Privacy Policy

Last updated September 2026

Who we are

This website, tarjastephens.com, is operated by TLS Holdings, LLC, United States, which is the data controller for the personal data described in this policy. You can reach us at info@tarjastephens.com or by post at TLS Holdings, LLC, 13056 NW 14th St, Pembroke Pines, FL 33028, United States.

What this website collects

This website uses one analytics service, Google Analytics, and only if you accept it in the cookie notice shown on your first visit. Nothing else tracks you here: there is no advertising pixel, no registration, no user accounts, no newsletter signup and no payment processing on this site.

The only personal data collected through the site is what you choose to send through the contact form: your name, your email address, the topic you select and the message you write. Sending the form is voluntary. If you prefer not to use the form, you can email us directly.

Like every website, this site is served by a hosting provider whose servers keep standard technical logs, such as the IP address that requested a page and the time of the request. Those logs exist for security and to keep the service running. We do not use them to identify or profile visitors.

Cookies and analytics

When you accept analytics, Google Analytics sets two cookies in your browser, named _ga and _ga_ followed by an identifier. They last up to two years and let the service tell one visitor from another. What we see is aggregated: which pages are read, how visitors arrive, roughly where they are and which kind of device they use. Google Analytics 4 does not log or store IP addresses, and we have not enabled advertising features or user-level identifiers. Google LLC processes this data on our behalf under its data processing terms, including on servers in the United States under the EU-US Data Privacy Framework. Analytics data is kept for 14 months and then deleted automatically.

If you decline, no analytics code loads and no analytics cookie is set. Your choice itself is remembered in your browser so that the notice does not return on every page, and you can change it at any time through the "Cookie settings" link in the footer of every page.

Why we process your data and on what basis

We use the details you send through the contact form for one purpose: to read and answer your message, and to continue the conversation you started, for example about a speaking invitation, an advisory engagement or a program.

Under the EU and UK General Data Protection Regulation, the legal basis for this is our legitimate interest in responding to people who contact us, and, where a conversation leads to an agreement, the steps needed to enter into that agreement.

How long we keep it

Messages sent through the contact form are delivered to our email inbox. We keep them for as long as needed to handle your enquiry and any follow-up, and no longer than 24 months after our last exchange, unless a working relationship follows or the law requires us to keep records for longer.

Who receives your data

We do not sell, rent or trade personal data. Your message is handled by the service providers we use to run the site and our email: our web hosting provider, which delivers the form, and our email provider, which stores our inbox. These providers process data on our behalf under their own contractual and security commitments. If you accept analytics, Google LLC receives the analytics data described above, also as a processor on our behalf.

We will disclose information if required or permitted by law, for example to comply with a subpoena or a similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to a government request.

International transfers

Tarja Stephens works between Finland and the United States. Messages you send may therefore be read and stored in the United States as well as in the European Union. Where data leaves the European Economic Area or the United Kingdom, we rely on the safeguards recognised by the applicable data protection law, such as the European Commission's standard contractual clauses used by our providers.

Your rights

If you are in the European Economic Area or the United Kingdom, you have the following rights regarding your personal data:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision-making and profiling. This website makes no automated decisions about you.

You also have the right to lodge a complaint with your national data protection authority.

If you are a California resident, you have the right to know what personal information we collect and how we use it, the right to request its deletion, and the right not to be discriminated against for exercising those rights. We do not sell or share personal information as those terms are defined in California law.

To exercise any of these rights, email info@tarjastephens.com. We will respond within the time the law allows, normally within one month.

Information security

We keep reasonable administrative, technical and physical safeguards to protect the information you send us against unauthorised access, use, modification or disclosure. The site is served over an encrypted connection. No transmission over the internet can be guaranteed to be completely secure, so please do not send sensitive information through the contact form.

Links to other websites

This site links to other websites, including the sites of Career Ventures, Career Twin and Leaders of the Future, and to social platforms. We are not responsible for the privacy practices of those websites. Please read their privacy statements when you visit them.

Children

This website is intended for professionals and is not directed at children under 16. We do not knowingly collect personal data from children.

Changes to this policy

If we add any other analytics or tracking to this site, we will update this policy first and change the date at the top. The current version is always available at tarjastephens.com/privacy/.

Contact

Questions about this policy or about your personal data: info@tarjastephens.com.