LAST UPDATED: 12 OCTOBER 2026
PRIVACY POLICY
BRTLS is built around understanding the individual father and the life around him.
That means some BRTLS services — particularly the Fatherhood Discovery and personalised Fatherhood Journey — depend on information you choose to provide about yourself, your circumstances and your experiences.
We recognise that this information can be personal.
This Privacy Policy explains what personal data BRTLS collects, why we use it, which service providers may process it, how long we keep it and what rights you have.
Our aim is simple:
Use personal information only where it has a clear purpose, protect it appropriately and be transparent about what happens to it.
WHO IS RESPONSIBLE
1. Who is responsible for your personal data?
The controller responsible for the processing described in this Privacy Policy is:
BRTLS
Sole proprietorship
Belfeld, Limburg
The Netherlands
Dutch Chamber of Commerce (KvK): 90495446
VAT ID: NL004820321B46
Email: info@brtls.store
For questions about privacy or to exercise your privacy rights, contact:
WHAT INFORMATION WE COLLECT
2. Information you provide to BRTLS
The personal data BRTLS processes depends on how you use our services.
This may include:
- your name;
- email address;
- account information;
- country or region;
- order and Fatherhood Journey information;
- Gift Card purchase or redemption information;
- communications with BRTLS;
- Fatherhood Discovery responses;
- Development Review and assessment responses;
- free-text responses you choose to provide;
- preferences and priorities;
- information about your experience of fatherhood and everyday life.
You do not have to provide information that is not required for the service you choose to use.
However, some personalised BRTLS functionality depends on the information you provide. If relevant information is unavailable, the resulting guidance may be more limited.
FATHERHOOD DISCOVERY
3. Information collected through the Fatherhood Discovery
The Fatherhood Discovery is designed to create a personalised picture based on information you provide.
Depending on your answers, Discovery data may relate to areas such as:
- yourself and your sense of identity;
- your partner or relationship;
- your children and family life;
- health, vitality, energy and wellbeing;
- work and responsibilities;
- home and everyday life;
- community and support;
- priorities and current difficulties;
- experiences of change or transition;
- what currently appears important to you;
- free-text reflections you choose to provide.
BRTLS processes these responses to provide the Fatherhood Discovery and generate personalised results.
Go to the Free Fatherhood Discovery
4. Where Discovery information is processed
BRTLS uses Octane AI to provide the Fatherhood Discovery.
Information you submit through the Discovery is processed through Octane AI.
Discovery data is also transferred to Klaviyo, together with relevant contact information such as your email address.
This allows BRTLS to maintain relevant profile information, provide permitted follow-up communications and, where applicable, connect your Discovery information with subsequent BRTLS experiences.
BRTLS remains responsible for determining why this information is processed and how it is used for BRTLS purposes.
5. Information about other people
Fatherhood naturally involves other people.
You may therefore mention a partner, child, family member, colleague or another person when describing your own situation.
Please avoid providing names or other directly identifying information about other people unless genuinely necessary.
For example, BRTLS generally does not need your child's full name in order to understand that you are experiencing difficulty around a particular family situation.
Where possible, describe the relationship or situation rather than identifying the other person.
FATHERHOOD JOURNEY
6. Fatherhood Journey information
If you purchase a BRTLS Fatherhood Journey, we may process information relating to:
- your BRTLS account;
- your purchase and selected Journey duration;
- your Journey activation and end dates;
- your Fatherhood Discovery;
- personalised BRTLS results;
- Development Reviews and assessments;
- information you provide during your Journey;
- relevant interactions with personalised BRTLS functionality;
- withdrawal and refund requests;
- service-related communications.
This information is used to provide and administer your purchased Journey and, where applicable, to keep personalised guidance relevant as your circumstances change.
The Fatherhood Journey is available for fixed periods of 90, 180 or 365 days.
A Journey does not automatically renew, and BRTLS does not process recurring subscription payments for the Journey.
Explore the Fatherhood Journey
7. Development Reviews and assessments
During a Fatherhood Journey, you may be invited to complete Development Reviews or assessments.
These may ask about matters such as:
- what has happened since your previous Review;
- changes in your circumstances;
- what you explored;
- what appeared to help or not help;
- how you currently experience relevant areas of your life;
- what may deserve attention next.
The information you provide may be used to update your BRTLS profile and personalised guidance.
You decide what information you provide, subject to any information necessary for a particular feature.
If relevant information is unavailable, some personalised functionality may become more limited or may not function as intended.
PERSONALISATION AND AI
8. How BRTLS uses personalisation
BRTLS does not aim to give every father the same predetermined programme.
Information from your Discovery and subsequent BRTLS interactions may therefore be used to determine which BRTLS information, reflections, guidance or communications are more relevant to you.
Personalisation may take account of:
- your Discovery responses;
- your current circumstances;
- Development Review information;
- previous BRTLS results;
- priorities or preferences you have provided;
- relevant BRTLS knowledge and methodology.
Personalisation is intended to support your BRTLS experience.
It is not intended to determine your worth, ability or quality as a father.
9. AI-supported functionality
BRTLS uses automated and AI-supported functionality, including functionality associated with Octane AI, to support aspects of the Fatherhood Discovery and personalisation.
Automated or AI-supported output may help generate, organise or personalise BRTLS content based on information you provide.
The current BRTLS approach does not involve intentionally sending your Discovery or Journey information to a separate third-party AI provider solely to generate personalised guidance.
If BRTLS introduces additional external AI providers or materially changes how personal information is processed for AI functionality, this Privacy Policy will be updated and additional information or consent will be provided where legally required.
AI-supported output is intended for personal development and reflection.
BRTLS does not use these systems to make solely automated decisions that produce legal effects concerning you or similarly significantly affect you, such as decisions about employment, insurance, credit or healthcare eligibility.
SENSITIVE INFORMATION
10. Health, wellbeing and other sensitive information
Some BRTLS questions concern everyday life, energy, vitality or wellbeing.
Depending on what you choose to disclose, your responses could contain information that qualifies as special-category personal data under the General Data Protection Regulation (GDPR), including information concerning health.
BRTLS does not need detailed medical information to provide its personal-development services.
Please do not provide medical records, diagnoses or other detailed health information unless BRTLS specifically requests information for a clearly explained purpose.
Where BRTLS intentionally processes special-category personal data, it must have both an appropriate legal basis under Article 6 GDPR and an applicable condition under Article 9 GDPR.
Where BRTLS relies on your explicit consent for such processing, you may withdraw that consent at any time.
Withdrawal does not affect processing lawfully carried out before your consent was withdrawn.
If the relevant information is necessary for a personalised feature, withdrawing consent may mean that BRTLS can no longer provide that feature in the same way.
ACCOUNTS, PURCHASES AND PAYMENTS
11. Shopify
BRTLS uses Shopify to operate its ecommerce website and manage customer accounts and purchases.
Depending on how you use BRTLS, Shopify may process information such as:
- name;
- email address;
- account information;
- order information;
- billing and transaction information;
- Gift Card purchase and redemption information;
- technical information associated with your use of the store.
BRTLS uses this information to operate the website, manage customer accounts, process purchases and administer its services.
12. Other Shopify applications
BRTLS may use Shopify applications to support specific functionality, including access management, order administration or digital product delivery.
Such applications may process customer, account, purchase or access-related information where necessary for their configured functions.
The providers that actually receive personal information depend on the applications enabled and the services they perform.
BRTLS aims to limit access to information reasonably necessary for each provider's function.
Where an application processes personal data on behalf of BRTLS, appropriate data-processing arrangements must be in place.
13. Payment information
Payment information is processed through the ecommerce and payment infrastructure used by BRTLS.
BRTLS may receive information confirming matters such as:
- whether a payment succeeded;
- amount paid;
- order number;
- transaction status;
- refund status;
- Gift Card redemption or balance information, where applicable.
BRTLS does not ask you to submit full payment-card details through the Fatherhood Discovery, Development Reviews, ordinary contact forms or email.
Please never send payment-card details to info@brtls.store.
KLAVIYO AND COMMUNICATIONS
14. Klaviyo
BRTLS uses Klaviyo for email communication, customer profiles, automated communication flows and personalisation.
Information transferred to Klaviyo may include:
- your email address;
- contact information;
- Fatherhood Discovery data;
- BRTLS profile properties;
- information relevant to your Fatherhood Journey;
- communication and engagement information.
At present, BRTLS transfers the data collected through the Fatherhood Discovery to Klaviyo.
This may include personal reflections and free-text responses provided through the Discovery.
BRTLS may change this architecture over time to limit information transferred to Klaviyo to information reasonably required for communication and personalisation.
15. Service communications
If you use BRTLS services, we may send communications needed to provide or administer them.
Examples include:
- Discovery-related communications;
- Fatherhood Journey information;
- Development Review invitations;
- purchase confirmations;
- account messages;
- withdrawal or refund confirmations;
- Gift Card delivery or purchase information;
- important service changes;
- security or operational messages.
Where these messages are necessary to provide or administer a service you requested, they are treated separately from optional general marketing communications.
16. Marketing communications
BRTLS may send marketing communications where permitted by law.
Where consent is required, BRTLS will request it.
You can unsubscribe from marketing communications using the unsubscribe option included in the relevant email.
Withdrawing from marketing does not necessarily stop essential service communications relating to an active BRTLS service.
BRTLS will not treat participation in the Fatherhood Discovery or purchase of a Fatherhood Journey as unrestricted permission to send marketing communications.
WHY WE PROCESS PERSONAL DATA
17. Our purposes and legal bases
BRTLS processes personal data only where an appropriate legal basis applies.
The applicable basis depends on the particular purpose and circumstances.
Performance of a contract
Where necessary to provide a service you requested or purchased, BRTLS may process information to:
- provide the Fatherhood Discovery and requested results;
- create and administer accounts;
- provide purchased Fatherhood Journey access;
- deliver contracted personalised functionality;
- administer payments and purchases;
- handle withdrawal and refund requests.
Steps requested before entering into a contract
BRTLS may process information where necessary to take steps you request before entering into a contract.
Consent
BRTLS relies on consent where appropriate, including certain optional communications or processing activities.
Where processing relies on consent, you may withdraw it for future processing.
Explicit consent
Where required for intentional processing of special-category personal data, BRTLS may request your explicit consent.
Legal obligation
BRTLS processes or retains information where necessary to comply with legal obligations, including relevant tax, accounting and consumer-law requirements.
Legitimate interests
Where legally appropriate, BRTLS may process information for legitimate interests such as:
- maintaining service security;
- preventing fraud or misuse;
- protecting BRTLS systems;
- resolving disputes;
- operating and improving the service.
BRTLS does not rely on legitimate interests where your interests, rights or freedoms override those interests.
The applicable legal basis must be established for each processing activity; the categories above do not mean that every basis applies to every use of your information.
SERVICE PROVIDERS
18. Who processes information for BRTLS?
BRTLS uses external technology providers to operate its services.
The principal providers identified in the current BRTLS setup include:
Shopify
Website, ecommerce, accounts and purchases.
May process customer, account, order and transaction information.
Octane AI
Fatherhood Discovery and related personalisation.
Processes Discovery responses, including free-text responses and associated profile or contact information.
Klaviyo
Email, customer profiles, communication flows and personalisation.
Processes contact information, Discovery data and relevant BRTLS profile information.
BRTLS may also use other enabled Shopify applications or payment providers for specific operational purposes.
These providers may use authorised subprocessors to deliver their services.
Where a provider processes personal data on behalf of BRTLS, the relationship must be governed by appropriate data-processing terms.
19. We do not sell your Discovery responses
BRTLS does not sell your Fatherhood Discovery responses, Development Review responses or other personalised BRTLS information to data brokers or advertisers.
We do not provide your private Discovery responses to unrelated companies so that they can independently target you with advertising based on those responses.
This does not prevent BRTLS from using the service providers described in this Policy where they process information for legitimate BRTLS purposes.
INTERNATIONAL PROCESSING
20. Transfers outside the European Economic Area
Some service providers or their subprocessors may process personal data outside the European Economic Area (EEA), including in the United States.
Where GDPR rules require safeguards for an international transfer, BRTLS and/or the relevant provider will use an appropriate transfer mechanism.
Depending on the provider and transfer, this may include:
- an applicable adequacy decision;
- the EU-U.S. Data Privacy Framework, where applicable;
- European Commission Standard Contractual Clauses;
- other safeguards permitted under the GDPR.
You may contact info@brtls.store to request information about safeguards relevant to your personal data.
RETENTION
21. How long we keep your information
BRTLS keeps personal data only for as long as necessary for the purpose for which it was collected, or as required by law.
The relevant period depends on the type of information.
Discovery and personalisation data
Discovery responses and related personalisation information may be retained while your BRTLS profile remains active and while the information remains relevant to providing requested services.
Fatherhood Journey and Development Review data
Journey-related personalised information may be retained during the purchased Journey and afterwards where necessary for account administration, legitimate follow-up purposes, handling requests, resolving disputes or complying with legal obligations.
Marketing information
Marketing information may be retained while BRTLS is legally permitted to use it for that purpose. Following an opt-out, limited information may be retained to ensure that the opt-out continues to be respected.
Transaction and administration records
Purchase, payment, tax and accounting information is retained for the applicable statutory retention period.
Support communications
Communications with BRTLS may be retained for as long as reasonably necessary to handle requests, maintain appropriate business records or resolve disputes.
When information is no longer required, BRTLS will delete or anonymise it where appropriate.
BRTLS will apply documented retention periods or criteria to its relevant systems and service providers.
WEBSITE DATA AND COOKIES
22. Technical information
When you use brtls.store, certain technical information may be processed automatically.
This can include:
- IP address;
- browser and device information;
- operating system;
- pages viewed;
- referring pages;
- timestamps;
- website interactions;
- cookie or similar identifiers.
Some processing is necessary for the website to operate and remain secure.
Other technologies, including certain analytics or advertising technologies, may require your consent.
23. Cookies
BRTLS uses cookies and similar technologies for purposes that may include:
- essential website functionality;
- account and checkout functionality;
- security;
- remembering preferences;
- analytics;
- measuring website performance;
- marketing, where applicable and permitted.
Where consent is legally required for non-essential cookies or similar technologies, BRTLS will request that consent before using them.
You can find more information in the BRTLS Cookie Policy.
YOUR PRIVACY RIGHTS
24. Your rights under the GDPR
Subject to the conditions provided by law, you may have the right to:
- access personal data BRTLS holds about you;
- correct inaccurate personal data;
- have incomplete information completed;
- request deletion of personal data;
- request restriction of processing;
- object to certain processing;
- receive certain personal data in a portable format;
- withdraw consent where processing relies on consent;
- receive relevant information about automated processing;
- lodge a complaint with a supervisory authority.
Not every right applies in every circumstance.
For example, BRTLS may be legally required to retain certain transaction records even after you request deletion of your account.
25. How to exercise your rights
To exercise a privacy right, contact:
Please explain what you are requesting and, where possible, use the email address associated with your BRTLS account.
We may ask for reasonable information to verify your identity before providing, changing or deleting personal information.
This helps prevent someone else from obtaining or deleting your data without authorisation.
We will respond within the period required by applicable data-protection law, normally within one month, subject to any lawful extension.
26. Withdrawing consent
Where BRTLS relies on your consent, you may withdraw that consent at any time.
Withdrawal applies to future processing.
It does not make processing lawfully carried out before withdrawal unlawful.
Depending on the consent withdrawn, a particular optional or personalised BRTLS feature may no longer be available.
Marketing consent can normally be withdrawn directly through the unsubscribe controls in the relevant communication.
For other consent-related requests, contact:
CHILDREN AND FAMILY INFORMATION
27. BRTLS is for adults
The Fatherhood Discovery and paid Fatherhood Journey are intended for adults aged 18 or older.
BRTLS is not designed for children to create their own Journey accounts or independently complete the Fatherhood Discovery.
Because BRTLS is about fatherhood, fathers may naturally provide information about their children when describing their own circumstances.
We ask you to minimise identifying information about children.
Unless genuinely necessary, please do not provide:
- children's full names;
- contact details;
- school names;
- exact addresses;
- medical records;
- other unnecessary identifying information.
Usually, information such as “my five-year-old daughter” or “my youngest child” is sufficient for BRTLS to understand the context.
SECURITY
28. How we protect information
BRTLS takes appropriate technical and organisational measures designed to protect personal information against:
- unauthorised access;
- loss;
- misuse;
- inappropriate disclosure;
- alteration;
- destruction.
BRTLS also selects technology providers with security and data-protection controls appropriate to their role.
No internet-based system can guarantee absolute security.
You are responsible for keeping your own BRTLS login credentials confidential and should contact us if you believe someone has gained unauthorised access to your account.
YOUR CHOICES
29. You remain in control of what you share
Personalisation does not mean you should provide every detail of your life.
We encourage you to provide information at the level reasonably needed for BRTLS to understand your situation.
In particular:
You do not need to identify other people unnecessarily.
You do not need to provide detailed medical information.
You may choose not to answer information you do not wish to share, although this may limit certain personalised functionality.
Where a particular response is required to complete a feature, BRTLS should make that requirement clear.
COMPLAINTS
30. Privacy concerns
If you have a question or concern about how BRTLS handles your personal information, please contact us:
We will investigate your concern.
You also have the right to lodge a complaint with the Dutch supervisory authority:
You may also have the right to contact the competent supervisory authority in the EU Member State where you live or work.
CHANGES TO THIS POLICY
31. Updates to this Privacy Policy
BRTLS may update this Privacy Policy as its services, technology, providers or legal obligations change.
The current version will be published on brtls.store, and the date at the top of this Policy will show when it was last updated.
Where a change materially affects how BRTLS uses your personal data, we will provide additional information or request new consent where required by law.
CONTACT
32. Contact BRTLS about privacy
For questions about this Privacy Policy, the personal information BRTLS holds about you or your privacy rights:
BRTLS
Sole proprietorship
Belfeld, Limburg
The Netherlands
KvK: 90495446
VAT ID: NL004820321B46
Email: info@brtls.store
Related BRTLS policies
Cookie Policy — Learn how BRTLS uses cookies and similar technologies.
Terms & Conditions — General terms for using BRTLS and its services.
Fatherhood Journey Terms — Terms specifically applicable to the Fatherhood Journey.
Disclaimer — Understand the scope and boundaries of BRTLS guidance.
Legal Information — View all BRTLS legal information in one place.