Privacy Policy
Last updated 19 October 2026
1. Who we are
CHANGE is operated by Blomeric, an auxiliary trade name of Matias Blomqvist Lääkäripalvelut Oy (Business ID 3396794-7), c/o PL83037, Pitkämäenkatu 9, 20250 Turku, Finland. We are the controller of your personal data. In anything concerning this policy, contact us at matias.blomqvist@mblp.fi.
2. What we collect, why, and on what legal basis
- Your email address and password (stored hashed by our account provider) — to create and secure your account. Basis: performance of our contract with you.
- Your subscription plan, payment status and Stripe customer and subscription identifiers — to take payment and keep your subscription running. Basis: contract.
- Your chosen language, delivery time and time zone — to deliver the program to you at the time you chose. Basis: contract.
- The day you have reached in the program and the related timestamps — to send you the right content next. Basis: contract.
- The messages you send to and receive from the Coach, stored encrypted — to provide the coaching conversation. Basis: contract.
- Counters that limit how many messages one account can send per day, and technical error logs — to keep the service available and to fix faults. Basis: our legitimate interest in protecting and maintaining the service.
- After you delete your account: your email address, the dates and whether a refund was made — to administer the money-back guarantee, which is available once per person. Basis: our legitimate interest in preventing repeated refunds.
- Invoicing and accounting records — to comply with accounting and tax law. Basis: legal obligation.
- Feedback you choose to give us — to improve the program. Basis: your consent, which you can decline or withdraw with no effect on the service.
- If you allow notifications: the push address and encryption keys your browser creates, together with the device type and the date added — to let you know when the Coach has replied or sent you a message. They are stored with our chat service (Stream) and are not visible to other users. The notification is delivered by your browser's own push service (for example Google, Apple or Mozilla); it is encrypted and contains no message content. Expired or withdrawn subscriptions are removed automatically the next time a notification is sent. Basis: your consent, which you can withdraw at any time by turning notifications off in your browser or device settings.
We do not ask you for, and you should not send us, information about diagnoses, medication or other medical matters. CHANGE is a lifestyle coaching and education program and is not medical care.
3. Who we share it with
We use the following service providers, who process the data only on our instructions: Memberstack (accounts), Stripe (payments), Make.com (automation, EU servers), Stream (the chat, EU servers), Google (Gemini for generating the Coach's replies, Sheets for program content) and Netlify (website hosting, sending notifications and cookie-free visitor statistics). We do not sell your data and we do not share it for advertising.
4. Transfers outside the EU/EEA
Some of these providers are located outside the EU/EEA, mainly in the United States. Those transfers are covered by the European Commission's standard contractual clauses or by the EU–US Data Privacy Framework.
5. How long we keep it
We keep your account data for as long as your account exists. When you delete your account, your account data and your conversation history are deleted. The limited deletion record described above is kept for as long as we offer the money-back guarantee. Accounting records are kept for the period required by Finnish accounting law (the current year plus six years).
6. Cookies
We use only what is necessary for the site to work: a session cookie that keeps you logged in, the cookies Stripe needs to complete a payment, and a few items stored in your browser, such as your language choice, the chat's sign-in token and, if you allow notifications, a notification subscription. We use no advertising or analytics cookies, so there is nothing here for you to consent to.
7. Automated content and decisions
The Coach's replies are generated automatically by an AI system and may be inaccurate or incomplete. We do not make automated decisions that produce legal effects for you or similarly significantly affect you.
8. Your rights
You have the right to ask us for a copy of your data, to have it corrected or deleted, to restrict or object to our processing of it, and to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time. You can delete your account and its data yourself in the app whenever you like; for anything else, contact us at matias.blomqvist@mblp.fi. If you believe we have handled your data incorrectly, you can complain to the Finnish Data Protection Ombudsman (tietosuoja.fi).
9. Do you have to give us your data?
Your email address and payment details are needed to make the contract with us; without them we cannot provide the service. Everything else is voluntary.
10. Changes to this policy
If we change this policy, the new version appears here and the date above is updated.