Privacy Policy

nondualship.com  •  Toshi Matsunaga

Last updated: April 2026  •  Compliant with UK GDPR & Data Protection Act 2018

This Privacy Policy explains how Toshi Matsunaga (“we”, “us”, “our”) collects, uses, stores and protects your personal data when you use nondualship.com and related services. Please read it carefully.

We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The data controller responsible for your personal data is:

Toshi Matsunaga

Website: https://nondualship.com

Contact: toshi.matsunaga.ki@gmail.com

As data controller, we determine the purposes and means of processing your personal data. If you have any questions about this Privacy Policy or how we handle your data, please contact us at the email address above.

We may collect the following categories of personal data:

• Name and email address (when registering or making a purchase)
• Payment information (processed securely via our third-party payment provider — we do not store full card details)
• Any personal information you share during sessions, workshops, retreats, or in the membership space
• Communications you send to us by email or through the Website

• IP address and browser type
• Pages visited and time spent on the Website
• Cookie and tracking data (see Section 9)

In the course of providing our spiritual and mentorship services, you may voluntarily share information that could be considered sensitive, such as information about your mental or emotional wellbeing. We treat all such information with the utmost confidentiality and do not process it beyond what is necessary to deliver our services.

We will never collect or process special category data (such as health data) without your explicit consent.

We use your personal data only for the purposes described below. The table sets out our lawful basis for each type of processing under UK GDPR Article 6.

Category: Account & Purchases

Data Used: Name, email, payment info

Purpose: Process your purchase and provide access to Services

Lawful Basis: Contract (Art. 6(1)(b))

Category: Service Delivery

Data Used: Session content, recordings

Purpose: Deliver mentorship, training, membership services

Lawful Basis: Contract (Art. 6(1)(b))

Category: Internal Mentoring

Data Used: Session info, recordings

Purpose: Share among faculty mentors/trainers to improve facilitation

Lawful Basis: Consent (Art. 6(1)(a))

Category: Marketing & Promotion

Data Used: Name, image, recordings

Purpose: Use excerpts in marketing or promotional materials

Lawful Basis: Consent (Art. 6(1)(a))

Category: Future Training Products

Data Used: Recordings, session content

Purpose: Include in future training programmes or courses

Lawful Basis: Consent (Art. 6(1)(a))

Category: Legal Compliance

Data Used: Any relevant data

Purpose: Comply with legal obligations

Lawful Basis: Legal obligation (Art. 6(1)(c))

Category: Website Analytics

Data Used: IP address, usage data

Purpose: Improve website performance and user experience

Lawful Basis: Legitimate interests (Art. 6(1)(f))

Where we rely on consent as our lawful basis, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Sessions, workshops, and retreats may be recorded. By purchasing our Services, you acknowledge this. We will use recordings only for the purposes for which you have given separate, explicit consent, which may include:

• Sharing within our faculty of mentors and trainers (to improve service quality)
• Use in future training products or courses
• Use in marketing or promotional materials

Each of these uses requires your separate opt-in consent at the point of purchase. You may withdraw consent for any of these uses at any time by contacting us at toshi.matsunaga.ki@gmail.com.

If you prefer not to appear in any publicly released material, please notify us at toshi.matsunaga.ki@gmail.com and we will ensure your presence is redacted before any release.

We retain your personal data only for as long as necessary for the purposes set out in this Policy, or as required by law. Our standard retention periods are:

• Account and purchase records: 7 years (required for UK tax and financial compliance)
• Session recordings (internal/training use): up to 5 years, or until consent is withdrawn
• Marketing recordings: until consent is withdrawn or the material is no longer used
• Website analytics data: up to 26 months
• Email correspondence: up to 3 years

When your data is no longer needed, we will securely delete or anonymise it.

We do not sell your personal data. We may share it with:

With your consent, relevant session information and recordings may be shared among our internal faculty of mentors and trainers to support effective facilitation.

We use carefully selected third-party providers who process data on our behalf, including:

• Payment processors (e.g. Stripe or similar) — to handle transactions securely
• Membership platform providers — to manage your account and access
• Email service providers — to send you communications

All third-party processors are required to handle your data securely and only for the purposes we specify, in accordance with UK GDPR.

We may disclose your data if required to do so by law, or in response to a valid request from a public authority (e.g. the police or a regulatory body).

Some of our third-party providers may be based outside the UK. Where your data is transferred internationally, we ensure appropriate safeguards are in place in accordance with UK GDPR, such as Standard Contractual Clauses or adequacy decisions.

You have the following rights in relation to your personal data:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to ask us to correct inaccurate or incomplete data
• Right to erasure (“right to be forgotten”) — to request deletion of your data in certain circumstances
• Right to restrict processing — to ask us to limit how we use your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us at toshi.matsunaga.ki@gmail.com. We will respond within one calendar month of receiving your request.

You also have the right to lodge a complaint with the UK’s data protection supervisory authority:

Information Commissioner’s Office (ICO)

Website: https://ico.org.uk

Helpline: 0303 123 1113

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction or alteration. These include:

• Secure (HTTPS) connections on our Website
• Access controls limiting who can view personal data
• Use of reputable, security-certified third-party platforms for payment and data storage

However, no method of transmission over the internet is entirely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

Our Website uses cookies and similar tracking technologies to improve your experience. Cookies are small text files placed on your device. We use:

• Essential cookies — necessary for the Website to function (no consent required)
• Analytics cookies — to understand how visitors use our Website (requires consent)
• Functional cookies — to remember your preferences (requires consent)

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the Website.

Our Services are not directed at or intended for use by individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at toshi.matsunaga.ki@gmail.com and we will delete it promptly.

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this document and, where the changes are significant, notify you by email or by a prominent notice on our Website. We encourage you to review this Policy periodically.

If you have any questions, concerns or requests relating to this Privacy Policy or our data practices, please contact us:

Toshi Matsunaga

Email: toshi.matsunaga.ki@gmail.com

Website: https://nondualship.com

We aim to respond to all enquiries within 5 working days.

This Privacy Policy has been drafted to comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. It does not constitute legal advice. You are encouraged to seek independent legal counsel to ensure full compliance with applicable data protection law.