Privacy Policy

Who We Are — Data Controller

SalsSky operates The Ascendancy Portal — a self-transcendence narrative platform. For the purposes of applicable data protection law, SalsSky acts as the data controller responsible for your personal information.

We operate as a global platform serving members worldwide. Our services are accessible internationally, and our data practices are designed to comply with applicable privacy and data protection laws in the jurisdictions where we operate.

What Data We Collect

SalsSky operates on a principle of data minimisation. We collect only what is genuinely necessary to provide and improve the Portal experience.

Data you provide directly:

• Identity data — your name (if provided during registration)
• Contact data — your email address, used for account creation, access management, and service communications
• Payment data — billing information processed by our authorised payment provider (Stripe or equivalent). SalsSky does not store card numbers or full payment details directly
• Communications — messages you send us via email or support channels
• Session data — if you join a SoulFire Session as a Participant, your voice may be heard and recorded by other attendees and archived, as disclosed in our Terms of Service

Data collected automatically:

• Technical data — IP address, browser type and version, device type, operating system, time zone
• Usage data — pages visited, chapters read, session duration, click interactions within the Portal
• Cookie and tracking data — see Section 9 (Cookies) for full details

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric information.

Why We Collect It — Purposes and Legal Bases

We process your personal data only where we have a lawful basis to do so. The following table sets out our purposes and the corresponding legal basis for each.

Where we rely on legitimate interest, we have assessed that our interests do not override your rights and freedoms. You may object to processing based on legitimate interest at any time — see Section 7 (Your Rights).

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

Who We Share Your Data With

SalsSky does not sell, trade, or rent your personal data to any third party. We share data only where strictly necessary, with the following categories of recipients:

• Payment processors — e.g. Stripe, for secure processing of your purchase. Their privacy practices are governed by their own policies.
• Platform infrastructure providers — hosting, database, and security services that support Portal operations. These providers act as data processors under our instruction and are contractually bound to protect your data.
• Email and communications providers — used to deliver account-related emails and service updates.
• Analytics providers — anonymised or pseudonymised usage data may be shared with analytics tools to help us understand and improve Portal performance.
• Legal and regulatory authorities — where we are required to disclose data by applicable law, court order, or lawful government request.

All third-party processors are assessed for compliance with applicable data protection standards prior to engagement. Where required, we maintain Data Processing Agreements (DPAs) with these providers.

International Data Transfers

SalsSky serves a global membership. Your data may be processed and stored in countries outside your country of residence, including countries outside the European Economic Area (EEA) or the United Kingdom.

Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the European Commission or UK ICO
• Standard Contractual Clauses (SCCs) approved by the European Commission
• UK International Data Transfer Agreements (IDTAs) where applicable
• Binding Corporate Rules or equivalent contractual protections

You may request details of the safeguards in place for any specific international transfer by contacting us at support@salssky.com

Data Retention

We retain your personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law.

• Account and access data — retained for the duration of your Portal membership and for up to 3 years thereafter for security and dispute resolution purposes.
• Payment records — retained for a minimum of 7 years in accordance with financial and tax regulations.
• Support communications — retained for up to 3 years from the date of the last communication.
• Usage and analytics data — anonymised or aggregated data may be retained indefinitely. Identifiable usage data is deleted within 26 months.
• SoulFire Session recordings — retained as part of the session archive for the lifetime of the Portal unless a removal request is submitted and upheld.

You may request deletion of your account and associated personal data at any time. See Section 7 (Your Rights) for how to do this. Note that deletion of certain data may affect your ability to access the Portal.

Your Privacy Rights

Depending on where you are located, you hold specific rights in relation to your personal data. SalsSky respects and supports all rights set out below for all members, regardless of jurisdiction.

How to exercise your rights: Submit your request by email to support@salssky.com with the subject line "Privacy Rights Request." We will respond within 30 days (or 45 days where permitted by law for complex requests). We do not charge a fee for reasonable requests.

We may need to verify your identity before processing your request. This is to protect your data from unauthorised access.

If you believe we have failed to handle your data in accordance with applicable law, you have the right to lodge a complaint with your local supervisory authority:

• EU / EEA — your national Data Protection Authority (DPA)
• United Kingdom — Information Commissioner's Office (ICO) · ico.org.uk
• Australia — Office of the Australian Information Commissioner (OAIC) · oaic.gov.au
• India — Data Protection Board of India (once operative under DPDPA 2023)
• UAE — UAE Data Office · dataoffice.ae
• USA (California) — California Privacy Protection Agency (CPPA)

Data Security

We implement technically and organisationally appropriate security measures to protect your personal data against unauthorised access, alteration, disclosure, destruction, or accidental loss.

• Encrypted data transmission via TLS/HTTPS across all Portal endpoints
• Secure, access-controlled hosting infrastructure
• Password hashing and salting — we do not store passwords in plain text
• Restricted internal access to personal data on a need-to-know basis
• Regular security reviews of third-party integrations
• Content protection measures against unauthorised copying or scraping

While we maintain rigorous security standards, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that presents a high risk to your rights, we will notify affected members in accordance with applicable law — and without undue delay.

Cookies and Tracking Technologies

The SalsSky Portal uses cookies and similar technologies to operate the platform, remember your session, and understand how readers engage with the content.

Types of cookies we use:

• Strictly Necessary Cookies — essential for the Portal to function. These cannot be disabled. They include session authentication tokens and security cookies.
• Functional Cookies — remember your preferences, such as reading progress and display settings.
• Analytics Cookies — help us understand how the Portal is used (e.g. which scenes are read most, where readers drop off). Used to improve the experience. Enabled only with your consent where required by law.
• Marketing Cookies — used to measure the effectiveness of advertising campaigns (e.g. Meta or Google Ads). Only placed with your explicit consent.

Your cookie choices: You may accept, reject, or manage cookie preferences via the cookie consent banner displayed on your first visit to the Portal. You may also manage cookies through your browser settings at any time. Disabling certain cookies may affect Portal functionality.

We respect Global Privacy Control (GPC) signals where technically supported. If your browser transmits a GPC signal, we will treat this as a request to opt out of sale or sharing of personal data for advertising purposes.

Children's Privacy

We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor has provided personal data without parental consent, we will delete that data promptly.

If you believe a minor has accessed the Portal or submitted personal data, please notify us immediately at support@salssky.com

This applies globally and is consistent with COPPA (USA), GDPR Article 8 (EU/UK), and equivalent laws in Australia, India, and the UAE.

Jurisdiction-Specific Disclosures

In addition to the rights described in Section 7, the following jurisdiction-specific provisions apply:

European Union and UK (GDPR / UK GDPR)

• Our lawful bases for processing are set out in Section 3.
• You have the right to lodge a complaint with your national DPA or the UK ICO.
• Where we transfer data outside the EEA or UK, we use approved safeguards as described in Section 5.
• We do not engage in solely automated decision-making that produces legal or similarly significant effects.

California, USA (CCPA / CPRA)

• We do not sell or share personal information as defined under CCPA/CPRA.
• California residents may request access, deletion, correction, and portability of their personal information.
• We do not use sensitive personal information for purposes beyond those permitted without an opt-out right.
• We will not discriminate against you for exercising your CCPA rights.
• To submit a CCPA rights request, email support@salssky.com with subject: "California Privacy Rights."

Australia (Privacy Act 1988 / Australian Privacy Principles)

• You may request access to or correction of the personal information we hold about you.
• We will not use or disclose personal information for a secondary purpose without your consent, subject to permitted exceptions under the Act.
• Complaints may be directed to the Office of the Australian Information Commissioner (OAIC).

India (Digital Personal Data Protection Act 2023)

• We process your personal data only with your consent or under legitimate uses as defined under the DPDPA 2023.
• You have the right to access, correct, and erase your personal data, and to nominate a representative to exercise these rights.
• We will notify the Data Protection Board of India of significant data breaches as required by law.

UAE (Federal Decree-Law No. 45 of 2021)

• Personal data is processed on the basis of consent or legitimate purpose as required by UAE data protection law.
• You may submit requests to access, correct, or delete your data in accordance with your rights under UAE law.
• Complaints may be directed to the UAE Data Office at dataoffice.ae.

Marketing Communications

Where you have provided your email address and indicated interest in receiving communications from SalsSky, we may send you updates about new content, portal enhancements, SoulFire Sessions, and community announcements.

You may opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Emailing support@salssky.com with the subject: "Unsubscribe"

Opting out of marketing communications does not affect essential service emails such as account confirmations, access links, or refund notifications.

Where required by law (including in the EU, UK, and certain US states), we will obtain your explicit consent before sending marketing communications.

Third-Party Links

The SalsSky Portal may contain links to third-party websites, platforms, or services — including payment providers, community platforms, or session conferencing tools.

SalsSky is not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policy of any site you visit via a link from the Portal.

Changes to This Policy

SalsSky reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or platform features.

When we make material changes, we will:

• Update the effective date at the top of this page
• Notify active Portal members via the email address associated with their account
• Where required by law, seek fresh consent for any materially new processing activities

Continued use of the Portal after notification of changes constitutes acceptance of the revised Policy.

Contact — Privacy Enquiries

For any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our Privacy team: