Privacy Policy — O!Sapiens
Legal & Data Protection

Privacy Policy

Last updated: 22 June 2026  ·  Effective from: 22 June 2026  ·  hi@osapiens.expert
01

Who we are

One Species Limited is the data controller responsible for your personal data. We operate the O!Sapiens brand, the SapiensOS HealthSpan platform, and the osapiens.expert website and tools.

DetailInformation
Legal entityOne Species Limited
Registered jurisdictionCyprus (EU member state)
Primary contacthi@osapiens.expert
Websiteosapiens.expert
Supervisory authorityOffice of the Commissioner for Personal Data Protection, Cyprus

As a Cyprus-registered entity, we are subject to the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Cyprus Personal Data Protection Law 125(I)/2018, which transposed the GDPR into national law.

02

What data we collect and why

We collect data through two primary touchpoints: the Inner OS Assessment tool and 1-on-1 coaching sessions. Below is a plain-language summary of each category.

Assessment data (self-reported wellbeing)

When you complete the Inner OS Assessment at osapiens.expert, you answer 10 questions about your current state across the Sapiens OS pillars — Sleep, Nutrition, Movement, Stress Regulation, Social Connection, Light & Darkness, Agency, Meaning, Rest, and Curiosity. Your answers produce a numerical score for each pillar (0–100).

We also collect the following choices you make during the assessment:

  • Your three lowest-scoring pillars (focus areas)
  • Your chosen implementation pace (Minimum / Standard / Deep)
  • Your preferred support type (implementation sequence or 1:1 session)
  • Your planned implementation time and predicted friction point
  • A randomly generated session identifier (no link to your identity unless you submit your email)
This is educational self-reflection data, not medical information. The assessment is a coaching and educational tool. It is not a diagnostic instrument, and we do not use it to make inferences about clinical health conditions. However, because it relates to your personal wellbeing and lifestyle, we treat it with the heightened care required for health-adjacent data under GDPR Article 9.

Contact and identity data

If you choose to submit your email address, we collect your first name (optional) and email address. Submission is always voluntary — you may view a summary of your assessment results without providing contact details.

Generated data

When you submit your email, we generate a personalised spider graph image of your pillar scores using a third-party charting service (QuickChart.io). The chart URL is stored on your contact record in our email platform so we can include it in your follow-up email.

Coaching session data

If you book a 1-on-1 coaching session via Google Calendar, Google collects your name, email, and the details you provide when booking. During the session, the coach (Vladislav Andreev) may take notes. These notes are held by the coach and are not processed by automated systems.

Technical data

Our website is hosted on Netlify. Standard server logs may include your IP address, browser type, and page URLs for security and performance purposes. We do not use these logs for profiling or marketing.

03

Legal basis for processing

We rely on the following legal bases under GDPR Article 6 (and Article 9 for health-adjacent data — see Section 4):

Activity Legal basis Detail
Processing assessment scores and submitting to our systems Explicit consent (Art. 6(1)(a) + Art. 9(2)(a)) You check a consent box before submitting. Consent is granular, freely given, and recorded.
Sending your protocol and personalised follow-up emails Consent (Art. 6(1)(a)) Covered by the same consent box. You can unsubscribe at any time via the link in every email.
Delivering 1-on-1 coaching Contract (Art. 6(1)(b)) Processing is necessary to deliver the service you have engaged us for.
Anonymised assessment research (no email link) Legitimate interests (Art. 6(1)(f)) Aggregated, anonymised score data (session ID only, no name or email) is used to improve our framework. This data cannot identify you and carries minimal privacy risk.
Security and server logs Legitimate interests (Art. 6(1)(f)) Necessary to maintain the security and integrity of our services.

Where we rely on legitimate interests, we have assessed that our interest does not override your fundamental rights and freedoms. You may object to legitimate-interest processing at any time (see Section 8).

04

Health and wellbeing data (Article 9)

GDPR Article 9 places stricter rules on the processing of certain "special categories" of personal data, including data concerning health. Our assessment asks about sleep quality, stress levels, energy, and other wellbeing indicators. While our service is educational coaching — not clinical healthcare — we treat this data as health-adjacent and apply Article 9 safeguards as a matter of principle.

Our explicit consent mechanism: Before submitting your assessment data and email, you are required to check a clearly worded consent box confirming: "I consent to O!Sapiens processing my self-reported wellbeing responses to generate and send my personal protocol. This is educational content, not medical advice." This satisfies the requirement for explicit consent under Article 9(2)(a).

What we do not do

  • We do not make clinical diagnoses or inferences about specific health conditions.
  • We do not share your health-adjacent data with insurers, employers, or any third party for purposes beyond service delivery.
  • We do not use your data to train AI models or sell it to data brokers.
  • We do not use automated decision-making that produces legal or similarly significant effects on you (Article 22).

Withdrawing consent

You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. To withdraw, email us at hi@osapiens.expert and we will delete your personal data from our systems within 30 days.

05

Third-party processors

We use a small number of carefully selected third-party services to operate our platform. Each is engaged as a data processor under a written agreement (Data Processing Agreement or equivalent) and may only process your data as we instruct.

Processor Role Data shared Location
Brevo (Sendinblue) Email marketing and contact management Name, email, consent record, assessment attributes (scores, focus pillars, support preference, commitment level, keystone practice) EU (Paris, France)
Google LLC Apps Script (server-side relay), Google Sheets (research log), Google Calendar (session booking) Assessment scores, session ID, email (relay only — not stored in Sheets), booking details US (see Section 6)
QuickChart.io Spider graph image generation Pillar scores (sent as chart parameters in a URL — no name or email transmitted) US (see Section 6)
Netlify, Inc. Website hosting Standard server logs (IP address, page URLs) US (see Section 6)
Stripe, Inc. Payment processing (coaching sessions) Payment details (card number is never seen by O!Sapiens — Stripe is the processor) US (see Section 6)

We do not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes.

06

International data transfers

Some of our processors are based in the United States, which is outside the European Economic Area (EEA). The EU has not issued an adequacy decision for the US as a whole, which means we must put in place appropriate safeguards before transferring personal data there.

For transfers to US-based processors, we rely on one or more of the following mechanisms:

  • Standard Contractual Clauses (SCCs) — the European Commission's approved model clauses that create binding obligations on the recipient to protect your data to EU standards. Google, Netlify, Stripe, and QuickChart are covered by SCCs.
  • EU–US Data Privacy Framework — where the processor is certified under this framework (Google LLC is certified).

You may request a copy of the relevant transfer safeguards by contacting us at hi@osapiens.expert.

07

How long we keep your data

Data type Retention period Reason
Email address and name Until you unsubscribe or request deletion Required to deliver the service you have subscribed to
Assessment attributes in Brevo (scores, focus pillars, preferences) Linked to your contact record — deleted when your contact is deleted Personalisation of communications
Anonymised research log (Google Sheets — session ID + scores, no email) Up to 3 years, then reviewed for deletion Framework improvement and pattern analysis
Coaching session notes Duration of coaching relationship + 1 year Continuity of care; deleted on request
Payment records 7 years Legal obligation (accounting and tax law)
Server logs (Netlify) 30 days Security monitoring — standard log rotation

When data reaches the end of its retention period, it is deleted or anonymised so it can no longer be linked to you. You may also request early deletion at any time (see Section 8).

08

Your rights under GDPR

As a data subject under the GDPR, you have the following rights. These rights apply to all personal data we hold about you as a data controller.

Right of access (Art. 15)

You may request a copy of all personal data we hold about you, together with information about how we use it.

Right to rectification (Art. 16)

You may ask us to correct inaccurate data or complete incomplete data we hold about you.

Right to erasure (Art. 17)

You may ask us to delete your personal data. We will comply unless we are required by law to retain it.

Right to restrict processing (Art. 18)

You may ask us to pause processing of your data while a dispute about accuracy or lawfulness is resolved.

Right to data portability (Art. 20)

Where processing is based on consent or contract, you may receive your data in a machine-readable format.

Right to object (Art. 21)

You may object to processing based on legitimate interests at any time. We must stop unless we have compelling grounds to continue.

Right to withdraw consent

You may withdraw consent at any time. This does not affect the lawfulness of processing before withdrawal.

Right not to be subject to automated decisions (Art. 22)

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

How to exercise your rights

Email us at hi@osapiens.expert with the subject line "GDPR Request" and describe your request. We will respond within 30 days. We may need to verify your identity before acting on a request.

Exercising your rights is always free of charge. In exceptional cases where requests are manifestly unfounded or repetitive, we may charge a reasonable administrative fee or decline to act — we will notify you if this applies.

09

Cookies and tracking

The Inner OS Assessment tool is a single-file HTML application that runs entirely in your browser. It does not set cookies, and it does not use third-party analytics or tracking pixels.

The main osapiens.expert website may use cookies for basic functionality (such as remembering your language preference). We do not currently use advertising cookies, retargeting pixels, or behavioural tracking services such as Google Analytics.

If we introduce any cookies beyond strictly necessary functionality in future, we will update this policy and present an appropriate consent mechanism before placing them.

10

Children's data

Our services are directed at adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. The Inner OS Assessment is designed for senior professionals and adults engaged in personal development.

If we become aware that we have inadvertently collected data from a minor, we will delete it promptly. If you believe a minor has submitted data to us, please contact us at hi@osapiens.expert.

11

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you directly by email.

We encourage you to review this policy periodically. Your continued use of our services after a material update constitutes acceptance of the revised policy, unless we are required by law to obtain fresh consent.

12

How to contact us or complain

Get in touch

For any question about how we use your data, to exercise a right, or to raise a concern, contact us directly first. We aim to respond within 30 days and to resolve concerns informally wherever possible.

Subject line for data requests GDPR Request
Data controller One Species Limited, Cyprus

Right to complain to a supervisory authority

If you are not satisfied with our response, you have the right to lodge a complaint with a data protection supervisory authority. You may contact the authority in the EU member state where you live, work, or where the alleged infringement took place.

Authority Jurisdiction Contact
Office of the Commissioner for Personal Data Protection Cyprus (our registered jurisdiction) dataprotection.gov.cy
Agencia Española de Protección de Datos (AEPD) Spain (where our operations are based) aepd.es

You may also contact the supervisory authority in your own country if you reside in a different EU/EEA member state.