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Privacy Policy

Last updated: 2 August 2026

1. Who We Are

This Privacy Policy explains how STB Integrity FZ-LLC, a free zone limited liability company registered with the Ras Al Khaimah Economic Zone (RAKEZ), United Arab Emirates, licence number 45032063, registered address FDRK0543, Compass Building, Al Shohada Road, AL-Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates (“STB Integrity”, “we”, “us”, “our”), collects and uses personal data when you use the Integrity Career Institute platform (the “Platform”), join a course waitlist, submit a coaching application, or receive our emails.

We are the controller of your personal data — meaning we decide why and how it is processed. We process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “UAE PDPL”) and, for individuals in the European Union, European Economic Area and United Kingdom, the General Data Protection Regulation (the “GDPR”) and UK GDPR.

For any privacy question or to exercise your rights, contact us at info@stbintegrity.com.

2. The Personal Data We Collect

Account and membership data

  • Name, email address and password (stored only in securely hashed form) when you create an account.
  • Your subscription details: plan, status, founding member status, billing period dates, and identifiers assigned by our payment processor.

Payment data

Payments are processed by Stripe. Your card details are entered directly with Stripe and never touch or reside on our systems. We receive from Stripe only what we need to run your membership: confirmation of payment, subscription status, invoice records and customer identifiers.

Course waitlist data

If you join a course waitlist, we collect your first name, last name, email address and your preference between the live and self-paced format. This data is held in Flodesk, our email platform.

Coaching application data

If you apply for one-to-one coaching, we collect your answers to the application questions, which concern matters such as your professional background, your history of applying for roles, and your readiness to invest in coaching. Applications are collected through Tally, our form provider. We do not request your CV, and we ask you not to include sensitive personal data (such as health information) in your answers.

Communications

Emails you send us, and records of how you interact with emails we send (such as opens and clicks, as recorded by Flodesk), and your subscription or unsubscription from marketing emails.

Technical data

Log and session data strictly necessary to deliver the Platform securely, and the cookies and similar technologies described in Section 3.

We do not knowingly collect any special categories of personal data, and we do not use automated decision-making that produces legal or similarly significant effects about you.

3. Cookies

The Platform stores or accesses information on your device only where strictly necessary to deliver the service:

  • the Platform itself sets no cookies; it uses local browser storage for session management and secure delivery of the service — keeping you logged in and the application functioning; and
  • Stripe sets cookies during checkout and payment, which are necessary to process your payment securely and to prevent fraud.

We do not use advertising cookies, third-party analytics, or any tracking for marketing purposes — whether by cookies or any similar technology. Because we use strictly necessary storage only, the law does not require your consent, and none is requested: the notice displayed on the Platform about this is informational only, to tell you transparently what we do and do not use. If our use of cookies or similar technologies ever changes, we will update this Policy and ask for your consent where required.

4. Why We Use Your Data, and on What Legal Basis

  • To provide the Platform and your membership — creating and managing your account, giving you access to member content, processing subscriptions and payments, and providing the customer portal. Legal basis: performance of our contract with you.
  • To send service communications — such as welcome emails, payment and renewal notices, failed-payment alerts, password resets and notices about changes to the service or these documents. Legal basis: performance of our contract and our legitimate interest in administering the service. These emails are not marketing and you receive them for as long as you have an account.
  • To send occasional marketing emails to members — as described in Section 5. Legal basis: our legitimate interest in informing existing customers about our own similar services, or your consent where the law of your country requires it.
  • To manage waitlists and coaching applications — assessing applications and contacting you when a course opens. Legal basis: steps taken at your request prior to entering into a contract.
  • To keep the Platform secure — authentication, role-based access control, abuse prevention and enforcement of our Terms of Use. Legal basis: our legitimate interest in the security and integrity of the service.
  • To comply with legal obligations — tax, accounting and invoicing record-keeping, and responding to lawful requests from competent authorities. Legal basis: compliance with legal obligations.

5. Marketing Emails

As a member, the emails you receive are almost entirely service emails. Occasionally — for example when we launch a new feature, or when a course opens and members receive early access or a member discount — we will email you about our own products and services. Every such email contains an unsubscribe link, and unsubscribing from marketing never affects your service emails or your membership.

If you subscribed to our newsletter before the Platform launched, we continue to email you on the basis of our existing relationship and your continued subscription, and you can unsubscribe at any time using the link in every email.

6. Who We Share Your Data With

We do not sell personal data, we do not share it with advertisers, and there is no advertising on the Platform. We share personal data only with the service providers who process it on our instructions to run the service (our processors), with professional advisers where necessary, and with authorities where the law requires it. Our processors are:

  • Supabase — database and authentication. Data is hosted in the Republic of Korea (Seoul region).
  • Vercel — hosting and delivery of the Platform (United States).
  • Stripe — payment processing (United States).
  • Flodesk — email delivery and marketing lists, including course waitlists (United States).
  • Tally — coaching application forms (Belgium, with data hosted in the European Union).
  • Resend — transactional email delivery, such as welcome emails, password resets and payment notices (United States).

7. International Transfers

We are established in the United Arab Emirates and our processors are located in several countries, so your personal data is transferred internationally. Where data of individuals in the EU, EEA or UK is transferred:

  • transfers to the Republic of Korea (Supabase) are covered by the European Commission's adequacy decision for South Korea (and its UK equivalent); and
  • transfers to the United States (Vercel, Stripe, Flodesk, Resend) are protected by appropriate safeguards, in particular the European Commission's Standard Contractual Clauses incorporated in each provider's data processing agreement, and, where the provider is certified, the EU-US Data Privacy Framework.

Under the UAE PDPL, we transfer data outside the UAE only where an adequate level of protection applies or appropriate safeguards are in place. You may contact us for more information about the safeguards used.

8. How Long We Keep Your Data

  • Account and membership data: for as long as you have an account, and for 24 months after your subscription ends — so that you can return without re-onboarding — after which it is deleted or irreversibly anonymised, unless you ask us to delete it sooner (see Section 10).
  • Billing and invoicing records: at least 5 years, as required by UAE tax law, or longer where another law requires it.
  • Waitlist and coaching application data: until the relevant course or coaching decision has been made, and for 12 months thereafter.
  • Email engagement data: for as long as you remain on our email list; if you unsubscribe, we keep the minimum record needed to honour your choice.

9. How We Protect Your Data

We apply technical and organisational measures appropriate to the risk, including: encryption of data in transit; passwords stored only in hashed form; access to content and administrative functions enforced at the database level through role-based rules, so that restrictions cannot be bypassed through the interface; payment card data handled exclusively by Stripe, a PCI-DSS certified processor; and access to member data restricted to the founder. No system is perfectly secure, but if we become aware of a personal data breach affecting you, we will notify you and the competent authorities where the law requires it.

10. Your Rights

Depending on the law that applies to you (the GDPR, UK GDPR or the UAE PDPL), you have the right to:

  • access the personal data we hold about you and receive a copy;
  • correct inaccurate or incomplete data;
  • request deletion of your data;
  • restrict or object to processing, including objecting to marketing at any time;
  • receive your data in a portable format;
  • withdraw consent at any time, where processing is based on consent, without affecting processing that took place before withdrawal.

To exercise any of these rights, email info@stbintegrity.com. We may need to verify your identity. We respond within one month, extendable where the law permits for complex requests. Exercising your rights is free of charge except where a request is manifestly unfounded or excessive.

If you are in the EU, EEA or UK, you also have the right to lodge a complaint with the data protection authority of your country of residence. In the UAE, complaints may be addressed to the UAE Data Office. We would appreciate the chance to address your concern first, but you may contact an authority at any time.

11. Children

The Platform is intended for professionals and is not directed at anyone under 18. We do not knowingly collect personal data from anyone under 18; if you believe we have done so, contact us and we will delete it.

12. Changes to This Policy

We may update this Policy from time to time, for example when our tools or practices change. Non-material updates take effect when posted with a revised “Last updated” date. If we make a material change to how we use your personal data, we will notify you by email before the change takes effect.

13. Contact

STB Integrity FZ-LLC — Integrity Career Institute

FDRK0543, Compass Building, Al Shohada Road, AL-Hamra Industrial Zone-FZ · RAKEZ license no. 45032063 · Ras Al Khaimah, United Arab Emirates

All communications should be sent by email to: info@stbintegrity.com.