Privacy Policy

1. Introduction

Welcome to Freedom After 40. This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our websites, use our services, or interact with our digital content.

We are committed to protecting your privacy and complying with global data protection regulations, including:

• General Data Protection Regulation (GDPR) for EU/EEA/UK residents
• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• U.S. Children’s Online Privacy Protection Act (COPPA)
• CAN-SPAM Act for email communications

By using Freedom After 40 websites or services, you agree to the terms outlined in this Privacy Policy.

2. Information We Collect

When you interact with Freedom After 40, we may collect:

2.1 Personal Information You Provide

• Contact Details: Name, email address, phone number
• Account Information: Username, password, preferences
• Purchase Information: Billing address, transaction history
• Communications: Messages, support requests, feedback
• Course/Program Data: Enrollment information, progress, submissions

2.2 Information Collected Automatically

• Technical Data: IP address, browser type, device information
• Usage Data: Pages visited, time spent, navigation patterns
• Location Data: Approximate location based on IP address
• Cookie Data: Session information, preferences, identifiers

2.3 Children’s Privacy (COPPA)

Our services are not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately at [email protected].

3. How We Use Your Information

We use your personal information for the following purposes:

• Service Delivery: Provide access to courses, content, and digital products
• Transaction Processing: Process payments and fulfill orders
• Communication: Send service updates, respond to inquiries, provide support
• Marketing: Send promotional content (with opt-out options)
• Improvement: Analyze usage patterns to enhance our services
• Security: Detect and prevent fraud, abuse, and illegal activity
• Compliance: Meet legal obligations and enforce our terms

3.1 Legal Basis for Processing (GDPR)

For EU/EEA/UK residents, we process your data based on:

• Consent: For marketing communications and optional cookies
• Contract: To provide services you’ve requested
• Legal Obligation: For tax, accounting, and compliance purposes
• Legitimate Interest: For security, fraud prevention, and service improvement

4. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

4.1 Types of Cookies

• Essential Cookies: Necessary for website functionality
• Performance Cookies: Help analyze website usage (Google Analytics)
• Functional Cookies: Remember your preferences and settings
• Advertising Cookies: Used for targeted advertising (Meta Pixel, Google Ads, TikTok Pixel)
• Email Tracking: Track email opens and clicks for engagement analytics

4.2 Cookie Consent and Control

When you first visit our website, you’ll see a cookie consent banner. For visitors from the EU, EEA, and UK, non-essential cookies (analytics, advertising) require explicit consent before activation.

You can control cookies through:

• Our cookie consent banner settings
• Your browser settings (to block or delete cookies)
• Contacting us at [email protected]

5. Data Security and Retention

5.1 Security Measures

We implement reasonable security measures to protect your information:

• Encryption: SSL/TLS encryption for data transmission
• Secure Payments: PCI-DSS compliant processors (Stripe, PayPal)
• Access Controls: Limited access to authorized personnel
• Regular Reviews: Periodic security assessments and updates

5.2 Data Retention Periods

We retain personal information only as long as necessary:

• Active Customers: Duration of service + 7 years
• Email Subscribers: Until unsubscribe request
• Analytics Data: Up to 26 months (Google Analytics)
• Payment Records: 7 years minimum (legal requirement)
• Support Communications: Up to 3 years

6. Payment Processing

All payments are securely processed by third-party providers:

• Stripe: Secure payment processing
• PayPal: Alternative payment processing

We do not store credit card numbers or full banking details on our servers.

7. Data Sharing and Third Parties

We do not sell your personal information. We may share data with:

7.1 Service Providers

• CRM/Funnel Platforms: Systeme.io, GoHighLevel, Stan Store, Beacon AI
• Analytics Providers: Google Analytics
• Advertising Platforms: Meta/Facebook Ads, Google Ads, TikTok Ads
• Email Services: Integrated email marketing platforms

7.2 Legal Requirements

We may disclose information when required by law or to protect our legal rights.

8. Freedom After 40 Subdomains

This Privacy Policy applies to all Freedom After 40 websites and subdomains, including:

• https://sylvanbarzey.com
• https://learn.sylvanbarzey.com (course delivery)
• Other related subdomains for content delivery and services

9. Your Privacy Rights

To exercise these rights, contact us at [email protected] with “Privacy Request” in the subject line.

9.1 Additional EU/EEA/UK Rights (GDPR)

If you’re in the EU, EEA, or UK, you also have:

• Right to Lodge Complaint: File a complaint with your local data protection authority
• Automated Decision Rights: We do not engage in fully automated decision-making that produces legal or similarly significant effects
• Processing Restrictions: Request temporary restriction of processing

9.2 California Residents (CCPA/CPRA)

If you’re a California resident, you have specific rights including:

• Right to Know: What personal information we collect and how we use it
• Right to Delete: Request deletion of personal information
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out: Opt out of “sale” or “sharing” of personal information
• Non-Discrimination: We won’t discriminate against you for exercising rights

Do Not Sell or Share My Personal Information

California residents can opt out of data sharing for advertising purposes by:

• Using our cookie consent banner to reject advertising cookies
• Emailing [email protected] with “CCPA Opt-Out” in the subject line

10. International Data Transfers

Your data may be transferred to and processed in the United States, where our servers are located. We implement appropriate safeguards for international transfers, including:

• EU-U.S. Data Privacy Framework: For transfers to certified U.S. providers
• Standard Contractual Clauses: For transfers to non-certified providers
• Service Provider Agreements: Ensuring adequate data protection

11. CAN-SPAM Compliance (Email)

We comply with the CAN-SPAM Act for all commercial emails:

• Accurate header and subject line information
• Clear identification as advertisements when applicable
• Our physical address in all commercial emails
• Clear unsubscribe mechanism in every email
• Honoring opt-out requests within 10 business days

12. Third-Party Websites

Our website may contain links to external sites. We’re not responsible for their privacy practices. We encourage you to review their privacy policies.

13. Policy Updates

We may update this Privacy Policy periodically. We’ll notify you of material changes by:

• Updating the “Effective Date” at the top of this page
• Posting a notice on our website
• Sending email notifications to active users (when appropriate)

Your continued use of our services after updates constitutes acceptance of the revised policy.