Legal & Privacy

Section 01

Privacy Policy

Adaptologie Limited ("Adaptologie", "we", "us") is the data user for all personal data collected through this website and our coaching services. We are registered in Hong Kong SAR and operate in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). This policy explains what we collect, why, how long we keep it, and how we protect it.

What We Collect

• Contact forms: Name and email address, collected to respond to your enquiry. Providing this data is voluntary; however, we cannot reply without it.
• Quiz data: Anonymous responses analysed to improve our services. No personally identifiable information is retained from quiz submissions.
• Coaching onboarding: Name, contact details, professional background, and any information you choose to share in intake forms or sessions. Providing this is necessary to deliver coaching services.
• Substack subscription: Email address, collected when you subscribe to our publication to receive updates. Subscription is entirely voluntary.
• Cookies and analytics: Basic site usage data via Google Analytics. No invasive tracking or cross-site profiling is performed.
• Payment data: Processed directly by Stripe, PayPal, or Airwallex depending on the programme. For group programmes offered as monthly subscriptions, payment card details are saved securely on the relevant payment platform. We do not store card details on our own systems.

How We Use Your Data

• To respond to your enquiries and deliver the coaching services you have engaged us for
• To personalise your coaching experience and send resources you have requested (e.g. AQ guides)
• To send marketing communications, including updates and promotions — only where you have given your explicit prior consent (see Marketing Consent below)
• To maintain accurate financial and service records as required by law
• To improve our website and services using anonymised analytics data

We will not use your personal data for any new purpose unrelated to the above without first obtaining your express written consent, as required under DPP3 of the PDPO.

Marketing Consent

We only send marketing communications where you have actively opted in. There are two pathways:

• Coaching clients: Consent is obtained as part of the written onboarding and confirmation of engagement process. You may withdraw consent at any time, in writing, to [email protected].
• Substack subscribers: Substack subscribers may be invited to opt in to marketing communications via a dedicated sign-up page at josiannerobb.com, linked from the publication's About page on Substack. Marketing consent is collected only at that point, separately from the Substack subscription itself. You may withdraw consent at any time by contacting [email protected] or using the unsubscribe link in any marketing email.

Silence does not constitute consent. We will never add you to a marketing list without an affirmative indication of agreement.

How Long We Keep Your Data

We retain personal data for up to 7 years from the end of our relationship or last contact, consistent with Hong Kong's standard record retention practices for financial and business records. After this period, data is securely deleted or irreversibly anonymised. Quiz data is anonymised at the point of collection and is not subject to this retention period.

If you request deletion of your data before this period has elapsed, we will comply unless retention is required by law (for example, financial records under the Companies Ordinance or tax obligations).

Data Security

We take all practicable steps to protect your personal data against unauthorised or accidental access, processing, loss, or disclosure. Our measures include:

• Password-protected and access-controlled systems for client records
• Use of GDPR-compliant and encrypted third-party platforms for scheduling and testimonials
• PCI-compliant payment processors (Stripe, PayPal) — we do not handle card data directly
• Restriction of data access to Josianne Robb and any directly engaged contractors, who are bound by confidentiality obligations

In the event of a data breach that is likely to result in risk to your rights or interests, we will notify affected individuals without undue delay and take immediate remedial steps.

Third-Party Data Processors

We engage the following third parties to process data on our behalf. Each is contractually or certifiably bound to appropriate data protection standards:

We do not sell, rent, or share your personal data with any third party for their own marketing purposes, and we never have.

Your Rights

Under the PDPO, and as applicable under other regulations relevant to your location, you have the following rights:

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days, as required under the PDPO.

Cookies

We use basic analytics cookies via Google Analytics. You may decline cookies via the cookie banner when you first visit the site. Declining cookies does not affect your ability to use any part of this website.

Section 02

Terms of Service

These terms apply to all use of this website and any coaching services provided by Adaptologie Limited. Clients engaging in coaching programmes are additionally governed by a formal written Confirmation of Engagement signed at the start of the relationship. Where the two documents conflict, the Confirmation of Engagement takes precedence for matters specific to your coaching programme.

Coaching Agreements

• All coaching sessions are strictly confidential. The only exceptions are where there is a credible risk of harm to you or to others, in which case we may be obliged to act in your best interests or as required by law.
• Our coaching approach is grounded in being fully present as a thinking partner. We do not take or retain notes from coaching sessions. No recording or transcription tools of any kind are used.
• A 48-hour cancellation policy applies. Sessions cancelled with less than 48 hours' notice will be forfeited unless exceptional circumstances apply, at our discretion.

Intellectual Property

• All proprietary frameworks, tools, and materials developed by Adaptologie are protected under copyright (© Adaptologie Limited).
• Client stories or case studies are shared publicly only with your explicit written permission.

Limitations

• Coaching is a professional development service. It is not therapy, counselling, medical advice, or financial or legal advice.
• Outcomes vary depending on individual commitment, context, and circumstances. No specific results are guaranteed.

Third-Party Platforms

• Senja: Testimonials (GDPR-compliant)
• CMM (GHL): Scheduling (encrypted)
• Stripe / PayPal / Airwallex: Payments (PCI-compliant)

Section 03

Pay It Forward Clause

Gift Session Terms

• Clients enrolled in our premium programme automatically have access to Pay It Forward sessions. They may gift the specified number of pre-paid sessions to a third party of their choice ("Recipient").
• Recipients must complete a brief eligibility form to ensure alignment with our coaching practice.
• Gifted sessions expire after 6 months if unused.

Recipient Agreement

• Recipients acknowledge that coaching is not therapy, financial, or legal advice.
• Recipients agree to our standard confidentiality and cancellation policies as set out in these Terms.

Limitations

• Gift sessions cannot be exchanged for cash or transferred more than once.
• We reserve the right to decline a Recipient if their needs fall outside our area of expertise.

Client Assurance

• Gifting clients receive a tax receipt for the session's fair market value (please consult your accountant regarding deductibility).
• Our liability ends once the gifted session has been conducted.

Section 04

Disclaimer

Coaching can be a powerful catalyst for growth and change. However, the client is ultimately responsible for their own decisions, actions, and outcomes. Adaptologie Limited is not liable for any decisions made or actions taken following coaching sessions.

Nothing on this website constitutes professional medical, psychological, legal, or financial advice.

Section 05

International Visitors

We work with clients across Asia and internationally. In addition to complying with Hong Kong's PDPO, we recognise obligations to clients in other jurisdictions.

EU Visitors — GDPR

If you are located in the European Union or European Economic Area, you benefit from the protections of the General Data Protection Regulation (GDPR). The legal bases on which we process your data are:

• Contract performance: To deliver the coaching services you have engaged us for
• Consent: For marketing communications and optional data collection
• Legitimate interests: For basic site analytics and business record-keeping

You may request access to, correction, deletion, or portability of your data, and may object to processing based on legitimate interests, by contacting us at [email protected]. You also have the right to lodge a complaint with your local data protection authority.

Cookies can be declined via the pop-up on your first visit to the site.

California Visitors — CCPA

If you are a California resident, you have the right to know what personal information we collect, to request deletion, and to opt out of the sale of your personal information. We do not sell personal information to any third party, and we never have. To exercise your rights under the CCPA, contact us at [email protected].

Cross-Border Data Transfers

Some of our third-party processors are based outside Hong Kong. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place, including contractual data processing agreements and the use of platforms certified under recognised data protection frameworks.