Privacy Policy

Last updated: March 2026

1 – Introduction

This privacy notice explains how Thriving Divergent collects, uses and protects your personal data when you use our Heartbeat community platform, participate in our CBT for Adult ADHD course, attend our events, or receive communications from us.

Thriving Divergent is operated jointly by Jane Hehir and Orla Fitzmaurice. For the purposes of data protection law, we are joint data controllers.

We are committed to protecting your privacy and handling your personal data in accordance with the General Data Protection Regulation (GDPR) as enacted in Irish law under the Data Protection Act 2018.

By using our community or purchasing our course, you confirm that you are 18 years of age or older.

 

2 – Who We Are and How to Contact Us

Thriving Divergent is run by:

 

For any data protection queries, to exercise your rights, or to raise a concern, please contact us at:

Email: info@thrivingdivergent.com

Please keep us informed of any changes to your personal information so that our records remain accurate.

 

3 – The Platforms We Use

We use the following third-party platforms to deliver our services. Each has been selected carefully and operates under its own privacy policy, to which links are provided below.

  • Heartbeat (heartbeat.chat) – our community hub, course delivery platform, events management, and payment processing. Privacy policy: heartbeat.chat/privacy | DPA: heartbeat.chat/legal/dpa •

  • Stripe – payment processing. Stripe handles all card transactions. We do not store your card details. Privacy policy: stripe.com/ie/privacy

  • Flodesk – our email marketing and communications platform. Privacy policy: flodesk.com/privacy

  • Adilo – secure video hosting for session replays. Access is restricted to enrolled course participants only. Privacy policy: adilo.com/privacy-policy

  • Formaloo – for anonymous survey results. Privacy Policy: formaloo.com/privacy-policy

  • Google Analytics – used on our website to understand how visitors use our site. This may involve the use of cookies. See Section 10 for further detail.

 

We require all third parties to respect the security of your personal data and to process it only for specified, lawful purposes in accordance with our instructions.

 

4 – What Personal Data We Collect and Why

4.1 Registration and Account Data

When you join our Heartbeat community, register for a course, or sign up to our waitlist or mailing list, we collect:

  • Your name and email address

  • Your Heartbeat profile information (which you control and can update at any time)

  • Payment information (processed securely by Stripe; we do not see or store your full card details)

 

Purpose: To create and manage your account, process your purchase, and provide you with access to the course and community.

Lawful basis: Performance of a contract.

 

4.2 Communication Data

Any communication you send to us, whether by email, through the Heartbeat platform, or via social media, is retained for the purpose of responding to your query, maintaining records, and, where necessary, establishing or defending legal claims.

Lawful basis: Legitimate interests (to communicate with you and maintain records).

 

4.3 Session and Video Data

Our live sessions are hosted via Zoom and recorded. You will receive a notification from Zoom at the start of each session informing you that recording is in progress.

Each session is recorded and produces two separate replays, handled differently:

Main session replay (available to all community members)

  • This covers the main taught content and is made available to all Thriving Divergent community members, so that everyone has access to the most current version of the course material.

  • Only Jane’s slides and voice, or Orla’s voice, are included in this edited replay. No participant video or audio is retained.

 

Discussion replay (available to that cohort only)

  • The group discussion section of each session is recorded separately. This replay includes participant video and audio and is made available exclusively to the enrolled cohort for that course run. It is not shared with the wider community.

  • Participants are notified verbally at the start of each discussion segment that recording is in progress. By remaining in the session, participants consent to their video and audio being included in this cohort-only replay.

  • If you do not wish to appear in the discussion replay, you are welcome to turn off your camera and/or mute your audio during the discussion section.

 

All recordings

  • All replays are hosted on Adilo and access is restricted to the appropriate audience as described above.

  • All raw Zoom recordings are permanently deleted once the relevant replay edit is complete.

  • All recording and editing is carried out exclusively by Orla Fitzmaurice.

     

Written session notes are produced following each session. These notes capture themes, insights, and useful contributions from the group discussion. They are shared only within the Thriving Divergent community and course participants. If you would prefer that any contribution of yours not be included in the session notes, please contact Orla at info@thrivingdivergent.com.

Lawful basis: Legitimate interests (main session replay, available to all community members); Consent (discussion replay, where participant video and audio is included and participants are notified at the start of each discussion segment).

 

4.4 Onboarding Survey Data

At the start of each course, participants are invited to complete an optional anonymous onboarding survey via Formaloo. Participation is entirely voluntary. The survey collects general information including age range, gender, diagnosis history, medication, and topics of interest. No identifying information is collected at any point.

Aggregated results are shared with the cohort in chart form in the week after the course starts. Over time, combined results across cohorts may also be included in course resources and shared publicly, including on social media, to promote the community and raise awareness of ADHD. Nothing shared publicly can ever be traced back to an individual response.

Because the survey touches on health-related information such as diagnosis and medication, it falls within the definition of sensitive personal data under GDPR even in anonymous form. We handle this data with particular care and use it only for the purposes described above.

Formaloo stores survey responses on our behalf. We export and delete responses from Formaloo at the end of each cohort. You can review Formaloo’s privacy policy at formaloo.com/privacy-policy

Lawful basis: Explicit consent (participants complete the survey voluntarily and are informed of how the data will be used including that aggregated results may be shared publicly over time).

 

4.5 Community Interaction Data

When you post, comment, or otherwise interact within the Heartbeat community, that content is visible to other community members. Members may also send direct messages to one another privately via Heartbeat. Thriving Divergent has no access to private direct messages between members.

Given the nature of our community and the personal topics that often come up, we gently encourage you to be thoughtful about what you share in direct messages with people you are getting to know. As with any online community, it is worth building trust gradually before sharing anything particularly personal or sensitive.

Lawful basis: Legitimate interests (to operate the community platform).

 

4.6 Marketing and Email Data

If you join our mailing list, sign up to our waitlist, or download a free resource, we will add you to our Flodesk email list.

We use this to send you:

  • Course follow-up emails and session resources

  • Our newsletter, which may include educational content, updates, and information about future courses

 

You can unsubscribe at any time by clicking the unsubscribe link in any email, or by contacting us at info@thrivingdivergent.com. Unsubscribing from marketing does not affect communications related to a course you are actively enrolled in.

Lawful basis: Consent (for newsletter and marketing); Legitimate interests (for course-related communications).

 

4.7 Technical and Usage Data

We may collect anonymised technical data about how you interact on our website, including browser type, pages visited, and time spent on pages. This data is collected via Google Analytics and is used in aggregated, anonymised form to improve our website and understand how our audience engages with our content.

Lawful basis: Legitimate interests (to maintain and improve our website and communications).

 

5 – A Note on Sensitive Information

We collect limited sensitive personal data via our optional onboarding survey (see Section 4.4). This is handled anonymously and used only as described above.

Beyond the survey, participants in our CBT for Adult ADHD course may choose to share personal information relating to their mental health, diagnosis history, or lived experience during sessions or within the community. This information is shared voluntarily and is treated with the utmost discretion and confidentiality.

We strongly encourage all participants to share only what they are comfortable with. Please review our Community Code of Conduct for our expectations around confidentiality within the group, and be mindful of what you share in community posts and direct messages, as these are visible to or accessible by other members.

 

6 – Use of Anonymised Content

From time to time, we may share anonymised insights, quotes, or themes from our sessions publicly, for example in our newsletter, on social media, or in promotional materials for future courses.

We take participant anonymity seriously. Any content shared publicly is carefully edited to remove all identifying details. If you have concerns about a particular contribution being shared, please contact Orla at info@thrivingdivergent.com.

 

7 – Who We Share Your Data With

We share your data only where necessary and with appropriate safeguards in place.

Recipients may include:

  • Heartbeat – to operate the community and course platform

  • Stripe – to process payments securely

  • Flodesk – to deliver email communications

  • Adilo – to host session replay videos

  • Formaloo – to run anonymous surveys

  • Google Analytics – aggregated, anonymised website usage data

  • Professional advisers (lawyers, accountants, insurers) where required

  • Government or regulatory bodies where we are legally required to report

We do not sell, rent, or trade your personal data. We do not use your data for advertising purposes and we do not share it with advertisers.

Some of our third-party providers are based outside the European Economic Area (EEA). Where this is the case, we ensure that appropriate safeguards are in place (such as Standard Contractual Clauses) to protect your data.

 

8 – How Long We Keep Your Data

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal and regulatory requirements.

  • Course and community access: for the duration of your membership plus a reasonable period thereafter

  • Financial transaction records: seven years, as required by Irish tax law

  • Email marketing data: until you unsubscribe or request deletion

  • Raw Zoom session recordings: deleted immediately after the replay edit is complete

  • Session notes: retained for as long as the relevant course materials are in use

  • Survey data: We export aggregated results for long-term record keeping and delete the raw responses from Formaloo at the end of each cohort. Aggregated chart exports are retained indefinitely for research and record-keeping purposes

 

When data is no longer needed, it is securely deleted or anonymised.

 

9 – Your Rights Under GDPR

As a data subject under Irish GDPR, you have the following rights:

  • Right of access – to request a copy of the personal data we hold about you

  • Right to rectification – to request correction of inaccurate or incomplete data

  • Right to erasure – to request deletion of your data in certain circumstances

  • Right to restriction – to request that we limit the processing of your data

  • Right to data portability – to receive your data in a structured, commonly used format

  • Right to object – to object to processing based on legitimate interests

  • Right to withdraw consent – where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

 

To exercise any of these rights, please contact us at info@thrivingdivergent.com. We will respond within one month. We may need to verify your identity before processing your request.

You have the right to lodge a complaint with the Data Protection Commission (DPC) at any time. We would, however, appreciate the opportunity to address any concern directly before you contact the DPC.

Data Protection Commission: www.dataprotection.ie

 

10 – Cookies

Our website (www.thrivingdivergent.com) uses cookies to help it function and to allow us to understand how visitors use it. Google Analytics uses cookies to collect anonymised data about website traffic and behaviour.

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

The Heartbeat platform may also use its own cookies to operate the community. Please refer to the Heartbeat privacy policy for further detail: heartbeat.chat/privacy

 

11 – Third-Party Links

Our website and community may contain links to external websites and resources. We are not responsible for the privacy practices of those sites and encourage you to read their privacy notices when you visit them.

 

12 – Changes to This Policy

We may update this privacy policy from time to time. Where changes are material, we will notify members via the Heartbeat community or by email. The date at the top of this document reflects when it was last updated.

Continued use of our community or course after an update constitutes your acceptance of the revised policy.

 

Thriving Divergent | info@thrivingdivergent.com | members.thrivingdivergent.com