Privacy Policy

Last updated: February 28, 2026

The Healthy Relationship Lab is committed to protecting your privacy and handling your personal data with transparency and care. This Privacy Policy explains what data we collect, how we use it, who we share it with, how long we retain it, and what rights you have under the General Data Protection Regulation (GDPR), applicable Italian privacy law, and the California Consumer Privacy Act (CCPA) where applicable.

1. Data Controller

The data controller for personal information collected through this website is Hodaya Bengiev, operating as part of The Healthy Relationship Lab, founded by Daniel Hartman. For all privacy-related inquiries, you may contact us at [email protected] or by phone at +39 378 092 6166.

2. What Data We Collect

Contact Data Name, email address, and phone number when you fill out a form or contact us directly.
Purchase Data Transaction details collected by Paddle when you make a purchase, including billing information. We do not store your payment card details all payment data is handled exclusively by Paddle.com Market Ltd.

Usage Data Information about how you interact with our website and course content, collected via Kajabi and analytics tools. This includes pages visited, time spent, and device information.

Cookie Data Cookies and similar tracking technologies. See our Cookie Policy for full details. Non-essential cookies are only activated after you provide explicit consent via our cookie banner.

3. Third-Party Processors

We use the following third-party service providers to operate our business. Each acts as a data processor under a Data Processing Agreement (DPA):

• Paddle.com Market Ltd. - Payment processing and Merchant of Record services. Paddle handles all billing data and VAT compliance. Paddle's privacy policy is available at paddle.com/privacy
• Kajabi - Our learning management platform, which hosts course content and manages student accounts. Kajabi's privacy policy is available at kajabi.com/privacy
• Google Analytics (GA4) - Website traffic analysis and user behavior tracking. IP addresses are anonymized. Google Analytics cookies are only activated after user consent. Google's privacy policy is available at policies.google.com/privacy

4. International Data Transfers 

Some of our third-party processors - including Kajabi and Google Analytics are based in the United States and process data outside the European Economic Area (EEA). These transfers are carried out in accordance with the European Commission's Standard Contractual Clauses (SCCs) or other appropriate safeguards as required by GDPR Article 46. You may request details of the specific safeguards in place by contacting us at [email protected].

5. Legal Bases for Processing (GDPR) 

We process your personal data on the following legal bases:

• Contractual necessity - to deliver purchased courses and programs
• Legitimate interests - to improve our services and communicate with existing customers
• Legal obligation - for tax, accounting, and compliance purposes
• Consent - for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Retention 

We retain your personal data only for as long as necessary for the purposes for which it was collected:

• Contact and purchase data: retained for 10 years to comply with Italian tax and accounting obligations
• Course access data: retained for the duration of your account and up to 2 years after account closure
• Marketing data: retained until you withdraw consent or unsubscribe
• Analytics data: retained for 14 months in accordance with Google Analytics default settings

7. Your Rights

As a data subject under GDPR, you have the right to:

• Access your personal data
• Request correction or deletion
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days as required by GDPR.

 8. Children's Privacy

The Healthy Relationship Lab's website and programs are not directed at children under the age of 16. We do not knowingly collect personal data from individuals under 16. If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected] and we will delete it promptly.

9. Italian Data

Protection Authority If you believe your data has been processed unlawfully, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) at garanteprivacy.it.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will notify you by email and by updating the "Last updated" date at the top of this page. We encourage you to review this policy periodically.