With your consent, we use Analytics and Marketing cookies.
Consent is collected via the Real Cookie Banner plugin and can be changed at any time via the “Cookie Settings” link in the page footer.

10. Analytics (Google Analytics 4)

We use Google Analytics 4 (GA4) to understand site usage. We deploy Google Tag Manager (GTM) with Consent Mode v2, so GA4 only runs after you’ve opted in.
Legal basis: Consent.

11. Advertising & Conversion Tracking

Google Ads: With your consent, we use tags to attribute conversions (purchases) to our ads.
Meta/Facebook Pixel: With your consent, we use the Meta Pixel to measure ad performance and build remarketing audiences.
Remarketing: We may show you ads on other platforms based on your visit to our site, but only if you have consented to marketing cookies.

12. Data Retention

We apply the storage limitation principle:

Transaction Records: Retained for tax/audit purposes (typically 6-10 years depending on Cyprus/EU tax laws).
Support Communications: Typically 24 months after closure.
Analytics Data: Default 14 months (GA4).
Call Recordings: Retained while the content remains relevant to the current community curriculum.

13. International Data Transfers

Some processing occurs outside the EEA (e.g., USA for GoHighLevel, Whop, Google, Meta). Where applicable, we rely on:

EU-US Data Privacy Framework (DPF) self-certification (where the vendor is certified), and/or
Standard Contractual Clauses (SCCs).

14. Your Rights (GDPR)

You have the right to access, rectify, erase, restrict, transfer (portability), object to processing, and withdraw consent. You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus).

15. Children

DPE is intended for individuals 18+. We do not knowingly collect children’s data.

16. Security

We implement commercially reasonable technical and organizational measures. Payment data is handled by Whop and is never stored on our local servers.

17. Changes to this Policy

We may update this Policy. Material updates will be communicated by email or website notice.

18. How to Contact Us

Controller: Driven DS Solutions Limited
Address: Kyriakou Matsi, 46, Office 101, 1082, Nicosia, Cyprus
Privacy Contact: support@drivenpublishers.com

Cookie & Tracking Overview (Annex)

Consent tool: Real Cookie Banner (WordPress Plugin)

Strictly necessary: Security, essential platform features (Legitimate interests).
Analytics: GA4 via GTM (Consent).
Advertising: Google Ads, Meta Pixel (Consent).