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PRIVACY POLICY

AULANI ALCHEMY LLC
Website Privacy Policy

Last Modified: March 2026

  1. INTRODUCTION.

AULANI ALCHEMY LLC ("Company," "we" or "us") respects your privacy. This Privacy Policy sets forth Company's policy with respect to the types of information we may collect from you or that you may provide when you visit aulanialchemy.com ("the Website"), including:

(a) Any content, services, functionality, mobile applications, downloadable materials and courses; and

(b) When you interact with our advertising and applications on third-party websites, if those advertisements include links to this policy ("the Services").

This policy does not apply to any information collected by any other means, including information collected by third parties or affiliates, including through any application or content that may be accessible or linked from the Website.

If you do not agree with our Privacy Policy, your choice is to not use our Website. By accessing or using this Website, you agree to this Privacy Policy and the Terms of Use found here: https://www.aulanialchemy.com/privacy-policy. This Privacy Policy may change from time to time and your continued use of this Website after we make changes is deemed to be acceptance of those changes.

  1. CHILDREN UNDER THE AGE OF 13.

Our Website is not intended for children under 13 years of age. All website users must be at least 13 years of age. If we learn we have received information from a child under 13, we will delete the information. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Website or Services, please contact us at [email protected] and we will endeavor to delete the information from our database. Residents of certain states under 13, 16 or 18 years of age may have additional rights regarding the collection and sale of their personal information.

  1. WHEN WE COLLECT INFORMATION FROM YOU.

We collect and process data when you access our Website, fill out forms on our Website, register, make a purchase, sign up for our newsletter, respond to a survey, surf the Website or use or view our Website via your browser's cookies. Company may also receive your data indirectly from the following sources: our email and content platform (Substack), our course and client portal platform and payment processors used in connection with your purchase of our products and services.

  1. WHAT TYPES OF INFORMATION WE COLLECT FROM YOU.

4.1 Voluntary Information.

When you visit our Website or use our Services we collect certain types of information from you. This includes your name, email address, mailing address, phone number, credit card or payment information, and other information you provide to us.

When you provide information to us, we collect certain information from you, such as information that you provide by filling in forms on our Website, copies of your correspondence or any other information you choose to provide.

You may also provide information to be published or posted on public areas of the Website ("User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk.

4.2 Automatic Data Collection.

We also collect information automatically through cookies and other tracking technologies, such as information about your internet connection, your IP address, traffic and location data, logs and other information. The information we automatically collect helps us to improve our Website and deliver a better service.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See our Do Not Track Policy in Section 8 below.

4.3 Categories of Consumer Data.

The categories of consumer data we have collected within the past 12 months include: identifiers (such as name and email address); commercial information (such as purchase history); internet and network activity information (such as IP address, browser type and browsing history on our Website); and geolocation data (general location based on IP address).

  1. HOW WE COLLECT INFORMATION FROM YOU.

The data controller for information collected through this Website is AULANI ALCHEMY LLC. You may contact the data controller at [email protected]. The technologies we use for automatic data collection may include:

5.1 Cookies.

Cookies are small files placed on the hard drive of your computer that enable the website or service provider's systems to recognize your browser and remember certain information. We use functionality cookies to recognize you on our Website and remember your previously selected preferences. We use advertising cookies to collect information about your visit to our Website, the content you viewed, the links you followed and information about your browser, device and your IP address. Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our Website.

5.2 Web Beacons.

Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Company to access certain website statistics.

5.3 Meta Pixels.

Pages of our Website may contain Meta Pixels. A Meta Pixel is an invisible code snippet that website owners may use to track user actions, gather insights and target advertisements. It is used to identify website visitors and serve them ads when logged on to Meta-owned platforms like Facebook and Instagram. By using the Website, you consent to Company's use of Meta Pixels.

5.4 Analytics.

We may use third-party analytics tools (such as Google Analytics) to help us understand how users engage with our Website. These tools may collect information about your use of our Website over time.

You may refuse to accept browser cookies by activating the appropriate setting in your browser, but if you do, you may not be able to access certain parts of our Website or Services. You may also provide information that is public or displayed on public areas of the Website or transmitted to other users of the Website or third parties ("User Content"). Your User Content is transmitted to others at your own risk.

  1. HOW WE USE YOUR INFORMATION.

Processing of your information is necessary for the purpose of legitimate interests and does not infringe on any fundamental rights and freedoms. Those legitimate interests include direct marketing, processing of client data, ensuring network and information security and fraud prevention. We use your information to:

(a) Understand and store information about visitor preferences;

(b) Compile aggregate data about site traffic and site interactions;

(c) Provide you with information, products or services that you request from us or that we think you may like;

(d) Provide you with notices about your account;

(e) Carry out billing and collection;

(f) Provide customer support;

(g) Send marketing communications where you have opted in to receive them; and

(h) In any other way we describe when you provide information to us.

We do not use automated decision-making in processing your personal information for our services and products. We do not sell personal information or consumer data for monetary gain or valuable consideration.

  1. THIRD PARTY DISCLOSURES.

Some content or applications on the Website are served by third parties, such as advertisements. We do not control third parties' tracking technologies. You should consult the privacy policies of any such third party for more detailed information on their practices. Our Website contains links to other websites. Our Privacy Policy applies only to our Website, so if you click on a link to another website, you should read their privacy policy.

  1. HOW WE DISCLOSE YOUR INFORMATION.

8.1 

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

8.2 

We disclose personal information that we collect or you provide as described in this Privacy Policy to the following third-party service providers and contractors: Substack, Inc. (email communication and content platform); Kajabi portal (course portal and purchase processing); and payment processors used in connection with your purchase of our products and services. Each of these service providers is bound by their own privacy policies and data processing agreements.

8.3 

We may also disclose your personal information to comply with any court order, law or legal process.

8.4 

We use your provided data to prevent fraudulent purchases by sharing your data with payment processors and credit reference agencies as needed.

8.5 

We will release information when it is appropriate to comply with the law or enforce our site policies.

8.6 Do Not Track Policy.

Our site honors Do Not Track ("DNT") browser settings. We do not track your online browsing activity on any other online service.

8.7 

We may transfer personal data collected from you to third-party processors whose operations may be located internationally, including in countries where you access our services. Please be aware that such countries may not have the same level of data protection as your home country; however, our collection, storage and use of your personal data will continue to be governed by this Privacy Policy.

  1. HOW WE STORE AND PROTECT USER INFORMATION.

9.1 

Company has implemented measures designed to secure your personal information from accidental loss and unauthorized access, use and disclosure. These security measures include:

(a) All payment information is encrypted;

(b) All information you provide to us is stored on secure servers behind firewalls;

(c) We use regular malware scanning; and

(d) No transmission over the internet or email is completely secure or error free. Please keep this in mind when disclosing personal information over the internet.

9.2 

We will keep your data for as long as your account is active or as needed to provide you with our services and fulfill the purposes outlined in this Privacy Policy. We retain personal data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Once this period has expired, we will delete your data.

  1. YOUR CALIFORNIA PRIVACY RIGHTS.

10.1 

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

10.2 

Under the CCPA, California residents have the right to opt-out of the sale of personal information about them or their household. You may opt out by emailing [email protected].

10.3 

In the preceding twelve months, we have not sold personal information. Our policy is that we do not and will not sell your personal information unless you give us your consent or direct us to do so.

  1. YOUR STATE PRIVACY RIGHTS.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah and Virginia provide their state residents with rights to:

(a) Confirm whether we process their personal information;

(b) Access and delete certain personal information;

(c) Correct inaccuracies in their personal information;

(d) Data portability; and

(e) Opt-out of personal data processing or limit or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights, please contact us at [email protected].

  1. RIGHT TO OPT OUT.

You have agreed to receive marketing material from Company and have consented to Company disclosing your information to third parties for marketing purposes. You may opt out at any time. If you no longer wish to be contacted for marketing purposes, please email us at [email protected] or click the unsubscribe link included in any marketing email we send you.

  1. YOUR DATA PROTECTION RIGHTS.

13.1 The Right to be Informed.

Anyone processing your personal data must make clear what they are processing, why and who else the data may be passed to.

13.2 The Right to Access.

This is your right to see what data is held about you by a Data Controller.

13.3 The Right to Rectification.

You have the right to have your data corrected and amended if what is held is incorrect in some way. You can request that we correct any information you believe is inaccurate or request that we complete information you believe is incomplete.

13.4 The Right to Erasure.

Under certain circumstances, you can ask for your personal data to be deleted. This is also called "The Right to be Forgotten." This would apply if the personal data is no longer required for the purposes it was collected for, your consent for the processing of that data has been withdrawn or the personal data has been unlawfully processed.

13.5 The Right to Restrict Processing.

This gives you the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded or the data is being corrected.

13.6 The Right of Portability.

You have the right to ask for any data supplied directly to the Data Controller by you to be provided in a structured, commonly used and machine-readable format. You may request copies of your personal data from us. You may request that we transfer the data we have collected to another organization or directly to you under certain conditions. We may charge a small fee for this service or for any copies requested.

13.7 The Right to Object.

You have the right to object to further processing of your data which is inconsistent with the primary purpose for which it was collected, including profiling, automation and direct marketing.

13.8 Rights in Relation to Automated Decision-Making and Profiling.

You have the right not to be subject to a decision based solely on automated processing.

13.9 Right Not to be Subject to Discrimination for the Exercise of Rights.

Company will not refuse goods or services to individuals who exercise their consumer rights.

If you would like to exercise any of these rights, please contact us at [email protected].

  1. CHANGES TO PRIVACY POLICY.

The date the Privacy Policy was last revised is identified on the first page of this Privacy Policy. We reserve the right to update this policy and if we make material changes to how we treat our users' personal information, we will notify you by email. You are responsible for periodically visiting our Website and Privacy Policy to check for any changes.

  1. CONTACT.

You may send us an email to inquire about our Privacy Policy or to request access to, correct or delete any personal information that you have provided to us at:

AULANI ALCHEMY LLC
Renahy Aulani Leila Levy
[email protected]

You may reach our Data Protection Officer by sending an email to [email protected].

  1. COMPLAINTS.

Should you wish to report a complaint or if you feel that Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner's Office (if you are an individual located in the United Kingdom) or the European Data Protection Board.

  1. INDIVIDUALS LOCATED WITHIN THE UNITED KINGDOM.

17.1 Restricted Transfers.

Our Company may make a restricted transfer if the receiver is located in a third country or territory or is an international organization covered by UK "adequacy regulations." If there are no adequate regulations about the country, territory or sector for the restricted transfer, our Company will determine whether the transfer may be made subject to "appropriate safeguards" as listed in the UK GDPR. Before we rely on an appropriate safeguard to make a restricted transfer, we must be satisfied that the data subjects of the transferred data continue to have a level of protection essentially equivalent to that under the UK data protection regime. We do this by undertaking a risk assessment which takes into account the protections contained in that appropriate safeguard and the legal framework of the destination country. Appropriate safeguards may include: (1) a legally binding and enforceable instrument between public authorities or bodies; (2) binding corporate rules as defined in Article 47 of the UK GDPR; (3) a contract incorporating standard data protection clauses recognized or issued in accordance with the UK data protection regime; (4) a code of conduct approved by the ICO; (5) certification under an approved certification scheme; (6) a bespoke contract governing a specific restricted transfer which has been individually authorized by the ICO; or (7) administrative arrangements between public authorities or bodies.

17.2 Children Under the Age of 13.

All website users located in the United Kingdom must be at least 13 years of age. If we learn we have received information from a child under 13 in the United Kingdom, we will delete the information. If you have reason to believe that a child under the age of 13 located in the United Kingdom has provided Personal Data to us through the Website or Services, please contact us at [email protected] and we will endeavor to delete the information from our database.

17.3 Local Representative in the United Kingdom.

Company offers services accessible to individuals in the United Kingdom through its publicly available Website. Our contact information for UK-related inquiries is:

AULANI ALCHEMY LLC
Renahy Aulani Leila Levy
[email protected]

 

Questions about this Privacy Policy? Contact us at [email protected]