Privacy notice
Written under Articles 13 and 14 of the EU General Data Protection Regulation ((EU) 2016/679, the GDPR). Reviewed with the institute's lawyer on 2026-10-13 and updated on 2026-10-14 after the lawyer's decisions. It describes what the applications actually do.
2026-10-21
1. Controller and contact
The controller of the data in this notice is Anthony Tatekawa, self-employed (autónomo), operating as Transcendent Institute (NIF ESY2241949S, Calle Blasco de Garay, Barcelona 08004, Spain). Transcendent Institute operates the Inner System Map and the Tree of Life tests (the Sephirot test and the Malkuth test). This notice covers all of them.
Privacy questions and requests: info@transcendentinstitute.com. We answer requests within one month of receiving them, as the GDPR requires.
2. Purposes and legal bases
Inner System Map, public mode: your answers are scored in your browser. When you give your name and email at the start, we email you your results as a PDF, keep a copy of your name, email, answers and results for 6 months, and send a copy to Transcendent Institute so the school can follow up if you ask. Legal basis: your explicit consent, given by ticking the consent box on the start screen (GDPR Article 6(1)(a) and Article 9(2)(a)).
WhatsApp (optional): tick the box and we also send your PDF there (via Meta), and keep your number so the institute can reply.
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Public mode only. The box is separate and never ticked for you. Meta's WhatsApp Business Platform delivers the message as our processor, and Meta may handle the message and the PDF outside the EU under its standard contractual clauses. We record when you agreed and which version of this notice you saw. If WhatsApp accepts the message, we keep your number with your stored results for 6 months and in your follow-up record (section 7). Without the tick, we send nothing on WhatsApp. Legal basis: your consent (GDPR Article 6(1)(a) and Article 9(2)(a)).
WhatsApp messages: if you write to the institute's WhatsApp number, we keep your messages, your WhatsApp profile name and our replies until 6 months after the last message in the conversation, so the institute's administrators (operational access) and consultants (who follow up with people) can answer you. Only they can read them, and every time they open them is recorded. Photos, voice notes and files are not downloaded or kept; we keep only their type and caption. To have the conversation deleted sooner, write to info@transcendentinstitute.com and we check within 30 days that it is yours and then delete it. Legal basis: our legitimate interest in answering you when you contact us (Article 6(1)(f)).
Follow-up: when a copy of your results is kept, the institute also keeps a follow-up record (section 3) so it can handle contact and deletion requests. We contact you about your results or the institute's programmes only if you ticked the separate box allowing it. Legal basis: your consent (Article 6(1)(a)). You can withdraw it at any time by replying to any message or by writing to info@transcendentinstitute.com; we then mark the record "do not contact" and stop. You can choose "do not contact me about this programme" (the edition where you took the test) or "never contact me again" (every programme); a request that does not say which counts as "never contact me again".
Newsletter: if you tick the newsletter box, we record your choice. Legal basis: your consent (Article 6(1)(a)), which you can withdraw at any time.
Inner System Map, cohort mode: your answers, results and any notes you choose to share are stored under your account and are visible to the named facilitators of your cohort, to support your work in the retreat. Legal basis: your explicit consent (Article 6(1)(a) and Article 9(2)(a)), recorded with its date and policy version.
Sephirot and Malkuth tests: we store your name with your answers so that we can show you your results, which you can download as a PDF. We also look at combined answers, never individual ones, to understand how the questions behave. Legal basis: your consent, given by starting the test (Article 6(1)(a) and Article 9(2)(a)). Administrators and consultants can also open an individual result in the institute's staff area to answer questions you ask about it; legal basis: the same consent.
Results by email: the Sephirot test needs your email address, the Malkuth test only if you tick its box; we email you only after you confirm it.
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Sephirot test: you give your email address to start the test, and one box on the start page, unticked by default, is for the institute's programmes and newsletter only. Malkuth test: we ask for an email address only together with one box, unticked by default, for results by email and the institute's programmes and newsletter; if you do not tick it, we keep no email address and you download your results instead. In both tests we first email you a link to confirm your address. Only after you press Confirm on the page it opens do we email you your results as a PDF (as soon as you have finished the test). Only if you ticked the box and confirmed your address does the institute add your name, email address and language to its follow-up records (section 3), and it may then email you about its programmes and send you its newsletter. If you do not confirm within 30 days, we delete your email address and send you nothing more (section 7). Your answers and results are never used for programme or newsletter emails, and you are never contacted about your result unless you ask. Legal basis: your consent (Article 6(1)(a), and Article 9(2)(a) for the results email); in the Sephirot test you give it for the results email by starting the test with your address, and the box is recorded with its date, your language and the version of this notice. You can withdraw your consent to programme and newsletter emails at any time by replying to any message or by writing to info@transcendentinstitute.com; we then mark the record "do not contact" and stop.
Security of the service: we record which staff member opened which result, export or conversation (the audit log) and count requests to stop abuse. Legal basis: our legitimate interest in protecting your data and the service (Article 6(1)(f)).
Do-not-contact and deletion requests: if you ask us not to contact you, we keep a coded record of your request (section 7) so that we keep honouring it; the legal basis is our legitimate interest in honouring your request (Article 6(1)(f)). We keep a record of deletion requests so that we can show they were handled; the legal basis is our legal obligation (Article 6(1)(c) and Article 5(2)).
Answers describe your inner life and may reveal information about mental health. We treat all of it, in every test, as special category data (Article 9). Your data is not sold and is not used for advertising.
3. The data we process
Inner System Map: name, email address, optional WhatsApp number, answers and results, language, form (short or full), the edition of the test and its country (the country set for that edition, not your location), your consents with their time and the version of this notice, and the follow-up record. The follow-up record holds your name, the email address or WhatsApp number you gave, your language, the edition and country of the test, whether you agreed to be contacted, its status, the staff member responsible, contact dates, the notes staff add about their conversations with you, and a flag when your result describes a state so overwhelmed that nothing promotional is sent to you. It never contains your answers or scores. In cohort mode we also process your account, your cohort and the notes you share.
If you take the test more than once with the same email address, each result is stored against that address and the institute may view them together. You can ask for copies of your past results by writing to info@transcendentinstitute.com.
Sephirot and Malkuth tests: name, email address (always in the Sephirot test; in the Malkuth test only if you ticked the box), answers (each saved as a number), language, date and a random session identifier, whether you ticked the box (programmes and newsletter, and in the Malkuth test also results by email), with its date, language and notice version, when we last sent you the confirmation email, and when you confirmed your address. If you ticked the box and confirmed your address, the institute also keeps a follow-up record like the one described above (name, email address, language, the test, the consent and its date, status, the staff member responsible, contact dates and notes), never your answers or results.
Your browser keeps your name, email and answers in its local storage while you take a test. The Sephirot and Malkuth tests also set two cookies, NEXT_LOCALE (one year) to remember your language and tol_session (seven days) so that only the browser that started a test can save, open or email its results, and count visits with Vercel Web Analytics, which sets no cookies and is not linked to your answers.
What we do not collect: no date of birth. The Inner System Map has no analytics cookies and keeps no IP addresses in its database. The Sephirot and Malkuth tests do not store or log IP addresses either. To stop abuse, every test counts requests per IP address in short-lived memory, for at most a day. Logs record job outcomes only, never answers or email addresses.
4. Where the data comes from and whether you must give it
We get the data from you. Your WhatsApp profile name comes from Meta when you write to us on WhatsApp. Staff notes come from their contact with you.
Giving your data is not a legal or contractual requirement. In the Inner System Map's public mode, your name and email address are needed to send you your results, and the test cannot start without them. The Sephirot test needs your name and email address, because it sends your results by email, and cannot start without them; the Malkuth test needs only your name, and an email address only if you want your results by email, which comes with the programmes and newsletter box (section 2). The WhatsApp number, the consent to be contacted and the newsletter are optional.
5. Recipients
Results emails go to the address you gave and contain your results and a PDF. Our email provider, Resend, keeps the content and delivery details of every email we send, including the attached PDF, for 30 days and then deletes them.
The institute gets an English copy of your results; if you use WhatsApp, staff also see your number.
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For the Inner System Map the copy is an email with your name, language, pattern and PDF. If you also get your results on WhatsApp, staff see your number in your follow-up record once WhatsApp has accepted the message. For the Sephirot and Malkuth tests, a copy may be sent to the practitioner who runs the test. The email in your own inbox is yours to keep or delete; we cannot delete it for you.
The institute's administrators have operational access to the service. Its consultants can open public Inner System Map results, follow-up records and WhatsApp conversations, because they follow up with people who asked to be contacted and answer messages. Cohort results are seen only by administrators and the cohort's facilitators. For the Sephirot and Malkuth tests, administrators and consultants can open the results, with the name, email and answers, each test on its own, in the institute's staff area, so that they can answer questions about them; only administrators can export them to a spreadsheet, and nobody who took those tests is contacted about their result unless they ask. Those who ticked the programmes and newsletter box are also in the follow-up records that administrators and consultants open.
Processors, which handle data on our behalf under contract: Vercel (hosting, Frankfurt), Neon (database and sign-in, Frankfurt), Resend (transactional email, EU), Upstash (rate limiting, EU), Meta Platforms (WhatsApp Cloud API, only if you use WhatsApp with us). For the Sephirot and Malkuth tests: Vercel (hosting and cookie-free analytics), Neon (database) and Resend (email). For the newsletter and programme emails, only to people who agreed to receive them: Brevo (Sendinblue SAS, France). We do not disclose data to anyone else.
6. Transfers outside the EU and EEA
Inner System Map: all data is stored and processed in the European Union. Exception: when you use WhatsApp with us (results delivery or messages), Meta may process those messages, and any PDF, outside the EU under its standard contractual clauses.
Sephirot and Malkuth tests: the database is hosted in the European Union (Frankfurt).
7. Retention
Inner System Map: public results 6 months, then deleted automatically. The follow-up record 24 months after our last contact with you, then deleted automatically; the deletion link in your results email deletes it together with your results. Cohort data: 12 months after the cohort end date unless the school sets otherwise, then deleted automatically. Account deletion removes everything immediately.
Sephirot and Malkuth tests: results are kept until you ask us to delete them; they are not deleted automatically, and neither is a confirmed email address stored with them. If you do not confirm your email address within 30 days, it is deleted automatically with any record of the box (from the test's database and from your stored results), and your results are never emailed; your name and results stay. If you ticked the box and confirmed your address, the follow-up record is kept 24 months after you gave that consent or after our last contact with you, whichever is later, then deleted automatically. A coded marker of the import (no name or email) is kept for at most 25 months so that a deleted record is not imported again.
Copies in the institute's mailbox: until you ask us to delete them, and then within 30 days. Email content at Resend: 30 days.
The audit log (which administrator opened which result, export or conversation): 12 months, then deleted automatically.
When you ask for deletion, we keep your email address or WhatsApp number for at most 30 days, only so the institute can find and delete the copies in its mailbox, and we clear it as soon as that is done. A record without personal data (the date, how the request arrived and what it covered) is deleted 24 months after the request closes.
If you ask us not to contact you, we keep a coded form of your email address or number (pseudonymised with a salted one-way hash), the date, and whether the request covers one programme or all of them. It is kept without a time limit, so that we keep honouring your request after the follow-up record is deleted.
8. Security
Access to the data is limited by role (administrators, consultants and cohort facilitators), and the database checks every query against row-level access rules. In the Inner System Map, every time a result, follow-up record or conversation is opened it is recorded in the audit log. Connections are encrypted (HTTPS), and staff sign in with a one-time code sent to their email. Logs never record answers, names, email addresses or phone numbers. The staff area reads the Sephirot and Malkuth tests through a read-only connection, checks the staff role itself because those databases have no row-level access rules, and records every list, result and export opened there in its audit log.
9. Your rights
You have the right to access your data (Article 15), to have it rectified (Article 16) or erased (Article 17), to restrict its processing (Article 18), to data portability (Article 20) and to object to processing based on legitimate interest (Article 21). You can withdraw your consent at any time; this does not affect the lawfulness of the processing before you withdrew it. Write to info@transcendentinstitute.com. For the Inner System Map you can also use the deletion link in your results email and the self-service export and deletion in the app.
Whatever the test, when you ask for deletion: your results and follow-up record are deleted from the database at once (if you had asked not to be contacted, only the coded record described in section 7 is kept); the copies in the institute's mailbox are deleted within 30 days; and any WhatsApp conversation with the number you gave is held back from the inbox until an administrator has checked, within 30 days, that it belongs to you: if it is yours it is deleted, and if it is not it is returned to the inbox.
10. Automated decisions and profiling
Your answers are scored automatically, which produces a description of your inner system in the language of parts. No decision with legal or similarly significant effects on you follows from it (Article 22). Its only automatic consequence is the flag described in section 3, which stops anything promotional being sent to you. We do not use your data for advertising or build audiences from it.
11. Right to complain to a supervisory authority
If you think the processing of your personal data breaks the GDPR, you can complain to the supervisory authority of the EU country where you live or work or where the alleged breach took place (Article 77). In Spain, where the controller is established, it is the Agencia Española de Protección de Datos (aepd.es).
12. Age
The Inner System Map is for adults: you confirm you are 18 or older before starting. The Sephirot and Malkuth tests are also for adults but do not check your age.
13. Changes to this notice
When this notice changes materially, we update its date and version. Your consent is recorded with the version of the notice in force when you gave it.