Transform28 is a private transformation sanctuary of individuals who are shifting from energetic entanglement to internal authority, intuitive clarity, and embodied power.
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Effective date: 9 September 2026
This Privacy Policy explains how Transform28.com (legal name Holistic Academy Global LTD, a company registered in the United Kingdom) collects, uses, stores, and shares personal data when you visit our websites, use our application, register for events, purchase products or memberships, upload content, or communicate through the platform.
We aim to collect only the information reasonably needed to operate the service, manage registrations and memberships, process payments, support creators and facilitators, protect the platform, comply with law, and improve the user experience.
Who we are
Information we may collect
Account and profile information
Event, community, and learning activity
Transactions and billing
Content you provide
Technical and usage information
Company listings and World Map location
Information from third parties
How we use information
We may use personal data to:
Legal bases for processing (UK GDPR)
Where UK GDPR applies, we rely on one or more of the following legal bases:
Payments and third-party processors
Payment processing is handled through Stripe and, for facilitators, Stripe Connect. Stripe processes billing information according to its own terms and privacy policy. Transform28 stores billing snapshots and transaction metadata needed to operate access control and receipts.
We may also use the following categories of service providers:
| Provider | Purpose |
|----------|---------|
| Stripe | Subscriptions, checkout, invoices, facilitator payouts |
| Bunny Stream / Bunny Storage | Video hosting, media delivery, file storage |
| Emailit | Transactional email delivery |
| OpenAI | Optional AI features such as blog SEO or transcript processing |
| Google Places | Venue search and location autocomplete |
| Hosting / CDN infrastructure | Application hosting, security, and content delivery |
These providers process data only as needed to provide their services to us or to you through the platform.
Cookies and similar technologies
We use cookies and similar technologies for:
You can control cookies through your browser settings. Some features may not work properly if required cookies are disabled.
Sharing of information
We do not sell personal information as part of the normal operation of this application. Information may be shared only when reasonably necessary to:
Facilitators, event hosts, and product owners may receive information needed to deliver the experiences you register for or purchase, such as your name, email address, attendance status, or booking details.
When you enrol in or access a course, class, programme, or related learning offering, we also share your learning progress for that offering — including lesson completion, resume position, completion status, and similar progress indicators — with the facilitator who owns that offering and with any co-facilitators or collaborators who have been granted access to manage or deliver it. This sharing is a mandatory condition of participation in those offerings (see the User Agreement & Non-Disclosure Terms). It is processed as necessary to perform the contract and to deliver the learning experience you request.
International transfers
If you access the service from outside the United Kingdom, your information may be processed in the United Kingdom and in other countries where we or our service providers maintain systems. Where personal data is transferred outside the UK, we use appropriate safeguards where required by law.
Data retention
Information may be retained for as long as reasonably necessary to operate the platform, maintain records of transactions and memberships, support customer service, resolve disputes, enforce agreements, comply with legal obligations, and preserve security or audit history. Retention periods vary depending on the type of data and the purpose for which it was collected.
Your rights
Under UK data protection law, you may have rights to:
To exercise these rights, contact hi@transform28.com. We may need to verify your identity before responding.
User content and community areas
Some parts of Transform28 are designed to be social or collaborative. If you post comments, profile information, messages, uploads, or event-related content, that information may be visible to the people and contexts for which those features were designed. Please avoid submitting sensitive information into public or semi-public areas unless you intend to share it.
Security
We use reasonable administrative, technical, and organisational measures intended to help protect personal information. No system can guarantee absolute security, so users should also take care with password choices, device access, and the information they decide to share through the platform.
Children
The service is intended for general audiences unless a specific offering states otherwise. If you believe information from a child was provided inappropriately, contact us so it can be reviewed and handled appropriately.
Changes to this policy
This Privacy Policy may be updated as the application evolves. The latest version published with the application will control going forward, and the effective date at the top will reflect the most recent revision. Material changes may also be communicated through the platform where appropriate.
Contact
Questions about privacy or this policy should be sent to hi@transform28.com.
Effective date: 5 August 2026
These Terms of Use govern access to and use of Transform28.com (legal name Holistic Academy Global LTD, registered in the United Kingdom), including our websites, application, event pages, public profiles, communities, and related digital services.
By accessing or using the platform, you agree to these Terms. If you do not agree, do not use the service.
Operator
Use of the platform
You may use Transform28 only for lawful purposes and only in connection with the community, learning, event, and commerce experiences made available through the service. You agree not to misuse the application, interfere with its operation, attempt unauthorised access, scrape the service except as permitted by law, introduce malicious code, or use the system to harass, defraud, spam, or harm others.
Accounts
Some features require an account, invite, RSVP, membership, or purchase. You are responsible for providing accurate information, maintaining the confidentiality of your login credentials, and for activity that occurs through your account.
The operator may suspend, limit, or terminate access where necessary to protect the service, comply with law, address misuse, or enforce these Terms or related agreements.
Relationship to other agreements
These Terms apply to general use of the platform. If you create an account, the User Agreement & Non-Disclosure Terms also applies. Separate terms may apply to specific events, products, facilitator tools, or purchases. Where a more specific agreement applies to a particular feature, that agreement applies in addition to these Terms for that feature.
Events, memberships, and purchases
Transform28 may offer free and paid experiences, including online access, in-person attendance, memberships, donations, subscriptions, digital content, courses, personal sessions, and related offerings. Availability, pricing, access rules, eligibility, and checkout requirements may vary by event or product.
Purchases, memberships, and donations may be subject to additional event-specific terms, payment-provider rules, cancellation windows, or facilitator policies.
Learning progress and facilitators
If you enrol in or access a course, class, programme, or related learning offering, you agree that your learning progress for that offering will be shared with the facilitator who owns it and with any co-facilitators or collaborators granted access to manage or deliver that offering. This sharing is mandatory for participation in such offerings and is described more fully in the User Agreement & Non-Disclosure Terms and the Privacy Policy.
User content
If you submit comments, messages, profile content, uploads, or other material, you represent that you have the rights needed to share it and that the content does not violate law or the rights of others. You retain ownership of your content, but you grant the platform operator a limited licence to host, store, display, reproduce, and process that content as needed to operate and improve the service.
The operator may remove or restrict content that is unlawful, abusive, infringing, deceptive, unsafe, or inconsistent with the intended community experience.
Community conduct
You agree not to post or transmit material that is defamatory, threatening, hateful, sexually exploitative, misleading, infringing, or invasive of another person's privacy. You also agree not to reverse engineer protected functionality where prohibited or attempt to bypass access controls.
Third-party services
Certain features may depend on third-party services, including payment processors, hosting providers, communications tools, media delivery networks, location services, authentication tools, analytics tools, or embedded services. Those third parties may have their own terms and policies, and the operator is not responsible for third-party systems outside the operator's reasonable control.
Availability and changes
The platform may evolve over time. Features may be added, removed, changed, interrupted, or discontinued without guaranteed continuity. While the operator aims to provide a reliable experience, the service may sometimes be unavailable due to maintenance, updates, technical failures, or external dependencies.
Disclaimers
Unless otherwise stated in a separate written agreement, the platform is provided on an "as is" and "as available" basis. To the maximum extent permitted by applicable law, the operator disclaims warranties of merchantability, fitness for a particular purpose, non-infringement, and uninterrupted availability.
Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law, including liability for death or personal injury caused by negligence or for fraud.
Limitation of liability
To the maximum extent permitted by applicable law, the operator and related facilitators, collaborators, or service providers will not be liable for indirect, incidental, special, consequential, or punitive damages, or for loss of profits, revenue, data, goodwill, or business opportunity arising from use of the platform.
Indemnity
You agree to indemnify and hold harmless the operator and related parties from claims, liabilities, damages, and expenses arising out of your misuse of the service, your content, or your violation of these Terms or applicable law.
Governing law
These Terms are governed by the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction, except where mandatory consumer protection laws in your country of residence give you the right to bring proceedings elsewhere.
Changes to these Terms
These Terms may be revised as the platform changes. The latest version published with the application will apply to future use after it is published. The effective date at the top shows when these Terms were last updated.
Contact
Questions about these Terms should be sent to hi@transform28.com.
Effective date: 9 September 2026
This User Agreement & Non-Disclosure Terms ("Agreement") is a binding contract between you ("Client", "you") and Holistic Academy Global LTD (trading as Transform28.com) ("Company", "we", "us") when you create an account or otherwise register to use the Transform28 platform.
By creating an account, you confirm that you have read and agree to this Agreement, our [Privacy Policy](#), and our [Terms of Use](#). If you do not agree, do not create an account.
Operator details
1. What Transform28 provides
Transform28 is a community, learning, and commerce platform. Depending on your role and access level, the platform may include some or all of the following:
Features may change over time. The Company may add, modify, suspend, or remove features as the platform evolves.
2. Eligibility and account registration
You must provide accurate registration information and keep your account details up to date. You are responsible for all activity that occurs under your account.
You must be old enough to enter into a binding contract in your jurisdiction. If you are using the platform on behalf of an organisation, you confirm that you have authority to bind that organisation.
Registration may require an invite, package code, external access confirmation, or other eligibility criteria depending on how access is configured.
3. Incorporation of other policies
This Agreement works together with:
If there is a conflict between this Agreement and a more specific agreement for a particular transaction or feature, the more specific agreement controls for that transaction or feature.
4. Confidential information
You acknowledge that all content, materials, methodologies, processes, systems, and information provided by the Company through the platform or related programmes are confidential and proprietary.
You agree not to disclose, reproduce, distribute, or otherwise share the Company's confidential content without prior written consent from the Company, except where disclosure is required by law.
You are explicitly prohibited from copying, imitating, or replicating the Company's modality, methods, or processes in any form.
Do not submit information into public, semi-public, or shared platform areas unless you intend it to be seen in that context. You are responsible for deciding what personal, health, financial, or other sensitive information you share through community features, messages, profiles, or uploads.
5. Use of information and content
You agree that information and content provided by the Company are for personal and educational purposes. Content may also be intended for entertainment purposes and should not be considered professional medical, legal, financial, or other regulated advice.
You shall not resell, redistribute, or exploit the Company's content for commercial purposes without prior written consent, except as expressly permitted through an affiliate, facilitator, or other authorised programme.
6. Intellectual property rights
All intellectual property rights in the Company's content and services remain the exclusive property of the Company.
You acknowledge that the Company's methodologies, processes, and systems are proprietary and unique, and agree not to use them beyond the scope of personal or educational purposes (or any other scope expressly authorised in writing).
You are prohibited from creating derivative works or using the Company's methodologies to develop competing products or services.
7. Non-compete
You agree not to use the Company's methodologies, processes, or systems to create competing products or services indefinitely, except where such restriction is unenforceable under applicable law. Where a restriction is limited by law, it applies to the maximum extent permitted.
8. User content and licence
You retain ownership of content you submit, including profile information, messages, comments, uploads, blog posts, course materials, event descriptions, and other material ("User Content").
You grant Holistic Academy Global LTD a worldwide, non-exclusive, royalty-free licence to host, store, reproduce, display, distribute, and process User Content solely as needed to operate, provide, secure, and improve the platform, including making content available to other users where the feature is designed for that purpose.
You represent and warrant that:
The Company may remove or restrict User Content that violates law, rights, or platform policies.
9. Free trial and paid access
Transform28 may offer a time-limited free trial for certain features. Trial access is managed by the platform and may expire automatically. After trial expiry, continued access to paid features may require an active subscription or other paid entitlement.
Paid subscriptions, memberships, and purchases are processed through Stripe. Billing terms, renewal, cancellation, and refunds may also be governed by Stripe's checkout flows, customer portal settings, and applicable facilitator or product policies.
10. Affiliate programme
You are encouraged to join the Company's affiliate or referral programme, where available, to earn commissions by promoting the Company's services.
Details of any affiliate or referral programme, including commission rates and payment terms, are provided separately and may change over time.
11. Events, courses, products, and facilitator offerings
Transform28 enables facilitators, hosts, and creators to publish events, courses, products, communities, and related offerings. Unless explicitly stated otherwise:
If you enable facilitator or seller features, additional obligations may apply regarding accurate listings, lawful offers, customer communications, and connected payment accounts.
11.1A World Map and T28C listing locations
Company and venue listings may include an address and related location details. When a listing is marked T28C (Transform28 certificate / map eligibility) by an authorised administrator, you acknowledge that the listing’s location may be displayed on the Transform28 World Map and sanctuary finder so others can discover facilitators and sanctuaries.
Personal live location (optional). Transform28 offers an optional Account setting to share live location. Sharing is off by default and is never required to use the community.
Until you opt in, personal live location is not shown on the World Map as a people pin. Map and API disclosure always follow your saved preferences; there is no administrator bypass of those choices.
You are responsible for ensuring that listing address and place details are accurate and that you have the right to publish them. Removing T28C eligibility (or inactivating the listing) stops new map display for that listing under the current product rules.
11.1 Learning progress shared with facilitators (mandatory)
By enrolling in, purchasing access to, or otherwise participating in a course, class, programme, or related learning offering on Transform28, you acknowledge and agree that your learning progress and related engagement data for that offering — including lesson completion, resume position, completion status, and similar progress indicators — will be shared with:
This sharing is a mandatory condition of participation. It is intended to enable facilitation, support, coaching, and delivery of the experience you join. If you do not agree to this sharing, do not enrol in or access those offerings.
Further detail on how this information is processed appears in the Privacy Policy.
If two or more scheduled events fall on the same day, the Company may facilitate a combined event covering those listings.
12. Payments, Stripe, and facilitator payouts
Platform billing and many purchases are processed through Stripe. Facilitator payouts may be processed through Stripe Connect.
By making a purchase, you agree to Stripe's Terms of Service and Privacy Policy (stripe.com/legal and stripe.com/privacy).
You agree that:
In case of payment disputes or issues, contact hi@transform28.com for resolution where appropriate.
13. Third-party integrations
The platform may connect to third-party services that you or the Company configure, including:
| Service | Typical use |
|---------|-------------|
| Stripe / Stripe Connect | Billing, checkout, subscriptions, facilitator payouts |
| Bunny Stream / Bunny Storage | Video hosting, media delivery, file storage |
| Emailit | Transactional email |
| OpenAI | Optional AI-assisted features |
| Google Places | Venue search and location autocomplete |
| Hosting / CDN providers | Infrastructure, security, and delivery |
Your use of those features may involve sharing limited data with the relevant provider. Third-party services are governed by their own terms and privacy policies.
14. Communications
By creating an account, you agree that we may send transactional messages related to your account, security, purchases, events, bookings, invitations, and service operation.
Optional marketing or inspirational content will only be sent where you have opted in or where permitted by law. You may manage marketing preferences where the platform provides controls.
15. Analytics and cookies
Transform28 may use first-party analytics, cookies, and similar technologies to secure the service, remember sessions, measure usage, and improve reliability. See the Privacy Policy for more detail.
16. GDPR and data protection
The Company acts as a data controller for personal data processed in connection with Transform28, except where another party (such as a facilitator) is the controller for their own offering. Processing is described in the Privacy Policy.
Processors and service providers used to operate the platform may include Stripe, Bunny, Emailit, OpenAI, and hosting or CDN providers. The Company aims to ensure processing is conducted in compliance with applicable UK data protection law.
For full details on what we collect, why we process it, retention, international transfers, and your rights, see the Privacy Policy.
17. No guarantee of results
The Company makes no guarantees regarding the results or outcomes of using its content, programmes, or services.
You acknowledge that results depend on your readiness, effort, participation, and other factors beyond the Company's control.
The Company is not liable for any outcomes or lack thereof resulting from the use of its content and services, except to the extent liability cannot be excluded under applicable law.
18. Client responsibility and health disclaimer
You acknowledge and accept full responsibility for your own physical, mental, and emotional well-being.
You agree to disclose any medical conditions that may require attention where relevant to your participation, and understand it is your obligation to consult with and adhere to the guidance of your healthcare provider.
The Company shall not be held liable for any medical or psychological issues that arise during or after participation in the Company's programmes, except where such liability cannot be excluded under applicable law.
You understand that the Company's services are not a substitute for professional medical advice, diagnosis, or treatment. You are encouraged to seek the advice of your physician or other qualified health provider with any questions regarding a medical condition.
The Company disclaims liability for outcomes related to your health or medical conditions. You are responsible for consulting with your healthcare provider before making health-related decisions based on the Company's services.
In the event of a medical emergency, contact your healthcare provider or emergency services immediately.
You acknowledge that individual progress depends on active participation, comprehension, and adherence to guidance provided. You agree to commit to the practices and recommendations appropriate to the offering you join where you wish to pursue the intended results.
19. Code of conduct for the community
19.1 Our goal
The Company is dedicated to creating a place of growth where individuals can thrive in a harassment-free environment. We do not tolerate harassment of community members in any form.
19.2 Applicability and scope
This code of conduct applies to all community spaces, including public channels, private channels, threads, direct messages, voice rooms, comment sections, notice boards, events, and live sessions, both online and offline. Violations may result in sanctions or expulsion at the discretion of the administrators.
19.3 Toward a welcoming and safe environment
Behaviours that contribute to this environment include:
19.4 Anti-harassment and prohibited use
Harassment of any kind will not be tolerated. Examples include:
You also agree not to use the platform to:
19.5 Reporting
If you are harassed or notice harassment, contact administrators via hi@transform28.com. Admins will respond promptly. If immediate safety is threatened, prioritise personal well-being and contact emergency services where appropriate, then notify the admins by email.
19.6 Enforcement process
Every report will be treated seriously. Immediate threats may result in temporary bans. In less urgent cases, administrators will determine a response. The decision will be final, and confidentiality requests will be respected where reasonably practicable.
19.7 Consequences
Participants asked to stop harassing behaviour must comply immediately. Failure to do so may result in expulsion and other sanctions. Discussions on avoiding future violations may be requested.
The Company may investigate reported misuse and take action including content removal, feature restriction, or account suspension.
20. Recording of video meetings
Video meetings conducted by the Company may be recorded for training and educational purposes, as well as for the creation of marketing materials.
The Company will not disclose your personal information or spoken words in marketing materials without obtaining consent (verbal or written, as appropriate to the context).
Marketing materials typically feature content spoken by the instructor. Should there be specific sections where you share information that the Company wishes to use publicly, the Company will seek explicit permission before using those parts of the recording.
Your privacy and comfort are important, and measures are taken to support a safe environment for sharing during recorded sessions.
21. Term and termination
This Agreement commences when you create an account or otherwise accept it and remains in effect while you use the platform, covering current and future products and features offered by the Company through Transform28, unless superseded by an updated version you accept.
Upon termination, you must cease use of the Company's confidential content and return or destroy any copies you are not authorised to retain.
The Company reserves the right to exclude any client from a programme, or to suspend or terminate access to the platform, if it determines the client is not a good fit to continue, or if reasonably necessary to:
You may stop using the platform at any time. Some provisions survive termination, including those relating to ownership, confidentiality, intellectual property, non-compete (to the extent enforceable), licences granted for operational purposes, disclaimers, limitations of liability, indemnity, and dispute resolution.
22. Disclaimers
The platform is provided on an "as is" and "as available" basis. To the maximum extent permitted by applicable law, Holistic Academy Global LTD disclaims warranties of merchantability, fitness for a particular purpose, non-infringement, and uninterrupted availability.
Transform28 does not guarantee the quality, safety, legality, or outcome of any event, course, session, community interaction, or third-party offering hosted through the platform.
Nothing in this Agreement excludes or limits liability that cannot be excluded or limited under applicable law.
23. Limitation of liability
To the maximum extent permitted by applicable law:
Nothing in this Agreement excludes or limits liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be limited under applicable law.
24. Indemnification
You agree to indemnify and hold the Company and related parties harmless from any claims, damages, liabilities, costs, and expenses arising from your breach of this Agreement, misuse of the Company's services, your User Content, your offerings as a facilitator or seller, or your violation of applicable law.
25. Dispute resolution
In the event of a dispute arising from this Agreement, the parties agree to attempt to resolve the matter through mediation before initiating any legal proceedings, except where urgent injunctive relief is reasonably required to protect intellectual property, confidentiality, or safety.
26. Governing law and jurisdiction
This Agreement is governed by the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction, except where mandatory consumer protection laws in your country of residence give you the right to bring proceedings elsewhere.
27. Severability
If any provision of this Agreement is found to be unenforceable, the remaining provisions shall continue in full force and effect.
28. Force majeure
The Company shall not be liable for any failure to perform its obligations under this Agreement due to events beyond its reasonable control, including but not limited to natural disasters, war, epidemic, infrastructure failures, or other unforeseen circumstances.
29. Assignment
You may not assign or transfer your rights or obligations under this Agreement without the prior written consent of the Company. The Company may assign this Agreement in connection with a reorganisation, merger, or sale of assets.
30. Notices
All notices or other communications required or permitted under this Agreement shall be in writing and delivered via email to hi@transform28.com, or through in-product notification where the platform provides that channel.
31. Enforcement and remedies
In the event of a breach of this Agreement, the Company reserves the right to seek legal action, injunctive relief, financial remedies, or other remedies available at law or in equity.
32. Changes to this Agreement
This Agreement constitutes the entire understanding between the parties regarding its subject matter and supersedes prior agreements on that subject matter, except for specific handshake, event, product, or facilitator agreements that expressly apply in addition.
The Company reserves the right to amend this Agreement at any time. When we publish an updated version, the effective date at the top will change. Clients will be notified of material changes where practicable, and continued use of the Company's services after an update may constitute acceptance of the revised terms where permitted by law. Where the platform requests renewed acceptance, you must accept to continue using affected features. Clients who do not agree to updated terms may stop using the service and terminate their account or subscription where available.
33. Contact
Questions about this Agreement should be sent to hi@transform28.com.
By using the services provided by the Company, you acknowledge and agree to abide by the terms and conditions outlined in this Agreement.
