Freedom Business System®
Privacy Policy
Last updated: 26 October 2026
This privacy policy explains how Freedom Business System® collects, uses, stores and protects personal data. It applies to freedombusinesssystem.com, the Freedom Business System® programme, its applications, sales calls, cohorts, live calls, course portal, community and resources, and the masterclasses and events we run to introduce it (together, our Services).
Freedom CEO®, Kristin Morris Coaching, Momentum Membership and Freedom Business Platform each have their own privacy policy. Freedom Business Platform access included in the programme is covered by the Freedom Business Platform privacy policy.
1. Who we are
Freedom Business System® is operated by Kristin Morris, a sole trader based in Jersey, Channel Islands, trading as Freedom Business System® and Freedom CEO® (we, us, our). We are the controller of the personal data described in this policy.
- Correspondence address: PO Box 163, Jersey, JE4 8RJ
- Email: [email protected]
- Registered with the Jersey Office of the Information Commissioner (JOIC), registration number 70630
We are subject to the Data Protection (Jersey) Law 2018 (the Jersey Law). Where we process personal data of people in the United Kingdom or European Economic Area, we also aim to meet the standards of the UK GDPR and EU GDPR.
2. The personal data we collect
| Category | Examples |
|---|---|
| Identity and contact data | Name, business name, email address, phone number, country, social media handle |
| Purchase and payment data | What you bought, billing details, payment plan status and transaction history. Card details are handled by our payment provider and we never see or store your full card number. |
| Application and sales call data | Answers in your application, notes from any call to discuss the programme, and your business stage, goals and budget |
| Programme and coaching data | Onboarding answers, goals, information about your business, workbook and template answers, progress through the modules, questions you ask, and notes from coaching calls |
| Course portal and community data | Login details, course progress, posts, comments and messages in the programme community |
| Event data | Booking details and, for in-person events, any dietary or access needs you choose to tell us |
| Usage and technical data | IP address, browser and device type, pages viewed, links clicked, email opens and clicks, referral source |
| Marketing data | Your marketing preferences, the keyword, ad or free resource that brought you to us, and your responses to our emails and messages |
| Communications | Emails, direct messages and other messages you send us, and recordings of calls you attend |
More sensitive information
Coaching conversations sometimes touch on personal matters such as health, wellbeing or family circumstances. You never have to share these, and we will not ask you to. If you choose to share them in a private coaching session, we will only record what is genuinely useful for your coaching, keep it confidential, and rely on your explicit consent to do so, which you can withdraw at any time. Dietary or access needs for events are used only to make arrangements for you and deleted after the event.
3. How we collect it
- Directly from you, when you register for a masterclass or event, apply for or join the programme, book a call, complete onboarding forms, workbooks or questionnaires, post in the community or contact us.
- Automatically, through cookies, pixels and similar technology on our websites and in our emails (see section 8).
- From third parties, such as social platforms when you message us or comment a keyword (for example via Instagram, Facebook or ManyChat), our payment provider, advertising platforms, and affiliates or partners who refer you to us.
4. Why we use it and our lawful basis
Under the Jersey Law we must have a lawful basis (a condition in Schedule 2 of the Jersey Law) for each use of your personal data. These are the ones we rely on.
| Purpose | Lawful basis | Data used |
|---|---|---|
| Delivering a masterclass or event you signed up for | Performance of a contract or steps at your request; legitimate interests | Identity and contact data |
| Delivering the programme, including onboarding, course access, live calls, community, support and alumni access | Performance of a contract | Identity, purchase, programme, community and communications data |
| Setting up the Freedom Business Platform access included in your programme | Performance of a contract | Identity and purchase data |
| Recording sensitive information you choose to share in coaching | Explicit consent | Programme and coaching data |
| Taking payment, managing payment plans and collecting overdue amounts | Performance of a contract; legitimate interests (recovering money owed) | Identity and payment data |
| Reviewing applications and holding calls about whether the programme is right for you | Steps at your request before entering a contract | Identity and application data |
| Sending marketing emails and messages about the programme and future cohorts | Consent, or legitimate interests where you are an existing customer and have not opted out | Identity and marketing data |
| Advertising, including retargeting on social media | Consent (through our cookie banner) | Usage and marketing data |
| Improving the programme, our content and website, including anonymised feedback and progress data | Legitimate interests (understanding what works) | Programme and usage data, usually in aggregated form |
| Paying affiliates and partners for referrals | Legitimate interests | Identity and purchase data (limited to what is needed) |
| Keeping business and tax records | Legal obligation | Identity and payment data |
Where we rely on legitimate interests, we have weighed our interests against your rights and are satisfied that the use is fair and expected. You can ask us for more detail on that assessment.
5. Marketing
When you register for a masterclass or event, we will add you to our email list so we can send you the resource, reminders and related content we think you will find useful. We will make that clear on the sign-up form. Every marketing email has an unsubscribe link, and you can reply STOP to any marketing text or direct message, or email us at any time. Unsubscribing will not stop essential messages about something you have bought.
We never sell your personal data, and we do not share it with other businesses for their own marketing.
6. Calls, recordings and testimonials
Live cohort calls, co-working sessions and masterclasses are recorded so members can watch later, and some may be turned into training content for current and future cohorts. We will tell you at the start of any session that is being recorded. If you would prefer not to appear, you can keep your camera off, change your display name and ask questions in the chat or by email instead. Private 1:1 calls are only recorded with your agreement, and the recordings are shared only with you.
We will only use your name, image, words or results in our marketing (for example as a testimonial or case study) with your specific permission, and only using your real words. You can withdraw that permission for future use at any time.
7. AI tools
We use AI tools in running the business, for example to help draft content, summarise call notes or produce workbooks. Where personal data is involved, we use paid business accounts and, where a provider offers the setting, we switch off the use of our data to train its models, and we keep personal data out of AI tools wherever we can. We do not use AI to make decisions that have legal or similarly significant effects on you.
8. Cookies, pixels and tracking
Our websites use cookies and similar technology. Strictly necessary cookies keep the site and your login working and do not need consent. We only set analytics and advertising cookies (such as the Meta Pixel and Google Analytics) if you agree through our cookie banner, and you can change your choice at any time using the cookie settings link in the footer of our website.
Our emails may contain small tracking images that tell us whether an email was opened and which links were clicked. You can block these by turning off automatic image loading in your email app.
Some of our pages and programme resources contain affiliate links (for example to ClickUp). If you buy through these, we may receive a commission, and the provider may set a cookie to record the referral.
9. Who we share your data with
We use trusted service providers to run the business. They may only use your data to provide their services to us and must keep it secure. Our main providers are listed below.
| Provider | What they do | Where data may be held |
|---|---|---|
| Freedom Business Platform (built on HighLevel, Inc.) | Website, CRM, email, course portal, community and calendars | United States |
| Stripe | Payment processing, subscriptions and payment plans | United States and European Union |
| Workspace email and files, analytics, YouTube | United States and elsewhere | |
| Meta Platforms | Facebook and Instagram, advertising and the Meta Pixel | United States and elsewhere |
| ManyChat | Instagram and Facebook direct message automation | United States |
| Zoom | Hosting calls, webinars and masterclasses | United States |
| Descript | Editing call and video recordings | United States |
| ClickUp | Internal task and project management, and the ClickUp workspace templates shared with members | United States |
| Anthropic (Claude) and OpenAI (ChatGPT) | AI tools described in section 7 | United States |
| Our accountant and bookkeeping software | Accounts and tax | Jersey and United Kingdom |
We may also share personal data with members of our team or contractors who help deliver our Services (under confidentiality obligations), with event venues where needed for your booking, with professional advisers, with a buyer if the business or part of it is sold, and with regulators, courts or law enforcement where the law requires it.
Anything you post in the programme community or say on a group call can be seen by other members of your cohort and, through recordings, by other current and alumni members, so please think before sharing personal details there.
10. Transfers outside Jersey
Several of our providers are based in, or store data in, the United States and other countries that are not recognised as having equivalent data protection laws to Jersey. Where that happens, we make sure appropriate safeguards are in place, such as standard contractual clauses approved for use under the Jersey Law, UK GDPR or EU GDPR, or the provider's certification under a recognised data transfer framework. You can ask us for more information about the safeguards for a particular provider.
11. How long we keep it
| Data | How long we keep it |
|---|---|
| Applications that do not go ahead | 12 months from your last contact with us |
| Client and coaching records | 6 years after your programme ends, in case of questions or claims, after which they are deleted |
| Sensitive information shared in coaching | Until the end of your programme, or sooner if you withdraw consent |
| Course portal account | For as long as you have access, including alumni access, then 12 months |
| Payment and invoice records | 6 years after the end of the financial year they relate to, for tax and accounting purposes |
| Marketing list data | Until you unsubscribe, or after 24 months with no engagement from you |
| Group call recordings and community posts | For as long as the programme runs, unless you ask us to remove your contributions |
| Event dietary and access needs | Deleted within 30 days after the event |
12. Your rights
Under the Jersey Law (and the UK and EU GDPR where they apply) you have the right to:
- ask for a copy of the personal data we hold about you;
- ask us to correct anything that is inaccurate or incomplete;
- ask us to delete your data, where there is no good reason for us to keep it;
- ask us to restrict how we use your data while a concern is looked into;
- object to our use of your data where we rely on legitimate interests, and object at any time to direct marketing;
- ask us to transfer data you gave us to you or to another organisation in a commonly used format;
- withdraw your consent at any time, where we rely on consent (this does not affect anything we did before you withdrew it);
- not be subject to decisions based solely on automated processing that significantly affect you.
To use any of these rights, email us at [email protected]. We will reply within four weeks. We may need to confirm your identity first. There is normally no charge.
13. Security
We use sensible technical and organisational measures to protect personal data, including secure hosting, encrypted connections, two-factor authentication on our accounts, and limiting access to people who need it. If a data breach is likely to put you at risk, we will tell you and the JOIC as the law requires.
14. Children
Our Services are designed for adults running or starting a business. They are not intended for anyone under 18 and we do not knowingly collect their personal data.
15. Changes to this policy
We may update this policy from time to time. The date at the top shows when it was last changed. If we make a significant change, we will let current and alumni members know by email.
16. Contact and complaints
If you have a question or concern about how we handle your personal data, please contact us first at [email protected] and we will do our best to put it right.
You also have the right to complain to the Jersey Office of the Information Commissioner (jerseyoic.org). If you live in the UK, you can complain to the Information Commissioner's Office (ico.org.uk), and if you live in the EU, to your local data protection authority.
Freedom Business System® is a trading name of Kristin Morris. PO Box 163, Jersey, JE4 8RJ.