Privacy Policy | Leaders Performance

Data Controller Identification

This Privacy Policy governs the processing of personal data collected through the website and services of:

LEADERS PERFORMANCE MANAGEMENT CONSULTANCIES L.L.C

Department of Economy and Tourism Licence No: 1119124 (Dubai Mainland)
Registered Office: I Rise Tower, Office 17 C12, Barsha Heights, Dubai, United Arab Emirates
Privacy Contact: info@leadersperformance.ae

This Privacy Policy is designed to support compliance with UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (“UAE PDPL”) and other applicable data-protection requirements.

Information Storage & Transmission

When you submit information through this website, it is transmitted using encryption in transit and processed through our authorised website, CRM, hosting, database and communication service providers.

Access is restricted to authorised personnel and service providers that require access to perform their contracted services under appropriate confidentiality obligations.

Information Collected & How It Is Used

1. Founder Pressure Scan

When you voluntarily complete our diagnostic assessment, we collect: Founder full name, company name, work email address, telephone/WhatsApp contact number, annual revenue band, and diagnostic questionnaire answers.

PROCESSING AND HUMAN REVIEW

Certain questionnaire responses may be processed automatically to generate directional indicators and support the internal review process.

These indicators do not constitute a validated diagnosis, final evaluation, advisory recommendation, qualification or commercial decision. Each completed submission is reviewed by Lionel Eersteling or an authorised member of Leaders Performance before any personalised result, recommendation or invitation for a conversation is issued.

Submission and review information may be recorded in our customer relationship management system for application administration, communication and follow-up in accordance with this Privacy Policy.

2. Strategic Conversation & Contact Enquiries

When you submit a contact enquiry via our website, we collect your full name, company, leadership role, work email, phone number, strategic objectives or discussion notes, and preferred communication channel. This data is transmitted to our CRM and authorised members of Leaders Performance strictly to review your enquiry, verify mutual fit, and coordinate subsequent communications.

3. Calendar Appointment Scheduling

When you book a strategic conversation or service-related consultation, booking details (name, email, preferred date and time) are managed through our scheduling infrastructure powered by GoHighLevel (GHL). This data is processed exclusively to manage calendar availability, issue invitations, and deliver meeting reminders.

4. UNMASKED PRIVATE Applications

When you apply for UNMASKED PRIVATE, we may collect:

your full name, work email address and mobile or WhatsApp number;
your company name, corporate website, role or title, and city and country;
information about the business result or challenge you want to address, why it requires attention now, your intended 90-day outcome and any previous attempts;
your responses concerning decision-making authority, openness to challenge, ability to act and availability for a confidential conversation;
your selected investment-readiness range.

How we use this information:

We use this information to:

review your application;
assess whether UNMASKED PRIVATE may be relevant to your situation;
determine the appropriate next step;
contact you regarding your application;
arrange a confidential conversation where appropriate;
maintain application and communication records;
protect the security and integrity of our application process.

Routing and human review:

Certain responses, including the selected investment-readiness range, may be used to route you to an appropriate next step or display an initial application outcome.

This routing does not constitute a final decision about your suitability for UNMASKED PRIVATE. Final qualification and strategic-fit decisions are made through human review by Lionel Eersteling or an authorised member of Leaders Performance.

Where applicable, you may request human review of an outcome produced through automated routing.

CRM processing:

Application information is processed through our customer relationship management provider, HighLevel, acting as a service provider on our behalf.

Further information about our service providers, international data transfers, retention periods, security measures and your data-protection rights is provided in the relevant sections of this Privacy Policy.

5. The Founder’s Next Move (Executive Masterclass & Participant Worksheet)

When you register for, access, or participate in The Founder’s Next Move Masterclass—structured as four video modules with an accompanying interactive participant worksheet, followed by a private 1-on-1 strategic review—we collect personal information directly from you:

Full Name: to identify the participant, personalize course materials, and prepare for the one-on-one strategic review session;
Work Email Address: to authenticate portal access, send purchase and enrollment confirmations, verify active access status, and deliver course materials;
Company Name and Role / Title: to understand business context, company scale, and operational dynamics;
Referral Source (“How did you hear about us?”): to capture acquisition channels (such as LinkedIn, YouTube, peer referral, organic search, or custom input);
Traffic Attribution & Routing Data: technical referral sources, UTM tracking parameters (including source, medium, campaign), and entry route identifiers to evaluate channel effectiveness;
Interactive Participant Worksheet Submissions: confidential responses, notes, reflection answers, and strategic priorities entered across the four video modules: Stage 1: Define the Next Stage, Stage 2: Success Changes the Game, Stage 3: Prepare for Performance, and Stage 4: Your Next Move;
Transaction & Payment Verification: payment confirmation tokens, transaction identifiers, and order status managed securely through Stripe. Leaders Performance utilizes Stripe Hosted Checkout; raw payment card numbers, CVVs, and expiry dates are transmitted directly to Stripe’s PCI-DSS Level 1 secure servers and never touch, pass through, or get stored on Leaders Performance servers or databases.

How We Use This Information:

Provisioning, authenticating, and maintaining your access to the four video modules and digital participant worksheet;
Saving and persisting your learning progress and worksheet entries across browser sessions;
Structuring and conducting the private 45-minute one-to-one strategic review session with Lionel Eersteling based on your submitted worksheet responses;
Compiling and generating your downloadable executive PDF dossier, which is provided as an integral part of your participant learning journey upon worksheet submission;
Managing fiscal transactions, statutory invoicing, and order records;
Maintaining administrative communication and participant support.

Processing, Infrastructure & Confidentiality:

Participant records, profile details, and interactive worksheet inputs are securely stored across our dual-tier technical infrastructure: our primary relational database (Supabase PostgreSQL hosted on dedicated AWS infrastructure with AES-256 encryption at rest) and our client relationship management platform (HighLevel / GoHighLevel) to facilitate session delivery, administrative notifications, and consultative preparation under strict contractual confidentiality obligations. Personal reflections, strategic challenges, and notes shared within the worksheet and during the 1-on-1 strategic review are treated as confidential executive work product and are never marketed, sold, leased, or disclosed to unauthorized third parties.

6. Newsletters & Requested Communications

When you subscribe to The Founder Performance Newsletter or request strategic briefings, we collect your email address and optional first name along with an explicit record of your consent and timestamp.

Subscription records and consent status are securely maintained in our Supabase PostgreSQL database as the primary source of truth, with contact synchronization to our CRM (HighLevel) for communication delivery. You may withdraw consent and unsubscribe at any time using the secure, cryptographic token-based link included in every newsletter email or through our dedicated unsubscribe portal. Upon unsubscribing, your record is maintained as an inactive suppression record to guarantee that no future communications are transmitted without renewed explicit consent.

Service Providers & International Data Transfers

Leaders Performance engages trusted third-party service providers (data processors) strictly on an operational need-to-know basis as required to deliver our educational programs, secure our digital infrastructure, and fulfill statutory obligations. We do not sell, rent, lease, or monetize participant personal data under any circumstances.

Participant data is shared with the named service providers below only under executed, legally binding Data Processing Agreements (DPAs) that incorporate strict confidentiality covenants, prohibit the provider from using participant data for their own independent commercial purposes or machine learning training, and mandate comprehensive security safeguards:

Payment Processing & Transaction Tokenization (Stripe): Stripe Payments Europe, Ltd. and Stripe, Inc. process transaction tokenization and payment settlements on infrastructure located in Ireland and the United States. Participant card data is captured directly via Stripe Hosted Checkout under certified PCI-DSS Level 1 compliance. Leaders Performance never accesses, processes, or stores raw payment card numbers.
Customer Relationship Management & Scheduling (HighLevel): HighLevel (GoHighLevel) provides contact management, consultative application routing, transactional email notifications, and calendar scheduling for the 45-minute strategic review. Infrastructure is hosted in the United States and operated under formal Data Processing Agreements with strict administrative access controls.
Database & Application Infrastructure (Supabase): Supabase, Inc. provides hosted PostgreSQL database storage and secure session authentication. Hosted within dedicated enterprise cloud facilities (AWS), database clusters enforce Row-Level Security (RLS) policies, multi-factor administrative authentication, and AES-256 encryption at rest.
Cloud Edge Delivery & Web Security (Cloudflare): Cloudflare, Inc. provides global edge content delivery, DNS resolution, DDoS mitigation, Web Application Firewall (WAF) filtering, and TLS 1.2/1.3 cryptographic protection in transit.
Consent-Gated Analytics (Google & Microsoft): Google Analytics (GA4) and Microsoft Clarity provide aggregated site usage statistics and UX heatmaps. These tracking scripts are strictly blocked from loading until affirmative consent is provided via our Cookie Banner.

International Transfer Safeguards & Technical Security (UAE PDPL Articles 22 & 23):

Where personal data is transferred to or accessed by service providers outside the United Arab Emirates (including the United States and the European Union), Leaders Performance ensures that appropriate legal safeguards are implemented in compliance with UAE Federal Decree-Law No. 45 of 2021. In alignment with our actual provider agreements and architecture, these safeguards comprise: (i) standard contractual clauses (SCCs) and binding data processing agreements containing enforceable non-disclosure and processing restrictions; (ii) end-to-end transport layer encryption (TLS 1.2 / TLS 1.3) and AES-256 storage encryption at rest; (iii) database Row-Level Security (RLS) isolating participant datasets; and (iv) strict multi-factor authentication (MFA) restricting administrative access solely to authorized personnel.

Retention Periods & Technical Security

Specific Data Retention Periods & Disposal Rules

Personal data is retained only for as long as necessary to fulfill the specific operational purposes for which it was collected, supported by defined retention cycles and secure disposal protocols:

Masterclass Course & Participant Worksheet Data24 Months / Active Duration

Purpose: Provisioning access to the four video modules, maintaining workbook persistence across sessions, generating the executive PDF dossier, and conducting the private 1-on-1 strategic review with Lionel Eersteling.

Retention & Deletion: Retained for the duration of the participant’s active engagement and up to twenty-four (24) months following completion or last activity for continuity. Upon expiry of this 24-month period (or earlier upon a valid, verified erasure request under UAE PDPL Article 15), personal identifying information and individual workbook submissions are permanently deleted from active database storage (Supabase / HighLevel) or irreversibly anonymized for pedagogical benchmarking where retention is not required by law.

Commercial Accounting & Financial Records5 Years (Statutory)

Legal Basis: Article 26 of UAE Federal Decree-Law No. 32 of 2021 on Commercial Companies (mandating the retention of commercial books and accounting records for a minimum period of five years from the end of the financial year).

Covered Records: General accounting journals, general ledgers, commercial invoices, billing receipts, supplier payment vouchers, bank reconciliation records, balance sheets, profit and loss statements, audited annual financial statements, and underlying accounting vouchers.

Segregation & Disposal: Fiscal records are strictly segregated from participant workbook responses, strategic notes, and diagnostic submissions. Following the expiration of the statutory five-year period, these records are securely and permanently purged.

Corporate Tax & Value Added Tax (VAT) Records7 Years (Statutory)

Legal Basis: Article 56 of UAE Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, read in conjunction with Article 78 of UAE Federal Decree-Law No. 28 of 2022 on Tax Procedures and Cabinet Decision No. 74 of 2023 on the Executive Regulation.

Covered Records: Corporate Tax returns and filings, Value Added Tax (VAT) returns, formal tax invoices and credit notes, taxable income calculation workpapers, transfer pricing documentation (where applicable), records of exempt and taxable revenues, and all supporting audit trail documentation verifying taxable income, deductions, or relevant to ongoing tax disputes/audits for seven (7) years following the end of the tax period to which they relate.

Disposal: Upon the expiration of seven years and resolution of any open tax audit or statutory dispute, tax documentation is securely incinerated or digitally shredded in compliance with our data disposal policies.

Founder Pressure Scan Submissions: Retained for internal review and consultative follow-up for up to 24 months, after which records are securely deleted or anonymized unless an active advisory engagement ensues.
UNMASKED PRIVATE Applications: Retained for application evaluation and administrative records for up to 24 months from submission.
Contact Enquiries & Calendar Bookings: Retained for up to 24 months to support administrative coordination and follow-up.
Newsletter Subscriptions: Retained for the duration of active subscription; upon unsubscribing, email details are placed on an inactive suppression list to prevent future mailings.
Analytics Data: Aggregated analytics metrics retained in Google Analytics and Microsoft Clarity for up to 14 months.

Technical & Organisational Security Measures

We and our service providers apply risk-appropriate technical and organisational safeguards, including encryption in transit (TLS 1.2 or higher) and at rest (AES-256), principle-of-least-privilege access controls, cryptographic tokens, multi-factor administrative authentication, continuous logging, backups, and regular vulnerability assessments.

Consent-Gated Analytics & Telemetry

We enforce consent-gated telemetry. No analytics tracking scripts are loaded or executed until you explicitly grant affirmative consent via our Cookie Banner:

Google Analytics (GA4): Aggregated usage metrics, traffic referral channels, and page views.
Microsoft Clarity: Aggregated interaction patterns, click heatmaps, and session UX metrics.

You may modify or withdraw your analytics consent at any time via the Cookie Settings link available in the website footer or on our Cookie Policy page.

Legal Grounds for Processing

Depending on the processing activity and applicable law, we process personal data with your consent, at your request before entering into an agreement, to perform or administer an agreement, to comply with legal obligations, to protect our systems and legal rights, or in other circumstances permitted by applicable law:

Steps Requested Before an Agreement

Processing contact enquiries, diagnostic reviews, and consultation requests to assess mutual fit prior to entering an agreement or service.

Voluntary Requested Assessment

Processing diagnostic responses to compile the preliminary business overview requested by the applicant.

Affirmative Consent

Applied where explicit consent is provided, such as newsletter subscriptions and optional analytics performance cookies.

Legal Compliance & Rights Protection

Processing required to comply with statutory accounting obligations, defend legal claims, and protect system security as permitted by applicable law.

Data Subject Rights & Human Review Requests

In accordance with applicable data protection laws, including UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (“UAE PDPL”), individuals hold statutory rights regarding the collection, processing, and transfer of their personal data:

Right of Access & Confirmation (Article 13): Request confirmation of whether your personal data is being processed, access to that data, and information on processing purposes, categories, and international recipients.
Right to Data Portability (Article 14): Receive your personal data in a structured, machine-readable format and request transmission directly to another controller where technically feasible.
Right to Correction or Erasure (Article 15): Request the updating, rectification, completion, or permanent erasure of inaccurate, outdated, or unnecessary personal data, except where continued retention is mandated by statutory UAE commercial accounting or corporate tax laws.
Right to Restrict Processing (Article 16): Require the limitation of data processing under specific conditions, such as while data accuracy or legal grounds are being verified.
Right to Object or Request Cessation (Article 17): Object to processing where data is processed for direct marketing, profiling, or where processing causes disproportionate prejudice.
Right to Human Review (Article 18): Contest any automated scoring, screening, or routing outcome (including diagnostic indicators or application routing) and require human assessment by Lionel Eersteling or an authorized representative.
Right to Withdraw Consent (Article 5): Withdraw previously granted consent (such as newsletter subscriptions or telemetry cookies) at any time, with immediate effect and without penalty.
Right to Lodge a Complaint: Lodge a formal grievance with the competent supervisory authority, the UAE Data Office, if you believe your personal data rights have been infringed.

Method for Exercising Rights & Requesting Human Review:

To exercise any statutory data subject right, request human review of an assessment or routing outcome, or seek clarification on international data transfers, please contact our designated Privacy Office:

Email: info@leadersperformance.ae
Postal Address: Leaders Performance Management Consultancies L.L.C, I Rise Tower, Office 17 C12, Barsha Heights, Dubai, United Arab Emirates.
Response Timetable: All verifiable data subject requests are acknowledged within 5 business days, with an internal operational target of thirty (30) calendar days to formally investigate and address requests, subject to identity verification and request complexity. (Note: Under the UAE PDPL, formal statutory timelines are subject to executive regulations; thirty calendar days reflects our internal operational commitment to prompt resolution.)

Leaders Performance Management Consultancies L.L.CLicence No: 1119124 · Public Privacy Policy · Dubai Mainland