Privacy Policy

Business: Alon Roth — The Spirit of Sales. Contact email: Alonroth11@gmail.com. WhatsApp: +972 52-896-6515. [Insert U.S. legal entity name, state of formation, EIN and mailing address — a physical postal address is required by the CAN-SPAM Act in every commercial email.]

In the last 12 months we have collected the following CCPA categories of personal information:

• Identifiers: name, email address, postal address, phone number, account ID, IP address and online identifiers.
• Customer records (Cal. Civ. Code § 1798.80): billing and shipping details, order history.
• Commercial information: products purchased or considered, program enrollment, referral and affiliate activity.
• Internet or network activity: pages viewed, features used, session and device data, browser type, referring URLs, email open and click data.
• Geolocation data: approximate location inferred from IP address (not precise geolocation).
• Audio, electronic and visual information: content you submit in the member area (posts, comments, progress entries) and messages you send us.
• Professional information: job title, company or sales role, where you choose to provide it.
• Inferences: preferences and interests derived from the above to personalize content.

We do not intentionally collect “sensitive personal information” as defined by the CCPA (such as Social Security numbers, precise geolocation, or account credentials combined with access codes beyond what is required to operate your account), and we do not use or disclose any such information for purposes requiring a “Limit the Use of My Sensitive Personal Information” link. Payment card numbers are collected and processed directly by our PCI-DSS compliant payment processor and are not stored by us.

• Directly from you (forms, purchases, account sign-up, messages).
• Automatically from your device through cookies, pixels and server logs.
• From third-party providers: authentication providers (such as Google Sign-In), payment processors, email delivery providers, hosting and analytics providers.

• To provide, operate, secure and support the Services and member area.
• To process orders, deliver purchases, and handle returns and refunds.
• To send transactional messages, and — consistent with the CAN-SPAM Act — commercial email that identifies itself as an advertisement, includes our physical postal address and provides a working one-click unsubscribe honored within 10 business days.
• To operate referral, affiliate and certification features you choose to use.
• To measure, analyze and improve the Services, and to detect and prevent fraud, abuse and security incidents.
• To comply with legal, accounting and tax obligations and to establish or defend legal claims.

We use cookies and similar technologies that are strictly necessary for the site to function (such as keeping you signed in), and may use analytics cookies to understand how the site is used. You can control cookies through your browser settings; disabling some cookies may affect site functionality. Because there is no uniform industry standard for responding to browser “Do Not Track” signals, we do not currently respond to them; where required by California and Colorado law, we do honor Global Privacy Control (GPC) opt-out preference signals as a request to opt out of sale/sharing. [Insert cookie list and consent banner details if analytics or advertising cookies are used.]

We disclose personal information for business purposes to service providers and contractors who process it on our behalf under written contracts, including hosting and database providers, authentication providers, email delivery providers, payment processors and analytics providers. We may also disclose information when required by law, subpoena or other legal process, to enforce our terms, to protect our rights or the safety of others, or in connection with a merger, acquisition or other business transfer.

We do not sell personal information, and we do not “share” personal information for cross-context behavioral advertising, as those terms are defined under the CCPA. We have not sold or shared the personal information of consumers, including minors under 16 years of age, in the preceding 12 months. [Re-confirm this statement if advertising pixels or ad-network tags are added to the site — that may constitute a “sale” or “share” and would require a “Do Not Sell or Share My Personal Information” link.]

We retain each category of personal information for as long as needed to provide the Services and for the periods required by U.S. federal and state law (for example IRS recordkeeping and state tax retention periods), after which it is deleted or de-identified. [Insert specific retention periods per category.]

Depending on your state of residence, you may have the right to:

• Know what personal information we collect, use and disclose.
• Access or obtain a portable copy of your personal information.
• Correct inaccurate personal information.
• Delete personal information, subject to legal exceptions.
• Opt out of sale, sharing or targeted advertising (we do none of these).
• Not be discriminated or retaliated against for exercising these rights.
• Appeal a denied request (Virginia, Colorado, Connecticut and certain other states).

To exercise a right, email Alonroth11@gmail.com with the subject line “Privacy Request.” We will verify your identity using the email address associated with your account or order and will respond within 45 days, extendable by an additional 45 days where permitted. An authorized agent may submit a request on your behalf with written permission. You can unsubscribe from marketing email at any time using the link in each email.

California “Shine the Light” (Cal. Civ. Code § 1798.83): we do not disclose personal information to third parties for their own direct marketing purposes.

Nevada (NRS 603A): Nevada residents may submit a request directing us not to sell certain covered information; we do not sell such information.

We use technical and organizational measures intended to protect personal information, including encryption in transit, access controls and authenticated member areas. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of unencrypted personal information occurs, we will notify affected individuals and, where applicable, state regulators in accordance with the applicable state breach notification statutes.

The Services are intended for adults and are not directed to children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it promptly. A parent or guardian who believes a child has provided us information may contact us at Alonroth11@gmail.com. We also do not knowingly sell or share the personal information of consumers under 16.

The Services are operated for a U.S. audience and personal information is processed and stored in the United States. If you access the Services from outside the U.S., you understand that your information will be transferred to and processed in the United States, where data protection laws may differ from those of your country. [If the business knowingly targets EU/UK or Israeli users, have counsel add GDPR/UK GDPR and Israeli Privacy Protection Law disclosures.]

We may update this Privacy Policy from time to time. The “last updated” date above reflects the latest version. Where a change is material, we will provide notice as required by applicable state law. Under the CCPA, this Policy is reviewed and updated at least once every 12 months.

Questions about this Policy or your personal information: Alonroth11@gmail.com. [Insert U.S. mailing address and toll-free number if the business meets the CCPA threshold requiring a toll-free contact method.]