Privacy Policy

1. Introduction

Welcome. This Privacy Policy outlines how Sustainable Momentum AS ("I", "we", "my", "our") collects, uses, stores, and protects your information when you visit my website, kjartanrumpsfeld.com ("Site"), and engage in my coaching services ("Services"). Your privacy is of the utmost importance to me, and this policy is designed to be transparent about my practices.

2. Who I Am

My website address is: https://www.kjartanrumpsfeld.com. The legal entity and data controller responsible for your information is Sustainable Momentum AS, a Norwegian limited liability company operated by Kjartan Rumpsfeld.

3. What Information I Collect

I collect information in the following ways.

4. How I Use Your Information

I use your information for the following purposes:

• To provide, operate, and maintain my coaching Services.
• To assess your application and determine if we are a good fit to work together.
• To communicate with you, including scheduling our sessions and sending you follow-up materials.
• To provide personalized consultation through the AI widget, helping you understand how the intensive work applies specifically to your circumstances and challenges.
• To create session summaries and training maps, potentially with the assistance of AI-powered tools, to support your journey.
• To process payments through manual or automatic invoicing.
• To Send Marketing Communications: I may use your email address to send you occasional newsletters, updates, or information about new services. You may opt-out of these communications at any time by clicking the "unsubscribe" link or by contacting me directly.
• To improve my Site and Services.

5. How I Share Your Information

I do not sell your personal information. Your information is shared only with trusted third-party service providers as necessary to provide my Services to you:

• Google Drive: To confidentially store session recordings, transcripts, and summaries for your access.
• Email & Calendar Providers: To communicate with you and schedule our appointments.
• AI Consultation Services: Consultation widget conversations are processed through Google's paid Gemini API solely to generate personalized insights. This tier is covered by the Google Cloud Data Processing Addendum and Google does not use prompts or responses to train its models. For detailed information about AI agent ownership, data rights, and usage terms, please refer to Section 8 of our Terms of Service.
• AI Tools: To assist in the creation of session summaries, as set out in Section 6 below.

In full, the providers that may receive your information, what each one receives, and how long it is held:

Contractual status, stated plainly: The Gemini API behind the website widget is covered by the Google Cloud Data Processing Addendum. The Claude account used for summaries and the Google Drive used for storage are consumer services: model training is switched off and no training takes place, but they are not covered by a separate data processing agreement. This is disclosed here rather than left implied, and it is under active review.

6. Recording, Transcription, and AI Summaries

Recording is optional: Sessions are not recorded by default, and you are never required to consent to recording, transcription, or AI-assisted summaries in order to work with me. These are supportive tools, offered for your benefit. If you decline, the work proceeds exactly as it otherwise would.

Where you do consent, this is the path a session takes:

• Recording: Audio and video are recorded locally, on my own device. They are never uploaded to Zoom's cloud.
• Transcription: Zoom AI Companion produces a written transcript. It is held in Zoom's cloud for no more than 7 days, and ordinarily deleted as soon as it has been downloaded. Zoom's terms prohibit the use of customer content to train Zoom or any third-party AI model.
• Summarisation: The transcript is used to produce a session summary with Anthropic's Claude, on an account where model training has been switched off.
• Storage: The summary — and, at your request, a copy of the transcript, audio, and video — is placed in a private Google Drive folder accessible only to you and me.

No anonymisation before summarisation: The transcript is used as recorded; identifying details are not stripped out first. This is precisely why the chain above is limited to providers that do not train on the content passing through it.

Withdrawing consent: You may withdraw consent at any time, ask for any recording, transcript, or summary to be deleted, and continue the work without recording. Email support@kjartanrumpsfeld.com.

7. Data Storage, Security, and Retention

• Recordings and Transcripts: Audio and video are held locally rather than in any cloud. Transcripts are removed from Zoom's cloud within 7 days, and ordinarily as soon as they have been downloaded. Material placed in your private Google Drive folder remains for the duration of our work together and is deleted on request.
• Security: I take reasonable measures to protect your personal information from unauthorized access, use, or disclosure. All consultation widget data is encrypted in transit and at rest, with access restricted to authorized systems only.
• Agent Services Data Retention: Personal conversation data from AI agent services can be deleted upon your request or service termination. To request deletion of all your conversation history and prevent future use of your data, email support@kjartanrumpsfeld.com with the subject line "Opt-Out". Aggregated insights that have been incorporated into service improvements remain part of our knowledge base and cannot be extracted or reversed.
• General Retention: I retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, primarily for the duration of our coaching container. Session recordings and materials stored in your dedicated Google Drive folder can be deleted upon the completion of our work together, as per your request.

8. Your Data Rights

You have rights concerning your personal data. Depending on your location, these may include:

• The right to access a copy of the personal data I hold about you.
• The right to rectification to have any inaccurate personal data corrected.
• The right to erasure to have your personal data deleted.
• The right to restrict processing of your personal data in the future.

To exercise any of these rights, please contact me at support@kjartanrumpsfeld.com.

9. Use of Cookies

A cookie is a small file that a website stores on a visitor's computer to remember certain information. My Site may use essential cookies to help identify and track visitors, understand their usage of the Site, and improve the user experience. You can set your browser to refuse cookies, but note that some parts of the Site may not function properly without them.

10. Changes to This Privacy Policy

I may update this Privacy Policy from time to time. I will notify you of any changes by posting the new policy on this page and updating the "Last Updated" date at the top.

11. Contact Me

If you have any questions about this Privacy Policy, please contact me at: support@kjartanrumpsfeld.com.