Privacy Policy

Last Updated: [Insert Date]

IntoGreation LLC (“IntoGreation,” “our,” “us,” or “we”) is committed to protecting the privacy and security of the information of our website visitors and users. We want you to understand how we collect and use information from our website, mobile application (if applicable), and portal (the “Platform”) and through offering our services (together with the Platform, the “Services”). By using the Services, you accept and agree to the practices this Privacy Policy (this “Policy”) describes.

Important Notice Regarding Our Services

IntoGreation is not a healthcare provider or licensed clinical service. The Services do not constitute and are not intended to provide medical advice, diagnosis, treatment, therapy, counseling, or any other licensed health service. The Services are limited to facilitating access to independent, third-party coaches, guides, and other facilitators who provide coaching for lifestyle improvements, overall well-being, and achieving personal goals, as well as personal development, educational, integration, and experiential services. These services are not a substitute for professional medical care, mental health treatment, or licensed therapeutic intervention. If you have a medical or mental health concern, please consult a qualified healthcare professional. By using the Services, you acknowledge and agree to this limitation.

“Personally identifiable information,” as used in this Policy, is information that specifically identifies an individual, such as an individual’s name, address, telephone number, e-mail address, or other similar information that can be used to identify you. Personally identifiable information also includes information about an individual’s activity on our Services, including profile information and other identifiable information entered by you. Your activity information and personally identifiable information are collected referred to in this Policy as “Your Information”.

What Information Do We Collect?

When you use our Services, we may collect and use Your Information as well as other non-individually identifiable information. To participate in certain features of the Services, you may be required to provide certain personal information. For example, when registering as a user for the Services, we may ask for your name, e-mail address, birth date, mailing address, zip code, phone number, credit card information or other personal information. We may also collect information that you provide directly to use by voluntarily filling in forms on the Platform, including transactional information or customer service information.

Service-Category and Interest Information. When a User indicates the service categories or types of offerings in which the User is interested, that information may reveal sensitive interests.

Service Provider Information. For Service Providers, IntoGreation collects business and professional information provided at onboarding, including identity and contact details, biography, professional background and experience, credential and licensure information, jurisdiction of practice, insurance information, and tax identification information required for payment and tax reporting (such as IRS Forms W-9 or W-8). Certain profile information provided by Service Providers—including name, biography, professional background, and credentials—is displayed publicly on the Platform so that Users can evaluate them.

Payment and Tax Information

Payment card information is collected and processed directly by Stripe and is not stored by IntoGreation. IntoGreation collects and retains tax identification and payout information for Service Providers as required to comply with tax reporting and information-reporting obligations and retains it for the periods required by applicable tax and recordkeeping law.

When you browse our Platform or use any of our Services, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. We may also use “cookies” and other tracking technologies to enhance your experience and gather information about our Platform visitors. Please see the section below called “How We Use Cookies” to learn more.

How Do We Use Your Information?

We may use Your Information we collect from when you use the Services in the following ways:

• To present our Services and content to you;
• To provide you with information that you request from us;
• To notify you about changes in the Services we offer;
• To allow you to participate in in any interactive features on the Services;
• To personalize your Services;
• To contact you when necessary or requested;
• To process transactions, including payments made by you;
• To verify and validate your identity;
• To the extent you have not opted out of receiving marketing communications, to send you information about IntoGreation or our Services, including by letter, email, text, telephone, or other forms of communication;
• To the extent you have not opted out of receiving marketing communications, to provide you with information about third-party businesses, products, and services, including by letter, email, text, telephone, or other forms of communication;
• To troubleshoot problems with the Services, as requested;
• To enforce the Terms of Use, and to detect and protect against error, fraud, and other unauthorized or illegal activities;
• To operate and improve the Services available through us;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Your Information held by us about our consumers is among the assets transferred.

Third-Party Marketing Opt-Out. If you do not wish to receive marketing communications from third-party businesses or have Your Information disclosed to third-party businesses for their own marketing purposes, you may opt out by providing written notice to IntoGreation, using the “Do Not Sell or Share My Personal Information” link in the Platform footer, or sending an opt-out preference signal as described in the California section. To opt out by written notice, send a written request to the address or email address set forth in the “Contacting Us” section with the subject line “Third-Party Marketing Opt-Out.” We will process written requests within fifteen (15) business days of receipt. Opt-out preference signals and requests submitted through the link will be honored within fifteen (15) business days. Exercising any of these opt-out routes will stop the disclosure of Your Information to third-party businesses for their own marketing purposes.

How We Use Cookies

A “cookie” is a small computer file that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies and similar technologies may store user preferences and other information. We use cookies and similar technologies in the following categories: (i) strictly necessary cookies, which support the operation and security of the Platform; (ii) functional cookies, which remember preferences and enable features; (iii) analytics cookies, which help us understand how visitors use the Platform and improve the Services; and (iv) advertising or marketing cookies, which may be used to deliver or measure advertising or marketing. Some features may not function properly if non-essential cookies or similar technologies are declined.

A “pixel tag” is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies. Other similar technologies may include tags and software development kits (“SDKs”). Third-party analytics and advertising providers may set their own cookies, pixels, tags, or SDKs through the Platform and may receive information about your device and activity on the Platform. These providers may use the information in accordance with their own privacy policies. IntoGreation does not itself track users across websites or over time through its own first-party cookies or similar technologies, but third-party providers may collect information as described above, including for cross-context behavioral advertising.

Where required by applicable law, IntoGreation will obtain your consent through a cookie banner or similar consent mechanism before setting non-essential cookies or using non-essential tracking technologies. You may withdraw or change your consent at any time through that mechanism. You may also control cookies through your browser settings, although declining or disabling cookies may affect the functionality of the Platform. To the extent permitted by applicable law, your continued use of the Platform after you have been presented with the consent mechanism, together with any consent given through it, constitutes consent to the tracking described in this section.

Session Content Handling

When you have a session with a Service Provider through the Platform, including video, audio, or messaging communications, please be aware of the following practices regarding session content:

• Chat Communications. The messaging feature is intended solely for scheduling and administrative logistics relating to booked sessions. Users should not share sensitive personal, health, medical, or financial information through it. Messages are monitored and may be reviewed by IntoGreation for compliance, safety, and enforcement purposes, including detecting the exchange of personal contact information or attempts to circumvent the Platform. Messages are retained only for a limited period appropriate to those purposes and are then deleted or anonymized, except where IntoGreation must retain them longer to investigate a complaint or allegation, to resolve a dispute, or to comply with legal obligations. The applicable period is described in IntoGreation’s retention practices.
• No Recording by IntoGreation. IntoGreation does not record video or audio sessions between Users and Service Providers.
• Recording by Users and Service Providers. Users and Service Providers may independently choose to record their own sessions. IntoGreation is not responsible for any recordings made by Users or Service Providers, and any such recording is subject to the consent of all parties and applicable law. You are responsible for complying with all applicable laws regarding the recording of conversations in your jurisdiction.

“Do Not Track” Request

Legacy browser “Do Not Track” (“DNT”) signals do not have a common industry standard, and IntoGreation does not currently respond to them. However, IntoGreation recognizes and honors opt-out preference signals, including the Global Privacy Control (“GPC”), as described in the “Opt-Out Preference Signals and Global Privacy Control” subsection of the California section. IntoGreation also honors the cookie and tracking preferences you set through the consent mechanism described in the “How We Use Cookies” section.

How Do We Share Your Information?

IntoGreation does not sell Your Information for money. However, its disclosure of personal information to third-party businesses for those businesses’ own marketing purposes, and its use of third-party advertising and analytics technologies for cross-context behavioral advertising, may constitute a “sale” or “sharing” of personal information as those terms are broadly defined under California law and certain other state privacy laws. Users have the right to opt out of that sale or sharing as described in the California section.

We may also disclose Your Information as follows:

• With contractors, service providers, and other third-parties we use to support our business, including to facilitate payments made by you;
• To fulfil the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Your Information held by us about the Platform users is among the assets transferred;
• To enforce any agreement, including any applicable terms of service;
• To establish or exercise our right to defend against legal claims;
• To law enforcement and other government authorities such as legislatures, courts, agencies and litigants if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of governmental authorities; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) protect the security or integrity of the Services’ information systems; and/or (e) exercise or protect our rights, privacy, safety or those of affiliates, clients, you or others; and
• If we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of IntoGreation or others.

How Do We Protect Your Information?

To protect Your Information, we take commercially reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. However, no data protection procedures are entirely infallible. As a result, while we strive to protect Your Information, we cannot guarantee that it will be 100% secure. Your transmission of your data to our Platform thus is done entirely at your own risk.

Data Retention

Unless you request deletion, we retain Your Information for as long as your account is active, as needed to provide the Services, to comply with our legal obligations (including tax, accounting, and recordkeeping requirements), to resolve disputes, and to enforce our agreements, which retention period may vary based on jurisdiction and the purpose for retention. The criteria used to determine retention periods include the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, applicable legal and regulatory requirements; provided that, if required by applicable law, we shall not retain Your Information for longer than is reasonably necessary. If you request deletion of your account or Your Information, we will delete or anonymize Your Information, unless we are required to retain it for legal, regulatory, or legitimate business purposes. Usage data and analytics may be retained in anonymized or aggregated form for longer periods to improve our Services. You may contact us at the address or email address set forth in the “Contacting Us” section with questions about our data retention practices.

Data Breach Notification

In the event of a data breach that compromises the security, confidentiality, or integrity of Your Information, we will notify affected users in accordance with applicable law. If we determine that a breach has occurred that is likely to result in harm to you, we will notify you without unreasonable delay and, where required by law, within the applicable time periods specified (such as within seventy-two (72) hours under the General Data Protection Regulation (GDPR) or as required by California law). Notification may be provided by email to the address associated with your account, by posting a notice on our Platform, or by other means as required by law. The notification will describe the nature of the breach, the types of information involved, the steps we are taking to address the breach, and recommendations for actions you can take to protect yourself.

Third-Party Websites

The Platform may contain links to other websites, including those of third parties or business partners. While we seek to link only to websites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use. By accessing other third-party websites or applications through our Service, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect information about your online activities over time and across different websites when you use our Service.

Age of Consent

Only individuals eighteen (18) years of age or older are authorized to use the Service on their own behalf. Any parenting or family-related Services are provided only to the adult User and not to any minor. We do not knowingly collect information directly from children under the age of eighteen (18). If you have reason to believe that an individual under the age of eighteen (18) has provided personal information to us through the Service, please contact us, and we will endeavor to delete that information from our databases.

California Visitors

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of Your Information to third parties for their direct marketing purposes. To make such a request, please send an email to the email address set forth in the “Contacting Us” section.

Your California Privacy Rights Under the CCPA

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide you with specific rights regarding Your Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know. You have the right to request that we disclose certain information to you about our collection and use of Your Information over the past twelve (12) months. Once we receive and verify your request, we will disclose to you: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information; and the specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request that we delete any of Your Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

Right to Opt-Out of Sale or Sharing. You have the right to opt out of the sale or sharing of Your Information, including the sale or sharing of personal information for cross-context behavioral advertising. You may exercise this right by using the clearly labeled “Do Not Sell or Share My Personal Information” link available in the Platform footer, using the cookie and tracking preferences mechanism described in the “How We Use Cookies” section to opt out of advertising technologies, emailing us at the email address set forth in the “Contacting Us” section, or writing to us at the address set forth in the “Contacting Us” section. We do not require you to have an account to submit an opt-out request, and we will not require you to verify your identity to submit one. An authorized agent may submit an opt-out request on your behalf. We will honor opt-out requests within fifteen (15) business days. If you later consent to the sale or sharing of Your Information, we will treat that as a new consent, and your prior opt-out will no longer apply.

Opt-Out Preference Signals and Global Privacy Control. IntoGreation recognizes and honors opt-out preference signals, including the Global Privacy Control (“GPC”), transmitted by your browser or device or by an authorized platform, extension, or plug-in. When we receive such a signal, we will treat it as a valid request to opt out of the sale and sharing of personal information for the browser or device from which it is sent and, where you are logged in to an account, will apply the opt-out to that account as well. Because such signals are browser- and device-specific, you must enable the signal on each browser and device you use, and clearing cookies may require you to re-enable it. IntoGreation will not interpret the presence or absence of such a signal as consent to the sale or sharing of personal information. IntoGreation does not charge a fee, degrade service, or otherwise discriminate against users who send an opt-out preference signal. See “Right to Non-Discrimination.”

Notice of Categories of Personal Information Sold or Shared. The categories of personal information that IntoGreation may sell or share include: (a) identifiers, such as your name, email address, and postal address; (b) commercial information; (c) internet or other electronic network activity information, including browsing and interaction data collected through cookies, pixels, and similar technologies; and (d) inferences drawn from that information. The categories of third parties to whom these categories may be sold or shared are third-party marketing partners, advertising networks and platforms, and analytics providers. IntoGreation does not sell or share sensitive personal information and does not sell or share the personal information of consumers it actually knows to be under eighteen (18) years of age.

Right to Limit Use and Disclosure of Sensitive Personal Information. The sensitive personal information IntoGreation collects includes information revealing your service-category interests and preferences to the extent those interests or preferences reveal health-related interests, and precise account credentials, where applicable. IntoGreation uses and discloses sensitive personal information only for purposes permitted under the CPRA: to perform the Services you request, to facilitate connections with Service Providers, to prevent and investigate fraud and security incidents, to verify and maintain the quality of the Services, and to comply with legal obligations. IntoGreation does not use or disclose sensitive personal information to infer characteristics about you or for cross-context behavioral advertising. Because IntoGreation limits its use and disclosure of sensitive personal information to these permitted purposes, it is not required to offer a separate right to limit such use or disclosure. Nevertheless, IntoGreation will honor a request to limit the use and disclosure of sensitive personal information. You may submit a request using the same contact methods described in the “Contacting Us” section by emailing us at the email address set forth in the “Contacting Us” section or by using a clearly labeled “Limit the Use and Disclosure of My Sensitive Personal Information” link on the Platform. See “Right to Non-Discrimination.”

Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Rights. To exercise the rights described above, please submit a verifiable consumer request to us by emailing us at the email address set forth in the “Contacting Us” section. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to Your Information. You may also make a verifiable consumer request on behalf of your minor child. We will respond to verifiable consumer requests within forty-five (45) days of receipt.

Information for Users in the European Union and United Kingdom (GDPR)

If you are located in the European Union (“EU”) or United Kingdom (“UK”), the GDPR and UK GDPR provide you with certain rights regarding Your Information. This section supplements our Privacy Policy with information specific to EU and UK users.

Data Controller. IntoGreation LLC is the data controller responsible for Your Information processed through the Services. Its legal name is IntoGreation LLC, and its address and data protection email address are set forth in the “Contacting Us” section below. IntoGreation is established in the United States and processes the personal data of individuals in the EU and UK in connection with offering the Services to them. IntoGreation has appointed a representative in the EU under Article 27 of the GDPR: [EU Representative Name], with contact details at [EU Representative Contact Details].

Lawful Basis for Processing. We process Your Information based on one or more of the following lawful bases: (a) your consent, which you may withdraw at any time; (b) the performance of a contract with you, including providing you access to our Services; (c) compliance with our legal obligations; and (d) our legitimate interests, such as improving our Services, preventing fraud, and ensuring the security of our Platform, provided such interests are not overridden by your data protection rights.

Right to Withdraw Consent. Where IntoGreation relies on your consent as the lawful basis for processing, you may withdraw that consent at any time by contacting IntoGreation at the address or email address set forth in the “Contacting Us” section. For cookies and tracking technologies, you may withdraw or change your consent by using the consent mechanism described in the “How We Use Cookies” section. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. When you withdraw consent, IntoGreation will cease the processing that relied on that consent unless another lawful basis applies; if another lawful basis applies, we will inform you of that basis. See “How We Use Cookies.”

Your Data Subject Rights. Under the GDPR, you have the following rights: the right to access your personal data; the right to rectification of inaccurate data; the right to erasure (“right to be forgotten”); the right to restrict processing; the right to data portability; the right to object to processing; and rights related to automated decision-making and profiling. To exercise any of these rights, please contact us at the email address set forth in the “Contacting Us” section.

Automated Decision-Making and Profiling. IntoGreation does not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. The Platform may use automated features to organize, sort, filter, or surface Service Provider listings and content based on the service categories, preferences, or search criteria you provide and to display relevant content. These features are intended to help you find and evaluate independent Service Providers. You retain full discretion over whether to engage any Service Provider, and no automated feature selects a Service Provider for you or makes any decision on your behalf. IntoGreation does not use automated processing to evaluate your health, personality, or behavior in order to make decisions about you. You may contact IntoGreation for more information about these features and may object to processing based on legitimate interests as described in the “Your Data Subject Rights” subsection.

International Data Transfers. Our Services are hosted and operated in the United States. If you are accessing our Services from the EU or UK, Your Information will be transferred to, stored, and processed in the United States, which may not provide the same level of data protection as your home jurisdiction. We rely on appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, to ensure that Your Information is protected when transferred outside the EU or UK. By using our Services, you acknowledge and consent to this transfer. You may contact us to request more information about the safeguards we use for international data transfers.

Right to Lodge a Complaint. If you believe that we have violated your rights under the GDPR, you have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or the place of the alleged violation.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Platform. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

Contacting Us

We welcome any questions, comments, or complaints you have may have regarding this Privacy Policy. Please do not hesitate to contact us at:

Address: [Insert Address]
Email: team@intogreation.com

You may also reach us through the support form.