Privacy Policy

Privacy & Data Protection

Last updated: 1 September 2026

PIVOT is operated by DUMOND LEARNING OÜ, an Estonian private limited company, registry code 14870526. This Privacy Policy explains how we collect, use, store and protect personal information when you use PIVOT and dumondeducation.com.

For privacy enquiries, data-access requests or other questions about your personal information, contact privacy@dumondeducation.com.

1. Information we may collect

  • Account information, such as your name, email address, username, membership level and account preferences.
  • Membership and transaction information, including purchases, subscription status, payment status, refunds and PIVOT Credit transactions. We do not store your full payment-card details.
  • PIVOT Journal information, including actions, reflections, development records and other information you choose to save.
  • Voice and transcription information when you choose to use voice-enabled features. Audio may be processed for transcription. PIVOT is designed to retain the resulting text rather than maintain a permanent library of your voice recordings unless a feature clearly tells you otherwise.
  • Coaching and booking information where you choose to book a coaching or other human-delivered service.
  • Technical and usage information, such as login activity, pages visited, device/browser information, IP address, security logs and information required to keep the platform working safely.
  • Communications you send to us, including support requests, feedback and issue reports.

2. Why we use your information

We use personal information only where we have an appropriate legal basis. Depending on the circumstances, this may include performing our agreement with you, complying with a legal obligation, pursuing legitimate interests such as operating and securing PIVOT, or acting with your consent.

  • To create and manage your PIVOT account.
  • To provide Free, Premium and other eligible membership features.
  • To maintain your private PIVOT Journal and development records.
  • To process purchases, subscriptions, renewals, refunds and membership entitlements.
  • To administer PIVOT Credits, rewards and benefits.
  • To provide coaching, bookings and other requested services.
  • To provide voice transcription and other optional AI-assisted functions.
  • To respond to questions, support requests and reported problems.
  • To protect PIVOT, our members and our systems from misuse, fraud and security threats.
  • To analyse platform performance and improve PIVOT.
  • To comply with accounting, tax, legal and regulatory obligations.

3. Your PIVOT Journal

Your PIVOT Journal is designed as a private personal-development space. Journal information is stored against your account and is not made public. PIVOT uses technical safeguards and account separation to protect one member’s Journal from another member.

We do not routinely read members’ private Journal entries. Access may occur only where technically necessary to provide support requested by you, investigate a security or platform problem, comply with a legal obligation, or where you have deliberately shared information with us.

4. Payments and subscriptions

PIVOT uses third-party payment providers rather than storing full payment-card details itself.

For eligible automated digital products, including PIVOT Premium where available, checkout may be provided through Stripe Managed Payments. For those transactions Stripe acts as merchant of record and is responsible for the payment transaction, applicable indirect tax handling and related checkout functions under its own terms and privacy practices.

Other services, including certain human-delivered services such as coaching, may use a different supported payment route. The payment provider and applicable terms are shown during checkout.

5. PIVOT Credits and rewards

Where your account uses PIVOT Credits, we record information such as your balance, credits earned, credits used and relevant reward events. PIVOT Credits are a platform benefit and are not payment-card or bank-account information.

6. AI-assisted and transcription features

Some PIVOT features may use specialist service providers to process information on our behalf, including speech-to-text or other AI-assisted functions. Information is sent only where required to provide the feature you have chosen to use.

You should not enter passwords, payment-card numbers or other information that you would not want processed by the relevant service when using AI-assisted features.

7. Who we may share information with

We do not sell your personal information. We may share information with trusted service providers only where necessary to operate PIVOT, provide a service you requested, protect the platform, or comply with the law.

  • Website hosting, infrastructure and security providers.
  • Payment and merchant-of-record providers.
  • Email and communication providers.
  • Booking and service-management providers.
  • Transcription and AI-processing providers where you use those features.
  • Analytics or technical-monitoring providers where enabled.
  • Professional advisers, regulators, courts or public authorities where required by law.

8. International processing

Some technology providers may process information outside Estonia or the European Economic Area. Where required, we use providers and safeguards intended to ensure that personal information remains protected in accordance with applicable data-protection law.

9. How long we keep information

We keep personal information only for as long as it is reasonably required for the purpose for which it was collected, to provide your account and services, resolve disputes, protect the platform, and meet legal, tax and accounting obligations.

Different information may therefore have different retention periods. For example, financial transaction records may need to be retained for statutory accounting purposes even after an account is closed.

10. Cookies and similar technologies

PIVOT uses cookies and similar technologies where required for functions such as login, account security, preferences, shopping and platform operation. Additional analytics or other non-essential technologies, where used, are managed in accordance with applicable consent requirements.

11. Security

We use technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse or disclosure. No internet-based system can be guaranteed to be completely secure, but protecting member information is an important part of how PIVOT is designed and operated.

12. Your data-protection rights

Depending on the circumstances and applicable law, you may have rights to:

  • request access to personal information we hold about you;
  • ask us to correct inaccurate or incomplete information;
  • ask us to delete personal information where the law permits;
  • restrict or object to particular processing;
  • request portability of eligible information;
  • withdraw consent where processing is based on consent; and
  • complain to an appropriate data-protection supervisory authority.

To exercise a privacy right, email privacy@dumondeducation.com. We may need to verify your identity before acting on a request.

13. Other websites and services

PIVOT may contain links to third-party websites or services. Their privacy practices are governed by their own policies, and we are not responsible for how an independent third party uses information you provide directly to it.

14. Changes to this policy

We may update this Privacy Policy when PIVOT, our service providers or applicable legal requirements change. The current version will be published on this page with its most recent update date.

15. Contact

DUMOND LEARNING OÜ
Registry code: 14870526
Estonia
Email: privacy@dumondeducation.com