Privacy Policy

What I collect, why I collect it, who else handles it, and how to get it removed.

Last updated 27 September 2026

1. Who is responsible for your data

This site, emmanuelchukwuemeka.com, is operated by Zerchis Ltd, trading as The 365 Career Architecture System. Zerchis Ltd is the data controller for personal data collected through this site.

Zerchis Ltd is registered in England and Wales, company number 15054883, registered office 128 City Road, London, EC1V 2NX. VAT registration number 482 4227 88.

Throughout this policy, "I" and "me" mean Emmanuel Chukwuemeka acting for Zerchis Ltd, and "we" and "us" mean Zerchis Ltd. The company is the party responsible for your data.

All data protection enquiries: privacy@emmanuelchukwuemeka.com.

2. What this policy covers

This policy explains what personal data I collect when you browse the site, take the Career Drift Diagnostic, create an account, buy a product, or contact me, why I collect it, who else handles it, and what rights you have. It does not cover third party sites I link to.

3. What I collect, why, and on what basis

Data	Why	Lawful basis
Name and email address	To create your account, deliver purchases, send your diagnostic result if you ask me to save it, and reply to enquiries	Contract, and legitimate interests for enquiries
Account credentials	To authenticate you and restore access to paid diagnostics, programs and account-based services	Contract
Diagnostic answers, layer scores and profile	To score the instrument, show your result, prepare and update your Personal Report, and let you retake and compare	Contract, and consent where you ask me to save the result to your account
Optional research responses, question edition, assessment date and participant code	With separate permissions: to evaluate and improve the Diagnostic; and to conduct research for annual Career Drift publications	Consent, separately for each purpose
Research permission choices, wording version, timestamps and withdrawals	To respect your choices and keep a record of which uses you authorised	Legitimate interests in accountability and respecting your choices
Pilot invitation and redemption records	To issue a personal code, prevent reuse, open the agreed pilot access and protect the pilot from automated guessing	Contract, and legitimate interests in service security
Pilot application name, email address and LinkedIn profile URL	To review your request for a place in the Career Drift Diagnostic pilot and contact you about the outcome	Consent
Course progress and online-workbook responses	To resume your program across devices, save your work, show completion and generate the personal workbook copy you request	Contract
Purchase records: what you bought, amount, date, Stripe payment reference, billing country	To take payment, unlock what you paid for, handle refunds and disputes, and meet tax and accounting duties	Contract, and legal obligation
Retake reminder preference	To send the optional reminder on the date shown when you opt in, which may be earlier for time-limited pilot access	Consent
Optional Diagnostic feedback: rating, comment and content edition	To identify unclear questions and improve the reflection experience. Feedback is private unless you separately permit publication.	Consent
Diagnostic terms version, acceptance time and account or purchase reference	To administer your agreed access and retain evidence of the agreement. Pilot acceptance is recorded at redemption; purchase acceptance is recorded before payment.	Contract; legitimate interests in keeping evidence of agreements and resolving disputes
Optional testimonial permission, its wording version, time, attribution and any withdrawal	To publish an authorised comment on our website and official social media, attributed only as “Diagnostic participant”. We do not publish your account name, employer, answers or scores under this permission.	Consent for publication; legitimate interests in retaining a minimal permission/withdrawal record to respect your choice and resolve disputes
Correspondence you send me	To answer you and keep a record of what was agreed	Legitimate interests
Booking details for a Career Direction Session	To schedule the session and send the joining link	Contract
Technical and security logs: IP address, browser, timestamps	To keep the site and accounts secure and to diagnose faults	Legitimate interests

I do not buy personal data, I do not sell it, and I do not use it to build advertising profiles. I do not ask for special category data. Please do not send me health, disciplinary or grievance detail in a diagnostic free text field or an enquiry.

Unfinished Diagnostic progress is held in the current browser tab. When a result is saved to your account, the answers are sent securely to calculate and check its scores. For completed full Diagnostics taken using the answer-storage notice shown before the questions, we also retain the 25 individual responses, question wording, edition and capture dates in a private record linked to that assessment. We use this record to prepare and update your Personal Report. Research use is separate and optional, as explained below. Answers are not included in feedback, advertising or browser funnel analytics. Your access to answer records and protected report content requires your signed-in account and active full Diagnostic access. Older individual answers that were not retained cannot be recovered. Free Identity results continue to save scores without retaining their individual answers on the server.

Saved results also include scores, the content edition and any statement or plan you choose to save. Answer records follow the account-data retention and deletion rules in section 8 below and are deleted with their assessment or account. Optional feedback does not send your answers or scores. Signed-out feedback uses a random identifier held in that tab to limit repeats; it is not an advertising identifier. Funnel analytics exclude Diagnostic answers, scores and result bands.

Optional Diagnostic research

Before a new full assessment, you can independently agree to use of its responses for Diagnostic evaluation and improvement, and for research supporting annual Career Drift publications. Neither box is preselected. Declining either or both does not change your Personal Report, price or access. Historical responses are not opted in automatically. New assessments ask again.

Authorised research uses a restricted dataset containing a participant code, assessment identifier, edition, assessment date, numeric responses and layer scores. It excludes names, emails, employers, written Career Drift Statements and plans. Participant codes distinguish repeat assessments from different people. This dataset is pseudonymised, not anonymous, and is accessible only to authorised backend operators, not other participants or the public. Access expiry alone does not withdraw a separate research permission.

Withdraw either permission at any time in Account → Support, even after pilot access expires, or contact privacy@emmanuelchukwuemeka.com. Withdrawal excludes your linked responses from further use for that purpose, including pending research analyses. It does not remove your private report record or affect your access. It does not affect processing already lawfully carried out. Findings already irreversibly anonymised cannot be traced back to you and removed.

Publications will contain only anonymised, grouped findings, with small groups suppressed or combined where needed to prevent identification. Permission does not authorise publication of individual responses or quotations. We will describe recruitment, sample size, editions and limitations rather than treat a self-selected participant sample as representative of the entire IT industry.

Research eligibility and linked research records follow the same account and assessment retention rules in section 8. Withdrawing stops eligibility immediately; authorised researchers must remove any linked working copies for that purpose before further analysis. Permission records remain for accountability while the associated assessment/account is retained. A pending choice receipt is valid for 24 hours, is replaced by a newer choice and is removed when used; any unused receipt is removed on account deletion. No identifiable research archive is retained indefinitely after account closure.

4. Card details

I never see or store your card number. Payments are taken by Stripe, which handles the card data directly as its own controller under its own privacy policy. I receive only a payment reference, the amount, the outcome, and the last four digits.

5. Cookies and local storage

The site uses a small number of strictly necessary cookies and browser storage entries, and no analytics or advertising cookies. Full detail is in the Cookie Policy.

6. Who else handles your data

I use a small number of providers to run the site. Each acts as a processor on my instructions, except Stripe, which is also a controller for payment data.

• Supabase for the account database and authentication. Data is held in the London region, eu-west-2.
• Stripe for payment processing, fraud prevention and refunds.
• Resend for transactional and reminder email, including receipts, password resets and the optional 30 day retake reminder.
• Cal.com for scheduling Career Direction Sessions, and Google Meet for delivering them.
• 20i for hosting, with the origin servers in the United Kingdom. 20i also operates a content delivery network that caches copies of public pages on servers in other countries so they load faster. Only static files are cached this way: page templates, stylesheets, scripts, images and fonts. Your account details, purchase history and diagnostic results are never part of a cached file. They are requested from the database only after you sign in, and are delivered directly to your browser rather than through the cache. No personal data is stored on the delivery network.

Enquiries sent through the contact form are written straight to my own database and emailed to me. No third party form handling service sits in between.

I disclose data beyond these providers only where the law requires it, or to my accountant or a professional adviser where necessary, or if a business or asset transfer takes place, in which case you will be told first.

7. International transfers

Account data is stored in the United Kingdom. Some providers process data in the United States or the European Economic Area. Where data leaves the UK it is protected by UK adequacy regulations or by the International Data Transfer Addendum to the EU Standard Contractual Clauses, together with appropriate technical safeguards.

8. How long I keep it

• Account, diagnostic, course-progress and workbook data: kept for as long as your account is active, so that your results, learning progress, saved work and paid access remain available to you. A self-service account closure is scheduled for seven days after your verified request and can be cancelled during that period. The account and associated personal workspace are deleted when that period ends. Other erasure requests are completed within 30 days, except where a legal obligation requires a limited record to be kept.
• Purchase and tax records: six years after the end of the relevant accounting period, as required by UK tax law. This applies even after account deletion, and is limited to the transaction record.
• Email marketing consent records: until you unsubscribe, then a suppression record so I do not contact you again.
• Pilot invitation and redemption records: failed redemption attempts are deleted after 24 hours; an unredeemed invitation is deleted within 30 days after it expires; a redeemed code and its issue note are deleted 12 months after redemption. The account access grant and any result you save follow the account-data period above.
• Pilot applications: the LinkedIn profile URL is deleted when verification and invitation-code issue are completed. Unsuccessful or abandoned applications are deleted within 30 days. An issued application record is deleted 12 months after verification.
• Correspondence: up to two years after the matter closes.
• Security logs: up to 12 months.

If you take the free Identity layer without creating an account, your answers stay in your own browser and are never sent to me.

9. Your rights

Under the UK GDPR you have the right to be informed, and to request access, correction, erasure, restriction of processing, or portability of your data. You may object to processing based on legitimate interests, and you may withdraw consent at any time, including by using the unsubscribe link in any reminder email.

You can close your account from the Security section after confirming your password and authenticator code. You can cancel that request during the seven-day period. To exercise any other right, email privacy@emmanuelchukwuemeka.com with "Data request" in the subject line. I will respond within one month. I may ask you to confirm your identity first.

If you are not satisfied with my response you can complain to the Information Commissioner's Office at ico.org.uk, or by calling 0303 123 1113. I would appreciate the chance to resolve it first.

10. Security

Testimonial choices. Giving feedback does not require permission to publish it. You can withdraw publication permission in Account → Support or by emailing privacy@emmanuelchukwuemeka.com, without losing access. Withdrawal does not invalidate prior lawful use. We will stop future use and remove it from channels we control, but cannot recall printed material already distributed or guarantee removal of independent third-party copies. We retain the record while the testimonial is in use and a minimal withdrawal record as needed to prevent further use and address disputes, subject to your data protection rights. Pilot acceptance records are removed with account deletion; purchase records follow the financial-record retention period stated above. Older permission to contact you about a quote is not treated as permission to publish it.

Access to the account database is restricted by row level security, so one account cannot read another. Data is encrypted in transit and at rest, administrative access uses multi factor authentication, and payment credentials never touch my systems. No system is perfect, and if a breach affects your rights I will notify you and the ICO as required.

11. Automated decisions

The diagnostic scores your answers automatically and shows you a zone and a profile. This is a self assessment tool for reflection, not a decision about you, and no legal or similarly significant decision is made automatically about anyone.

12. Children

This site and its products are intended for working professionals and are not directed at anyone under 18. I do not knowingly collect data from children.

13. Changes to this policy

If this policy changes I will update the date at the top. Where the change materially affects how your data is used, I will tell account holders by email before it takes effect.