PRIVACY POLICY
Effective Date: July 16, 2025
Last Updated: July 16, 2025

Mariela Wellness LLC DBA Wellness by Mariela ("Company," "we," "us," or "our") is committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you visit our websites (www.wellnessbymariela.com, www.transformationvault.com, www.after35podcast.com) or use our platforms, services, products, courses, coaching, memberships, newsletters, blogs, podcasts, or any related offerings (collectively, the "Services").

This Policy applies to all users of our Services, including visitors, subscribers, members, and purchasers. By accessing or using our Services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. If you do not agree, you must immediately discontinue use of the Services and refrain from providing any personal information.

We reserve the right to modify this Privacy Policy at any time. Changes will be effective immediately upon posting the updated Policy on our websites, with the "Last Updated" date revised accordingly. Your continued use of the Services after any changes constitutes your acceptance of the updated Policy. It is your responsibility to review this Policy periodically for changes.

1. INFORMATION WE COLLECT
   We collect information in the following categories to provide, improve, and secure our Services. We only collect what is necessary and with your consent where required.
2. Personal Information You Provide
   We collect personal data that you voluntarily provide when interacting with our Services, such as when you:

• Register for an account, subscribe to newsletters, promotions, or updates;
• Purchase or enroll in products, courses, coaching, memberships, or services;
• Contact us via forms, email, phone, chat, or support tickets;
• Participate in community discussions, forums, surveys, webinars, Q&As, or promotions;
• Submit user-generated content, testimonials, or feedback;
• Voluntarily share health-related information during coaching, courses, or interactions.

The types of personal information we may collect include:

• Identifiers: Full name, email address, mailing address, phone number, username, or similar identifiers.
• Payment Information: Billing details, credit/debit card numbers, or other financial information (processed securely via third-party processors like Stripe, PayPal, and Kajabi Payments—we do not store full payment details).
• Health-Related Data: Any voluntarily provided information about your health, wellness goals, dietary preferences, or medical conditions (e.g., during coaching or surveys). Note: We are not a healthcare provider, and such data is collected only with your explicit consent for educational purposes. It is not used for diagnosis or treatment.
• Commercial Information: Purchase history, preferences, and interactions with our Services.
• Other Information: Any additional data you provide, such as survey responses, feedback, or communications.

1. Information Collected Automatically
   We do not currently use cookies, web beacons, pixels, or similar tracking technologies to collect browsing data, IP addresses, device information, or geolocation data. If we implement such technologies in the future, we will update this Policy and obtain consent where required by law. However, our third-party service providers (e.g., analytics tools) may collect limited automatic data, such as:

• Usage Data: Pages visited, time spent, and interactions (e.g., via Google Analytics or Facebook Pixel).
• Device Information: Browser type, operating system, and device identifiers (anonymized where possible).

1. Information from Third Parties
   We may receive information about you from third-party sources, including:

• Payment Processors: Transaction details from Stripe, PayPal, or Kajabi Payments.
• Analytics and Marketing Providers: Aggregated usage data from Google Analytics, Facebook Pixel, or similar services.
• Social Media Platforms: If you interact with us on platforms like Facebook, Instagram, TikTok, or X, we may receive public profile information or engagement data.
• Affiliates or Partners: Referral data if you arrive via an affiliate link.

We do not purchase or collect data from data brokers or unrelated third parties.

2. HOW WE USE YOUR INFORMATION
   We use your information solely for legitimate business purposes, including:

• Providing and Improving Services: To deliver courses, coaching, memberships, newsletters, podcasts, and other content; process transactions; and personalize your experience.
• Communications: To send transactional emails (e.g., order confirmations), newsletters, updates, promotions, or support responses. You may opt out of marketing communications at any time (see Section 4).
• Analytics and Optimization: To analyze usage patterns, improve content, and enhance user experience (e.g., via aggregated data).
• Customer Support: To respond to inquiries, resolve issues, and provide assistance.
• Legal and Security: To comply with legal obligations, prevent fraud, enforce our terms, and protect against misuse or security threats.
• Health-Related Data: If voluntarily provided, used only for educational or coaching purposes (e.g., tailoring wellness advice). We do not use it for medical diagnosis, treatment, or automated decision-making.

We process information based on: (i) your consent (e.g., for newsletters or health data); (ii) contractual necessity (e.g., fulfilling purchases); (iii) legitimate interests (e.g., improving Services); or (iv) legal requirements.

3. HOW WE SHARE YOUR INFORMATION
   We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share information in limited circumstances:

• Service Providers: With trusted vendors who assist in operating our Services, such as payment processors (Stripe, PayPal, Kajabi Payments), hosting platforms (Kajabi, Buzzsprout), analytics providers (Google Analytics, Facebook Pixel), email services (e.g., Mailchimp), or marketing tools. These providers are contractually obligated to use your data only for our purposes and maintain confidentiality.
• Affiliates and Partners: For joint promotions or referrals, with your consent.
• Legal Compliance: If required by law, subpoena, court order, or regulatory authority; to enforce our terms; or to protect our rights, users, or the public (e.g., fraud prevention).
• Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of the transaction, subject to equivalent privacy protections.
• Aggregated/Anonymized Data: We may share non-personal, aggregated data (e.g., usage statistics) for research, marketing, or analytics purposes.

For health-related data, we share it only with your explicit consent and limit it to necessary service providers (e.g., coaching platforms). We do not share it with advertisers or unrelated third parties.

4. YOUR RIGHTS AND DATA CONTROL
   We respect your privacy rights and provide tools to manage your data. Depending on your location (e.g., under CCPA/CPRA for California residents or similar state laws), you may have the following rights:

• Access: Request details about the personal information we hold about you.
• Correction: Update or rectify inaccurate or incomplete information.
• Deletion: Request removal of your data (subject to legal retention requirements, e.g., for transactions).
• Opt-Out of Sale/Sharing: We do not sell your data, but you may opt out of any sharing for targeted advertising.
• Opt-Out of Marketing: Unsubscribe from promotional communications via the "unsubscribe" link in emails or by contacting us. Transactional messages (e.g., order confirmations) will continue.
• Non-Discrimination: We will not discriminate against you for exercising your rights.
• Sensitive Data: For health-related data, you may limit its use or request its deletion at any time.

To exercise these rights, submit a verifiable request to [email protected]. We will respond within 30-45 days (extendable by law). For California residents, you may designate an authorized agent. We may require identity verification to protect your data.

5. SECURITY MEASURES
   We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, loss, misuse, alteration, or destruction, including:

• Encryption: For sensitive data in transit (e.g., SSL/TLS) and at rest (e.g., payment details via processors).
• Access Controls: Limited to authorized personnel with confidentiality agreements.
• Regular Audits: Security reviews, vulnerability scans, and updates to our systems.
• Incident Response: Procedures to detect, respond to, and notify of data breaches as required by law (e.g., under Florida's data breach notification laws).

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and using secure practices when sharing information.

6. DATA RETENTION
   We retain your personal information only as long as necessary to fulfill the purposes outlined in this Policy, including for the duration of your account or membership, to provide Services, comply with legal obligations (e.g., tax records for 7 years), resolve disputes, or enforce agreements. When no longer needed, we securely delete or anonymize data. For example:

• Transaction data: Retained for 7 years for legal/compliance reasons.
• Account data: Retained while active; deleted upon request or inactivity (after 2 years).
• Health-related data: Retained only during active coaching/membership; deleted upon completion or request.

7. THIRD-PARTY LINKS AND SERVICES
   Our Services may contain links to third-party websites, apps, or services (e.g., social media platforms, affiliate links). We are not responsible for the privacy practices, content, or security of these third parties. Clicking on such links is at your own risk, and we encourage you to review their privacy policies before providing any information. We do not endorse or control third-party content.
8. CHILDREN’S PRIVACY
   Our Services are not intended for or directed to individuals under the age of 18 (or 13 in some jurisdictions). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such data, we will promptly delete it. If you believe a child has provided us with personal information, contact us immediately at [email protected]. We comply with the Children's Online Privacy Protection Act (COPPA) and do not engage in practices that require parental consent.
9. INTERNATIONAL USERS
   Our Services are hosted and operated in the United States and primarily intended for US residents. If you access our Services from outside the US (e.g., EU/UK), your information may be transferred to, stored, and processed in the US, where data protection laws may differ from those in your jurisdiction (e.g., GDPR). By using our Services, you consent to such transfer and processing. For EU/UK users, we provide equivalent rights (e.g., access, deletion) and process data based on consent or legitimate interests. Contact us for details on international transfers.
10. DISPUTE RESOLUTION AND GOVERNING LAW
    This Privacy Policy and any disputes arising from or related to it or our Services shall be governed exclusively by the laws of the State of Florida, United States, without regard to conflict of law principles.

You agree to first attempt to resolve any disputes through good-faith mediation in Florida, with costs shared equally. If mediation fails, disputes shall be resolved through binding arbitration in Florida under the rules of the American Arbitration Association (AAA), rather than in court. Arbitration shall be conducted on an individual basis only—no class actions, consolidated actions, or representative proceedings. The arbitrator's decision shall be final and enforceable in any court of competent jurisdiction. You waive any right to a jury trial or participation in class actions.

11. SEVERABILITY
    If any provision of this Privacy Policy is held invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be reformed to the minimum extent necessary to make it valid and enforceable, reflecting the original intent.
12. CONTACT INFORMATION
    For questions, concerns, rights requests, or to report a potential breach regarding this Privacy Policy, please contact our Privacy Officer at:
    Mariela Wellness LLC DBA Wellness by Mariela
    Email: [email protected]
    Mailing Address: 3118 Cortona Dr., Melbourne, FL 32940
    Phone: 321.338.2167

By continuing to use our Services, you affirm that you have read, understood, and consent to this Privacy Policy in its entirety. If you do not consent, you must cease use immediately.