Privacy Policy

Last updated: 3 May 2026

1. Who we are

AOOC LTD is a company incorporated in the United Kingdom.

We trade as The Chapter System, thechaptersystem.com, and Jason Berry.

Our website is thechaptersystem.com.

You can contact us at hello@thechaptersystem.com.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website, buy our products, join our waitlist, create an account, use our habit tracker, or access our coaching services.

We process personal data under UK GDPR and the Data Protection Act 2018.

2. International users

We are based in the United Kingdom, but our website, products, and services may be accessed by users in other countries.

If you are based outside the United Kingdom, other privacy laws may also apply to how your data is handled.

If you are based in the European Economic Area, EU GDPR may apply to our processing of your personal data where we offer goods or services to you or monitor behaviour covered by EU GDPR.

Where required, we will respect any mandatory privacy rights that apply to you under your local data protection laws.

3. What data we collect and why

We only collect data we need to run the business, deliver our products, improve the website, keep accounts secure, and communicate with you.

Name and email address

We collect your name and email address when you buy a product, join a waitlist, create an account, or contact us.

We use this to deliver purchases, create your account, send login or access details, provide customer support, and send marketing emails where allowed.

Phone number

We may collect your phone number on waitlist forms. This is optional.

We use it to contact you about relevant products, coaching, or services where you have chosen to provide it.

Password

If you create an account, we store your password in a hashed form.

We never store your password in plain text.

Purchase history and product access

We keep records of what you bought, when you bought it, and what products your account can access.

This helps us give you access to your products, provide support, and meet our tax and accounting obligations.

IP address

We may collect your IP address for security reasons, including new device checks and two-factor authentication.

Session data

We use session data to keep you logged in and make the website work properly.

UTM parameters

We may collect anonymous UTM parameters to understand which marketing campaigns lead people to our website.

Analytics and usage data

We use Google Analytics 4 to understand how people use the website. This data is anonymised where available.

We use Microsoft Clarity to view session recordings and heatmaps. This helps us improve the website and user experience.

Advertising data

We use Facebook Pixel and Facebook Conversions API for advertising attribution.

Where email data is used for attribution, it is hashed before being shared with Meta.

AI coaching feature data

If you use an AI coaching feature, your messages may be processed by AI providers such as Anthropic, OpenAI, or Google so the feature can respond to you.

These messages are processed to provide the service. They are not used by us for marketing.

Where available, we configure AI providers so that user messages are not stored by those providers beyond what is needed to provide the session and operate the service.

4. Legal basis for processing

Under UK GDPR, we need a valid legal basis to process your personal data.

We rely on the following legal bases:

Contract

We process your data when it is necessary to deliver something you have bought or requested, such as PDF downloads, online courses, access to the habit tracker, or coaching services.

Legitimate interests

We process some data where we have a legitimate business reason, as long as this does not override your rights.

This includes website security, fraud prevention, product improvement, customer support, analytics, and understanding marketing performance.

Consent

We rely on consent for non-essential cookies and some marketing activity where consent is required.

You can withdraw consent at any time.

Legal obligation

We process and retain some purchase and accounting records because UK law requires us to do so.

5. How we use your data

We use your personal data to:

Process purchases and payments.

Create and manage user accounts.

Give access to purchased products.

Send transactional emails, such as receipts, login links, product access emails, and account messages.

Send marketing emails where allowed.

Provide coaching services and digital tools.

Provide AI coaching features where you choose to use them.

Keep accounts and the website secure.

Improve the website, products, and user experience.

Understand marketing performance.

Comply with legal, tax, and accounting duties.

6. Third parties we share data with

We use trusted third-party providers to run the website and deliver our services.

We only share the data needed for them to provide their services.

Stripe

Stripe processes payments.

We do not store card details on our servers. Stripe handles payment data directly.

Resend

Resend sends transactional and marketing emails.

Anthropic, OpenAI, and Google

These providers may process user messages for AI coaching features.

Google Analytics 4

Google Analytics 4 helps us understand website usage using anonymised analytics data where available.

Microsoft Clarity

Microsoft Clarity provides heatmaps and session recordings to help us improve the website.

Facebook / Meta

Meta tools help us measure ad performance and attribution through Facebook Pixel and Facebook Conversions API.

Replit

Replit hosts the website and related services.

7. International data transfers

Some of the third-party providers we use may process personal data outside the United Kingdom.

Where personal data is transferred internationally, we rely on appropriate safeguards where required by law.

These may include adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement, or the UK Addendum to the EU standard contractual clauses.

8. How long we keep your data

We only keep personal data for as long as needed.

Account data

We keep account data while your account is active.

If you ask us to close your account, we aim to delete account data within 30 days, unless we need to keep certain records for legal, tax, security, or accounting reasons.

Purchase records

We keep purchase records for 7 years for UK tax and accounting purposes.

Email marketing

We keep your email marketing data until you unsubscribe or ask us to remove you.

Analytics data

Analytics data is kept according to the default retention settings of each platform we use.

9. Your rights

Under UK GDPR, you have rights over your personal data.

You have the right to:

Access the personal data we hold about you.

Ask us to correct inaccurate or incomplete data.

Ask us to delete your personal data.

Ask us to restrict how we use your data.

Ask for a copy of your data in a portable format.

Object to certain types of processing.

Withdraw consent where we rely on consent.

If you are based outside the United Kingdom, you may also have additional rights under local privacy laws.

To exercise any of these rights, contact hello@thechaptersystem.com.

You also have the right to complain to the UK Information Commissioner's Office if you are unhappy with how we handle your data.

10. Cookies

We use cookies to keep the website working, remember your cookie choices, understand website usage, improve the user experience, and measure advertising performance.

Some cookies are essential. Others are optional and depend on your consent.

For full details, please read our Cookie Policy.

11. Changes to this policy

We may update this Privacy Policy from time to time.

If we make important changes, we may notify you by email or by placing a clear notice on the website.

12. How to contact us

If you have any questions about this Privacy Policy or how we use your data, contact us at:

hello@thechaptersystem.com