Privacy Policy

Last updated: 2 October 2026

This Privacy Policy explains how Webley Global - FZCO collects, uses, shares, stores and protects personal information when you visit mattwebley.com, register for or attend a webinar or event, buy or use a product or service, join a community, receive our emails or messages, see or respond to our advertising, or contact us.

Please read it together with our Terms and Conditions and Cookie Policy.

1. WHO WE ARE

1.1 Webley Global - FZCO is a free zone company licensed by the International Free Zone Authority (IFZA), Dubai, United Arab Emirates, licence number 46169, with its registered address at Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates ("we", "us" or "our").

1.2 We are the controller of the personal information described in this policy. "Matt Webley" is the public-facing name of Matthew Webley, who acts on behalf of the Company.

1.3 Privacy contact: matt@mattwebley.com (please use the subject line "Privacy").

2. WHAT THIS POLICY COVERS

This policy covers personal information about website visitors, webinar and event registrants, leads, customers, members, coaching clients and people who contact us. It does not cover third-party websites, platforms or services, even where we link to them or use them to deliver our Services. Those are governed by their own privacy policies.

3. INFORMATION WE COLLECT

3.1 Information you give us:

(a) Identity and contact data: name, email address, telephone number, messaging handle, country, time zone and postal or billing address.

(b) Business data: business name, website, role, product details, stage of business, goals, challenges, revenue range, team size and similar information you share in forms, applications, surveys or calls.

(c) Transaction data: products purchased, prices, payment plan status, billing history, refunds and disputes. Card and bank details are collected and processed by our payment processors. We do not receive or store full card numbers.

(d) Account data: login details, profile information and preferences.

(e) Event and call data: registration answers, attendance, watch time, chat messages, questions, poll responses and, where calls are recorded, your image, voice, name and anything you say or show.

(f) Community content: posts, comments, messages and files you share in our communities.

(g) Communications: emails, messages, support requests, feedback, reviews and testimonials.

(h) Marketing preferences: your consent and opt-out choices.

3.2 Information collected automatically:

(a) Technical data: IP address, browser type, device type, operating system, approximate location derived from IP address, time zone and language settings.

(b) Usage data: pages viewed, links clicked, referring pages, time on page, form interactions, course progress, video views and login activity.

(c) Email and message data: whether you open emails or click links, collected through tracking pixels and tracked links.

(d) Cookie and advertising data: cookie identifiers, advertising identifiers, pixel events (such as page views, registrations and purchases) and campaign source data. See our Cookie Policy.

3.3 Information from third parties:

(a) Advertising and social platforms such as Meta (Facebook and Instagram) and Google, including information from lead forms you complete on those platforms and aggregated campaign reports.

(b) Payment processors, including confirmation of payment, fraud signals and dispute information.

(c) Webinar, community, scheduling and course platforms that we use to deliver Services.

(d) Affiliates, partners and referrers who introduce you to us.

(e) Publicly available sources, such as your business website or public social media profile, where permitted by law.

3.4 Sensitive information. We do not ask for, and you should not send us, sensitive information such as information about health, religion, ethnicity, political opinions, sexual orientation, biometrics, criminal history or government identification numbers. If you choose to share sensitive information in a call, community or message, you consent to us processing it for the purpose of providing the Services to you.

4. HOW WE USE YOUR INFORMATION AND OUR LEGAL BASES

Where the law requires a legal basis, we rely on the bases shown below.

(a) To provide the Website, webinars, events, products, courses, coaching, communities and support, and to manage your account. Basis: performance of a contract or steps at your request before a contract; legitimate interests for free Services.

(b) To process payments, manage payment plans and subscriptions, collect amounts owed, prevent fraud and handle refunds and chargebacks. Basis: performance of a contract; legitimate interests in protecting our business; legal obligations.

(c) To send service messages, such as access details, event reminders, replays, receipts, renewal notices and changes to our terms. Basis: performance of a contract; legitimate interests; legal obligations.

(d) To send marketing emails and messages about our products, services, events and offers. Basis: consent where required by law; otherwise legitimate interests in promoting our business to people who have engaged with us.

(e) To show you advertising, measure the performance of our ads and build and exclude advertising audiences. Basis: consent where required for cookies and similar technology; otherwise legitimate interests.

(f) To understand how people use our Services and to improve our content, products, website and customer experience. Basis: legitimate interests; consent where required for analytics cookies.

(g) To record calls and create training libraries, transcripts and summaries for members. Basis: performance of a contract; legitimate interests.

(h) To use testimonials, reviews, case studies and results in our marketing. Basis: consent.

(i) To secure our systems, enforce our terms, investigate misuse and account sharing, and establish, exercise or defend legal claims. Basis: legitimate interests; legal obligations.

(j) To comply with tax, accounting, record-keeping, regulatory and legal obligations, and to respond to lawful requests from authorities. Basis: legal obligations.

(k) In connection with a sale, merger, financing, restructuring or transfer of all or part of our business. Basis: legitimate interests.

When we rely on legitimate interests, we have considered that our interests are not overridden by your rights and interests. You can ask us for more information about this assessment.

5. MARKETING, MESSAGING AND ADVERTISING

5.1 Email. You can unsubscribe from marketing emails at any time using the link in any email or by contacting us. We will keep your email address on a suppression list so that we can respect your choice.

5.2 SMS, WhatsApp and similar messaging. If you give us your phone number and consent, we may send event reminders and marketing messages. Message and data rates may apply. You can opt out at any time by replying STOP or by contacting us. Your consent to receive marketing messages is not a condition of any purchase.

5.3 Advertising audiences. We may share hashed (encrypted) contact details, such as your email address or phone number, with advertising platforms such as Meta and Google so that they can match them to their users. This lets us show you relevant ads, exclude existing customers from ads and find similar audiences. These platforms act under their own terms and privacy policies.

5.4 Conversion tracking. We may use pixels and server-side tools, such as the Meta Pixel, Meta Conversions API and Google tags, to tell advertising platforms when someone registers, attends or buys after seeing an ad.

5.5 You can control personalised advertising through your browser settings and the ad settings in your Meta and Google accounts.

6. CALL RECORDINGS, TRANSCRIPTS AND AI TOOLS

6.1 Group calls and some 1:1 calls are recorded as explained in our Terms and Conditions. Recordings may be made available to other members of the relevant programme.

6.2 We may use third-party AI and software tools to transcribe, summarise, organise and analyse recordings, messages, support requests, survey answers and other content, and to help us draft responses and training. Where available, we choose settings or providers whose business terms state that customer content is not used to train their general models.

6.3 We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

7. WHO WE SHARE INFORMATION WITH

We do not sell your personal information for money. We share it only as described below.

7.1 Service providers that process information on our behalf, including:

(a) website, funnel, email, course and checkout platforms (such as Systeme.io);

(b) payment processors and fraud-prevention services;

(c) webinar, video, scheduling and video-call platforms;

(d) community platforms (such as Skool and Telegram);

(e) cloud storage, productivity, CRM, transcription and AI service providers;

(f) analytics and advertising platforms (such as Meta and Google);

(g) customer support, IT, security and hosting providers; and

(h) team members, contractors and coaches who help deliver the Services.

7.2 Professional advisers, such as lawyers, accountants, auditors and insurers.

7.3 Other members, when you post in a community, speak or appear on a group call, or choose to share information with them.

7.4 Affiliates and referral partners, limited to what is needed to confirm and pay commissions on referrals.

7.5 Authorities, courts, regulators, payment networks and others where we believe disclosure is required by law, or needed to protect our rights, property or safety or that of others, to prevent fraud or to enforce our terms, including in a chargeback dispute.

7.6 A buyer, investor, successor or other party in connection with a merger, acquisition, financing, restructuring or sale of all or part of our business or assets.

7.7 Anyone else with your consent or at your direction.

8. INTERNATIONAL TRANSFERS

8.1 We are based in the United Arab Emirates and our service providers may process information in the United States, the European Union, the United Kingdom and other countries. These countries may have data-protection laws that differ from those where you live.

8.2 Where the law requires, we transfer personal information using appropriate safeguards, such as adequacy decisions, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum or Agreement, or other lawful transfer mechanisms. You can ask us for more information about the safeguards we use.

9. HOW LONG WE KEEP INFORMATION

We keep personal information only for as long as we need it for the purposes in this policy, including:

(a) Leads and webinar registrants who do not buy: for as long as you stay subscribed and engaged, and for up to 3 years after your last interaction, unless you ask us to delete it sooner.

(b) Customer, transaction and payment records: for the duration of our relationship and for at least 7 years afterwards, or longer if required by UAE tax and accounting law or other applicable law.

(c) Account, course progress and community data: for as long as your access continues and for a reasonable period after it ends.

(d) Call recordings and transcripts: for as long as they form part of the training library for the relevant programme, or for up to 3 years for 1:1 calls.

(e) Testimonials: until you ask us to stop using them in new marketing, subject to Section 16 of our Terms and Conditions.

(f) Suppression lists: indefinitely, so that we can honour your opt-out.

(g) Information needed for fraud prevention, disputes, chargebacks or legal claims: until the matter is finally resolved and any limitation period has expired.

When information is no longer needed, we delete or anonymise it.

10. SECURITY

We use reasonable administrative, technical and organisational measures designed to protect personal information against loss, misuse, unauthorised access, alteration and disclosure. No website, platform, transmission or storage system is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your login details safe. If we become aware of a personal data breach that the law requires us to report, we will notify the relevant authority and affected individuals as required.

11. YOUR RIGHTS

11.1 Depending on where you live, you may have the right to:

(a) know whether we process your personal information and receive a copy of it;

(b) correct inaccurate or incomplete information;

(c) delete your information;

(d) restrict or object to certain processing, including processing based on legitimate interests;

(e) object at any time to direct marketing, including profiling for direct marketing;

(f) receive your information in a portable format and have it transmitted to another organisation;

(g) withdraw consent at any time, without affecting processing that took place before withdrawal;

(h) opt out of the sale or sharing of personal information, targeted advertising or profiling, where those terms apply under your local law;

(i) not be subject to decisions based solely on automated processing that have legal or similarly significant effects; and

(j) complain to a data-protection authority.

11.2 How to make a request. Email matt@mattwebley.com with the subject line "Privacy Request" and the email address you use with us. We will respond within the time the law requires, usually within 30 days. We may need to verify your identity before we act. You may use an authorised agent where the law allows, and we may ask for proof of their authority.

11.3 Some rights have exceptions. For example, we may keep information we need to complete a transaction, meet legal obligations, prevent fraud or defend legal claims. If we cannot fully meet a request, we will explain why.

11.4 We will not discriminate against you for exercising your privacy rights.

12. ADDITIONAL INFORMATION FOR SPECIFIC REGIONS

12.1 United Arab Emirates. We process personal information in line with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and other applicable UAE law.

12.2 UK, EU and EEA. Where the UK GDPR or EU GDPR applies, the legal bases in Section 4 apply and you have the rights in Section 11. You can complain to the data-protection authority in the country where you live or work, or where an alleged breach took place. In the UK this is the Information Commissioner's Office (ico.org.uk). We would appreciate the chance to address your concern first.

12.3 United States. Residents of certain US states, including California, may have the rights described in Section 11. In the past 12 months we have collected the categories of information described in Section 3, from the sources described in Section 3, for the purposes described in Section 4, and disclosed them to the categories of recipients described in Section 7. We do not sell personal information for money. Some of our advertising and analytics activity may be considered "sharing" for cross-context behavioural advertising or "targeted advertising" under state law. To opt out, email matt@mattwebley.com with the subject line "Do Not Sell or Share". Where required by law, we treat a Global Privacy Control signal from your browser as a valid opt-out request for that browser. We do not use or disclose sensitive personal information for purposes that would give you the right to limit it. If we decline your request, you may appeal by replying to our decision with the subject line "Privacy Appeal", and we will respond within the time the law requires.

12.4 Other countries. If you live elsewhere, you may have similar rights under your local law, and we will respond to requests in line with that law.

13. CHILDREN

Our Website and Services are intended only for adults aged 18 or over. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, please contact us and we will delete it.

14. SOCIAL MEDIA AND THIRD-PARTY SERVICES

When you interact with our pages, groups, ads or content on social media platforms, those platforms collect information under their own policies. For some features, such as page insights on Facebook and Instagram, we and Meta may be joint controllers. Third-party links and services are not covered by this policy, and we are not responsible for their privacy practices.

15. CHANGES TO THIS POLICY

We may update this policy when our practices, Services or legal obligations change. The date at the top shows when it was last updated. If we make material changes, we will take reasonable steps to tell you, for example by email or a notice on the Website.

16. CONTACT

Webley Global - FZCO

Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates

IFZA licence number: 46169

Email: matt@mattwebley.com (subject line "Privacy")

(c) 2026 Webley Global - FZCO. All rights reserved.

© 2026 Webley Global - FZCO. All rights reserved.

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