Privacy Policy — EmpowerSync LLC (Lionel Moses)

1. Information We Collect

1.1 Information You Provide

We may collect information that you voluntarily provide, including:

• Your name;
• Email address;
• Telephone or mobile phone number;
• Billing address and mailing address;
• Account or registration information;
• Purchase and order information;
• Information submitted through forms, surveys, questionnaires, or support requests;
• Questions, comments, testimonials, or other content you voluntarily submit;
• Information provided when you request customer service; and
• Any other information you choose to provide.

Please do not submit confidential, highly sensitive, or unnecessary personal information through forms, question submissions, or other website features.

1.2 Payment Information

Payments are processed through third-party payment processors, including Stripe or another payment processor made available at checkout. Full payment-card information is transmitted directly to the applicable payment processor and is not stored on our servers.

Payment processors may collect, use, and retain payment information in accordance with their own privacy policies and legal obligations. We may receive limited payment-related information, such as transaction status, payment method type, billing information, and the last four digits of a payment card.

1.3 Information Collected Automatically

When you visit or use our website, we and our service providers may automatically collect information such as:

• Internet Protocol ("IP") address;
• Device type and operating system;
• Browser type and language;
• Pages viewed and links clicked;
• Referring and exit URLs;
• Dates and times of visits;
• Approximate geographic location derived from IP address;
• Website and product usage information; and
• Other technical, diagnostic, and usage information.

We use this information to operate, secure, analyze, and improve the website and our services.

2. How We Use Personal Information

We may use personal information to:

• Provide, administer, and improve our products and services;
• Process registrations, purchases, payments, orders, and downloads;
• Provide access to live or on-demand training and related materials;
• Send transactional communications, including confirmations, receipts, access information, account notices, and support responses;
• Send marketing communications by email and, where separately authorized, SMS or text message;
• Respond to questions, requests, and customer-support inquiries;
• Personalize website content, communications, and user experiences;
• Understand website traffic, engagement, and purchasing activity;
• Maintain the security and integrity of our systems;
• Detect, investigate, and prevent fraud, abuse, unauthorized access, and other unlawful activity;
• Enforce our agreements and protect our rights, property, and users;
• Comply with applicable legal, tax, accounting, and regulatory obligations; and
• Fulfill any other purpose disclosed at the time information is collected or otherwise permitted by law.

3. Email and SMS Marketing Consent

3.1 Email Communications

When you provide your email address, you may receive transactional emails necessary to provide products or services. Where you provide marketing consent or otherwise lawfully subscribe, you may also receive promotional emails, educational content, offers, and updates.

Every marketing email includes an unsubscribe link. You may withdraw email marketing consent at any time by clicking the unsubscribe link in the applicable email or by contacting support@lionelmoses.com.

3.2 SMS or Text Messages

Transactional Text Messages. If you provide a mobile telephone number in connection with a purchase, registration, or account, you consent to receive transactional text messages from EmpowerSync LLC at the number provided. Transactional messages relate directly to a transaction or service you have requested, such as order confirmations, receipts, access links, delivery information, appointment or access reminders, account notices, and customer-support responses.

Marketing Text Messages. We send marketing or promotional text messages only where you have separately opted in by affirmatively agreeing to receive them. If you provide that separate opt-in, you consent to receive automated marketing text messages from EmpowerSync LLC at the number provided. Marketing consent is not a condition of purchasing any product or service. Message and data rates may apply. Message frequency varies.

You may:

• Reply STOP to cancel or withdraw SMS consent;
• Reply HELP for assistance; or
• Contact support@lionelmoses.com to revoke consent or request assistance.

After you reply STOP, you may receive one final confirmation message. You will not receive further marketing text messages unless you provide new consent.

Withdrawing consent does not affect the lawfulness of processing that occurred before consent was withdrawn. You may continue to receive necessary transactional communications related to purchases, accounts, security, or services where permitted by law.

3.3 How We Contact You (Sending Domain)

Our transactional and marketing emails are sent from our dedicated sender domain, go.empowersync.org. This domain is an email-sending domain only and is not a data-collection surface or a website; it does not host any registration forms, landing pages, or checkout pages, and no personal information is collected through it. Links in our emails direct you to the applicable Site, where any information collection is governed by this Privacy Policy. Note that go.empowersync.org is a sending subdomain used only to transmit email and is distinct from empowersync.org, which is a Site covered by this Privacy Policy; the two serve different roles, and this section applies only to the sending subdomain.

4. Cookies, Pixels, and Analytics

We and our service providers may use cookies, pixels, tags, scripts, web beacons, and similar technologies to:

• Operate and secure the website;
• Remember preferences and activity;
• Maintain sessions and shopping-cart functionality;
• Measure traffic and engagement;
• Understand how visitors use the website;
• Improve website performance and content;
• Evaluate marketing effectiveness; and
• Support advertising, audience measurement, or personalization where permitted by law.

Third-party analytics and advertising providers may receive information about your device, browser, IP address, pages viewed, and website activity when their technologies are enabled.

You can manage or disable cookies through your browser settings. You may also be able to use device-level privacy controls or available cookie-preference tools. Disabling cookies may affect website functionality, registration, checkout, downloads, or other features.

5. Third-Party Service Providers and Data Processors

We use third-party service providers to operate our business and provide products and services. These providers may process personal information on our behalf or, depending on their role and applicable law, may process information as independent controllers under their own privacy terms.

Our providers may include:

• GoHighLevel: Funnel pages, registration forms, customer relationship management, email delivery, SMS delivery, and related automation;
• WebinarJam: Live and on-demand training delivery, registration management, access administration, and related communications;
• Stripe: Payment processing, payment security, fraud prevention, and transaction administration; and
• Email service providers: Transactional email, marketing email, list management, delivery, suppression, and engagement measurement.

These providers may store or process information in the United States or other countries. Their handling of information is also governed by their own privacy policies and terms. We encourage you to review the privacy information published by any third-party service you use.

We may also disclose personal information to:

• Professional advisers, such as attorneys, accountants, insurers, and auditors;
• Government authorities, courts, law-enforcement agencies, or regulators when required or permitted by law;
• Successors or transaction participants in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction; and
• Other parties with your direction or consent.

We do not disclose personal information to third parties except as described in this Privacy Policy, as disclosed at the time of collection, or as otherwise permitted by law.

6. Data Retention

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

• Provide products and services;
• Maintain business and transaction records;
• Process payments and fulfill orders;
• Communicate with you;
• Resolve disputes;
• Enforce agreements;
• Prevent fraud and protect security; and
• Comply with legal, tax, accounting, and regulatory requirements.

Marketing information is generally retained until you withdraw marketing consent or request deletion, subject to legal requirements and legitimate business needs. We may retain limited information on a suppression or do-not-contact list to ensure that we honor an opt-out request.

Retention periods may vary depending on the type of information, the purpose for which it was collected, and applicable legal requirements.

7. Your Privacy Rights

Depending on where you live and applicable law, you may have the right to:

• Request access to personal information we hold about you;
• Request correction or updating of inaccurate or incomplete information;
• Request deletion of personal information;
• Request a copy of personal information in a portable format;
• Request restriction of certain processing;
• Object to certain processing, including direct marketing;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with an applicable privacy or data-protection authority.

To submit a privacy request, email support@lionelmoses.com with the subject line "Privacy Request." Please identify the request you are making and provide enough information for us to locate your records.

We may need to verify your identity before completing a request. We may request information reasonably necessary to prevent unauthorized access or disclosure. We will respond within the time required by applicable law. If we deny a request, we will explain the reason where required and provide any available appeal or complaint options.

8. California Privacy Rights

This section applies to California residents to the extent required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA").

8.1 Categories of Information

Depending on how you interact with us, we may collect or disclose the following categories of personal information:

• Identifiers, such as name, email address, telephone number, IP address, and account identifiers;
• Contact, billing, and mailing information;
• Commercial information, such as purchase, registration, and transaction history;
• Internet or other electronic network activity, such as browsing activity, pages viewed, and interactions with the website;
• Inferences derived from use of the website or services, such as preferences or interests; and
• Other information you voluntarily submit through forms, surveys, support communications, or questions.

Payment-card information is processed by payment providers and is not stored on our servers.

8.2 California Rights

Subject to applicable exceptions, California residents may have the right to:

• Know and access the categories and specific pieces of personal information collected;
• Know the categories of sources, purposes, and third parties involved in collection or disclosure;
• Request deletion of personal information;
• Request correction of inaccurate personal information;
• Opt out of the sale or sharing of personal information;
• Limit the use and disclosure of sensitive personal information where applicable; and
• Receive equal service and pricing without unlawful discrimination for exercising privacy rights.

8.3 Sale and Sharing

We do not sell personal information for monetary consideration.

We may disclose personal information to service providers and contractors for business purposes, such as payment processing, customer relationship management, analytics, communications, security, and service delivery. If analytics, advertising, or similar technologies are enabled, certain disclosures of identifiers or internet activity may be considered "sharing" under the CCPA/CPRA, even when no money is exchanged.

To submit a California request or opt out of the sale or sharing of personal information, email support@lionelmoses.com with the subject line "Do Not Sell or Share My Personal Information."

We will process the request as required by applicable law. We will not require you to create an account to submit a request, although we may need to verify your identity. Authorized agents may submit requests on your behalf where permitted, subject to reasonable verification of the agent's authority.

9. Other U.S. State Privacy Rights

Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, and other jurisdictions, may have additional rights depending on the law applicable to them.

These rights may include access, correction, deletion, portability, objection, appeal, and the right to opt out of targeted advertising, certain profiling, or the sale of personal information.

To exercise applicable rights, contact support@lionelmoses.com. We will process and respond to requests according to the law applicable to the requesting individual.

10. International Privacy and Data Transfers

Our services are operated from the United States, and personal information may be collected, stored, accessed, or processed in the United States or other countries that may have privacy laws different from those in your country.

For individuals in jurisdictions such as the European Economic Area, the United Kingdom, or Switzerland, we may process personal information based on one or more of the following legal bases:

• Performance of a contract or steps taken at your request before entering into a contract;
• Your consent;
• Our legitimate interests, provided those interests are not overridden by your rights;
• Compliance with legal obligations; or
• Protection of vital interests where permitted by law.

Where applicable, international transfers may rely on recognized legal safeguards, such as standard contractual clauses, adequacy decisions, or another lawful transfer mechanism.

You may have rights to access, correct, delete, restrict, object to, or receive a portable copy of your personal information. You may also withdraw consent where processing is based on consent and lodge a complaint with a competent data-protection authority.

By using the website or submitting information, you acknowledge that your information may be transferred to and processed in the United States and other jurisdictions as described in this Privacy Policy.

11. Children's Privacy

Our website and services are not directed to children under 13 years of age, or under 16 where a higher age is required by applicable law. We do not knowingly collect personal information from children below the applicable age.

If a parent or legal guardian believes that a child has provided personal information to us, the parent or guardian should contact support@lionelmoses.com. We will take reasonable steps to verify the request and delete the information where required by law.

12. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, disclosure, or destruction.

No method of transmitting or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of personal information. You are responsible for maintaining the confidentiality of any account credentials and for notifying us promptly of suspected unauthorized access.

13. Third-Party Links

Our website may contain links to third-party websites, services, platforms, or resources. We are not responsible for the privacy, security, content, or practices of those third parties.

Your use of a third-party website is governed by that party's privacy policy and terms. We encourage you to review those policies before submitting personal information.

14. Do Not Track and Similar Signals

Some browsers and devices offer "Do Not Track" or similar privacy signals. Because there is not a uniform industry standard for responding to all such signals, our website may not respond to every signal in the same way.

Where required by applicable law, we will honor recognized opt-out preference signals in accordance with our technical capabilities and legal obligations.

15. Governing Law

This Privacy Policy is governed by the laws of the State of New Jersey, without regard to its conflict-of-law principles, except to the extent that applicable privacy laws in another jurisdiction provide rights that cannot lawfully be waived or limited.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal obligations, or privacy practices.

When we make changes, we will post the revised Privacy Policy on the Sites (including lionelmoses.com and its subdomains) and update the "Last Updated" date. Your continued use of the website after an updated Privacy Policy is posted constitutes acknowledgment of the revised policy to the extent permitted by law.

17. Contact Us

For privacy questions, requests, consent withdrawals, or complaints, contact:

Lionel Moses / EmpowerSync
Website: lionelmoses.com
Privacy email: support@lionelmoses.com

Please include "Privacy Request" in the subject line when submitting a request to access, correct, delete, restrict, or receive a copy of your personal information.