PRIVACY POLICy

Legal Entity: Frey & Co Holdings LLC (EIN: 23-8737781)
Trading As: Success School
Address: 30/209 Moo 4, T. Bophut, Koh Samui, Surat Thani 84320, Thailand
Email: [email protected]
Website: https://startsuccessschool.com/
Last Updated: April 2026

This Privacy Policy explains how Frey & Co Holdings LLC (“we,” “us,” “our”) collects, uses, stores, and shares your personal information when you visit our website or enrol in Success School. Please read it carefully.

By using our website or enrolling in our programme, you acknowledge that you have read and understood this Privacy Policy.

1. INFORMATION WE COLLECT

Information you provide directly

We collect personal information you voluntarily provide when you:

Fill out an application or enquiry form — name, email address, phone number, business details
Book a call or schedule a consultation — name, email address, and any information you provide during the booking process
Enrol in Success School — name, email address, billing address, payment information, phone number, and business information
Participate in the programme — coaching session notes, KPI data, business performance information you choose to share
Contact us by email — your name, email address, and the contents of your message
Subscribe to our email list — name and email address

Self-reported client performance data

Active clients may voluntarily submit monthly revenue and business performance data for coaching and accountability purposes. This data is not required and is provided at your discretion. It may be used to track your progress, improve our coaching, and generate anonymised aggregate statistics. We will not publish or share your individual performance data without your express consent.

Information collected automatically

When you visit our website, we automatically collect certain technical information including your IP address, browser type and version, device type, operating system, the pages you visit, the time and date of your visit, referring website, and browsing behaviour on our site. This information is collected through cookies and similar tracking technologies.

2. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies. Cookies are small files placed on your device that help us operate and improve the website.

We use the following types of cookies:

Essential cookies — necessary for the website to function properly
Analytics cookies — help us understand how visitors use our website so we can improve it
Marketing and advertising cookies — used to deliver relevant advertising and track the effectiveness of our marketing campaigns

Third-party tracking

Our website uses the Facebook Pixel (Meta Pixel), which allows Meta Platforms Inc. to collect data about your activity on our website. This data is used to measure the effectiveness of our advertising on Facebook and Instagram and to deliver targeted advertisements. Meta’s data practices are governed by Meta’s Privacy Policy.

You can opt out of Facebook/Meta personalised advertising through your Facebook Ad Preferences or via the Digital Advertising Alliance opt-out.

You can control or disable cookies through your browser settings. Note that disabling certain cookies may affect website functionality.

3. HOW WE USE YOUR INFORMATION

We use the personal information we collect to:

Deliver the Success School programme and related services
Process enrolments and payments
Communicate with you about your programme, account, and support requests
Send programme-related updates, resources, and coaching materials
Send marketing communications about Success School (where you have consented or where we have a legitimate interest)
Operate, maintain, and improve our website
Analyse usage trends and improve the programme
Generate anonymised aggregate statistics from voluntarily submitted client data
Create client case studies and testimonials (with your express consent)
Comply with our legal obligations and enforce our agreements
Prevent fraud and protect the security of our website and business

4. LEGAL BASIS FOR PROCESSING (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data on the following legal bases:

Contract performance — processing necessary to deliver the programme you have enrolled in
Legitimate interests — improving our services, marketing to prospective clients, and preventing fraud, where these interests are not overridden by your rights
Consent — where you have given explicit consent, such as subscribing to our email list or agreeing to be featured in a case study
Legal obligation — where we are required to process data to comply with applicable law

5. SHARING YOUR INFORMATION

We do not sell your personal information. We may share your information with:

Service providers — third-party companies that help us operate our business, including payment processors, email marketing platforms, scheduling tools, CRM systems, and website hosting providers. These providers are contractually required to protect your data and use it only for the purposes we specify.
Meta Platforms (Facebook/Instagram) — via the Facebook Pixel for advertising measurement and targeting purposes, as described in Section 2.
Legal and regulatory authorities — where required by law, court order, or regulatory requirement.
Business transfers — in the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you if this occurs.

We will not share your individual performance data, business information, or coaching session content with any third party without your express consent.

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, including:

Active clients — for the duration of your programme and for a period of seven (7) years after your programme ends, for legal, accounting, and tax purposes
Enquiries and applications that did not result in enrolment — for up to two (2) years
Email subscribers — until you unsubscribe or request deletion
Website analytics data — in accordance with the retention settings of the analytics tools we use

When data is no longer required, we delete or anonymise it securely.

7. YOUR RIGHTS

Depending on your location, you may have the following rights regarding your personal information:

Access — request a copy of the personal information we hold about you
Correction — request that we correct inaccurate or incomplete information
Deletion — request that we delete your personal information, subject to legal retention obligations
Portability — request your data in a structured, machine-readable format (where applicable)
Objection — object to our processing of your data for marketing purposes
Restriction — request that we restrict processing of your data in certain circumstances
Withdraw consent — where processing is based on consent, withdraw that consent at any time

To exercise any of these rights, contact us at [email protected]. We will respond within thirty (30) days. We may need to verify your identity before processing your request.

If you are in Australia, you also have rights under the Australian Privacy Act 1988. If you are in the EEA or UK, you have the right to lodge a complaint with your local data protection authority.

8. MARKETING COMMUNICATIONS

If you have subscribed to our email list or enquired about our programme, we may send you marketing emails about Success School. You can unsubscribe at any time by clicking the unsubscribe link in any email or by contacting us at [email protected].

Existing clients may receive programme-related communications for the duration of their enrolment. These are not marketing emails and cannot be opted out of while your programme is active, as they are necessary for service delivery.

9. DATA SECURITY

We implement reasonable technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. However, no internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

If you believe your personal information has been compromised, please contact us immediately at [email protected].

10. INTERNATIONAL DATA TRANSFERS

Frey & Co Holdings LLC is a US-registered entity operating internationally. Your personal information may be transferred to and processed in countries other than your own, including the United States and Thailand, where our operations are based. We take reasonable steps to ensure your data is protected in accordance with this Privacy Policy regardless of where it is processed.

If you are in the EEA or UK, transfers of your data outside those regions will be made in accordance with applicable data transfer mechanisms, including Standard Contractual Clauses where required.

11. CHILDREN’S PRIVACY

Our website and programme are intended for adults aged 18 and over. We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected such information, please contact us at [email protected] and we will delete it promptly.

12. THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal information.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last Updated” date at the top of this page. We encourage you to review this policy periodically. Your continued use of our website after changes are posted constitutes your acceptance of the updated policy.

14. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us at:

Frey & Co Holdings LLC
30/209 Moo 4, T. Bophut, Koh Samui
Surat Thani 84320, Thailand
Email: [email protected]
Phone: +61 4 9990 4035