Privacy Policy

Updated: October 28, 2026

In Plain English

At emotive.energy, privacy is particularly important because our work explores personal experience, workplace situations, relationships, embodied experience, and patterns of thought, emotion, and behavior.

We collect and use personal information to operate our website, deliver educational and consulting services, administer purchases and memberships, communicate with participants, and conduct research where separately authorized.

Our approach is straightforward:

  • Defined purposes. We collect personal information for identifiable business, educational, contractual, or research purposes.
  • Personalized educational feedback. Some programs may interpret participants’ questionnaire answers and return observations about their individual circumstances. These activities are educational, not medical diagnoses or psychotherapy.
  • Protection of sensitive information. Private assessment answers, consultation narratives, and identifiable research material are not authorized for unrelated advertising, behavioral targeting, or routine marketing-database use.
  • Research is separate. Buying a course or completing an educational assessment does not automatically enroll someone in a separate research study.
  • Independent professionals. Practitioners delivering services through the Platform may have additional professional privacy responsibilities and may separately control certain records.
  • External technology. We use website, payment, educational, communications, survey, and security services. Their responsibilities depend on the actual service and processing arrangement.
  • Cookies and tracking. We use cookies and related technologies for website functionality and, where permitted, analytics and other purposes. See our Cookie Policy for details and available privacy choices.
  • Privacy rights. Depending on applicable law, individuals may request access, correction, deletion, restrictions, or other controls concerning their personal information.
  • Adults only. Our offerings are intended for individuals aged 18 or older who have reached the age of majority in their jurisdiction.

This summary is provided for convenience. The complete Policy explains our information practices, responsibilities, and applicable legal rights.

Notice at Collection

emotive.energy LLC collects personal information when you browse our website, communicate with us, register, make purchases, or participate in our services.

Information may include contact and professional details, account and transaction records, website activity, communications, and information voluntarily provided through educational programs, assessments, or research.

We use this information to operate our platform, deliver services, process purchases, communicate with participants, maintain security, and conduct authorized research, analytics, and marketing.

Information is retained according to its purpose and applicable legal requirements. We do not sell personal-information databases or authorize the use of private assessment responses for behavioral advertising. Certain website tracking and attribution practices may constitute selling or sharing under applicable privacy laws.

For specific categories, purposes, retention periods, disclosures, and privacy rights, see Sections 4, 6, 12–14, and 17–18 of this Privacy Policy.

Privacy inquiries: admin@emotive.energy

1. Who We Are

This Privacy Policy describes how emotive.energy LLC (“emotive.energy,” the “Company,” “we,” “us,” or “our”) collects, uses, stores, discloses, and protects personal information.

Company and Privacy Contact

emotive.energy LLC
1968 S. Coast Hwy, Suite 3310
Laguna Beach, CA 92651
United States

Email: admin@emotive.energy

Website: https://emotive.energy

emotive.energy LLC is a California-organized limited liability company with business operations principally in New York.

The Company is currently an LLC operating according to collaborative and cooperative principles. It is not a separately incorporated, member-owned cooperative.

For information whose purposes and means of processing the Company determines, emotive.energy LLC acts as the responsible controller or business under applicable privacy law.

Our activities include adult education, professional development, experiential learning, consulting, embodied practices, creative programs, collaborative inquiry, and research.

The Platform is not operated as a psychotherapy clinic, medical practice, or general clinical patient-record system.

However, certain educational activities may involve information concerning wellbeing, workplace distress, physical experience, emotional experience, or other potentially sensitive matters.

The educational or nonclinical designation of a service does not remove privacy obligations that otherwise apply to the information processed.

2. Scope of This Policy

This Policy applies to personal information processed by the Company through its websites, services, and business activities, including:

  1. The main website at https://emotive.energy.
  2. Website accounts, registration, and contact forms.
  3. WooCommerce purchases, checkout, refunds, and order administration.
  4. Sensei LMS course enrollment, access, progress, and educational activities.
  5. Self-paced courses, digital publications, recordings, and guided audio practices.
  6. Live educational programs, professional groups, workshops, and facilitated experiences.
  7. Individual, dyad, team, leadership, and organizational consultation administered through the Company.
  8. Educational questionnaires, self-assessments, and personalized feedback.
  9. Company-sponsored research and collaborative inquiry.
  10. Professional membership applications and participation.
  11. Business, provider, and organizational relationships.
  12. Customer support and other communications.
  13. Website analytics, security, attribution, and lawful marketing activities.

Some activities use external or separately hosted services.

Questionnaires and research activities may use BlockSurvey or other services identified in the relevant program or research notice.

The Company’s Substack publication operates at:

https://connect.emotive.energy

External platforms may maintain their own terms, privacy notices, cookies, and technical systems.

This Policy addresses information for which emotive.energy LLC has an applicable responsibility. It does not replace a separate legally required notice for a distinct research project, independently controlled professional activity, or external platform.

Personal information obtained by a licensed professional through a separate clinical practice outside the Platform is not automatically part of the Company’s educational records and is subject to the laws and notices governing that separate professional relationship.

3. The Company, Independent Practitioners, and Organizational Customers

emotive.energy LLC operates the Platform and is the contracting seller for purchases completed through its current website checkout.

Some offerings are developed or delivered by independent professionals, including consultants, educators, researchers, coaches, licensed professionals, movement practitioners, and creative facilitators.

3.1 Information Controlled by the Company

The Company generally determines the purposes and means of processing information associated with:

  • Website accounts and registration.
  • Platform purchases, payments, and refunds.
  • Course enrollment and access administration.
  • Company-managed educational services.
  • Company communications and customer support.
  • Company-operated marketing systems.
  • Website analytics and security.
  • Company-sponsored assessments and research.

3.2 Information Controlled by Independent Practitioners

An independent practitioner may separately maintain information arising from direct professional work.

Such information may include confidential consultation notes, separately administered assessments, professional correspondence, or other records maintained outside the Company’s general administrative systems.

A practitioner may act as an independent controller, joint controller, or processor, depending on the actual arrangement and applicable law.

These roles are determined by the relevant processing activities and agreements, not merely by the practitioner’s designation as an independent contractor.

An independent practitioner’s professional qualifications do not mean the Company itself holds the same professional license.

3.3 Sharing Between the Company and Practitioners

The Company may share information reasonably necessary for a practitioner’s authorized work, such as enrollment, contact, scheduling, or relevant service information.

The Company does not automatically receive unrestricted access to every confidential professional record maintained by a practitioner.

Similarly, practitioners do not automatically receive access to all information held by the Company.

Sensitive educational responses and private records require purpose-specific access authorization and any additional legal safeguards.

3.4 Organizational Customers

Organizations may purchase or sponsor Company offerings for employees, professionals, or other participants.

An organizational purchaser may receive information necessary for legitimate contractual administration, including authorized enrollment, attendance, or aggregate participation information.

An organization does not automatically receive identifiable private assessment answers, confidential group disclosures, individualized educational feedback, or research responses.

Any additional sharing must be justified by an applicable legal basis and the relevant disclosures or agreements.

4. Categories of Personal Information Collected

The categories collected depend on how a person uses the Platform.

4.1 Identity and Contact Information

We may collect:

  • Name.
  • Email address.
  • Telephone number.
  • Mailing or billing address.
  • Country, state, or relevant jurisdiction.
  • Professional title or affiliation.
  • Organization or employer information where relevant.
  • Communication preferences.

4.2 Account and Enrollment Information

We may collect:

  • Usernames and account identifiers.
  • Authentication and security information.
  • Course registrations.
  • Enrollment and participation records.
  • Attendance.
  • Lesson progress.
  • Course completion.
  • Educational submissions.
  • Purchased access rights.
  • Account and subscription status where applicable.

4.3 Purchase and Transaction Information

We may collect or receive:

  • Order identifiers and transaction dates.
  • Products or services purchased.
  • Prices, currencies, discounts, and coupon codes.
  • Applicable tax information.
  • Billing jurisdiction.
  • Payment status and processor references.
  • Refunds, chargebacks, and disputes.
  • Installment or subscription information, where applicable.
  • Provider attribution.
  • Referral or promotional attribution where applicable.

Payment-card transactions are processed through services such as Stripe.

The Company generally receives payment confirmations and relevant transaction information rather than complete payment-card credentials.

4.4 Website and Technical Information

Technical information may include:

  • IP address.
  • Browser and device characteristics.
  • Operating-system information.
  • Website pages visited.
  • Referral sources.
  • Campaign parameters.
  • Approximate location inferred from technical information.
  • Cookies and local-storage identifiers.
  • Session information.
  • Interaction and diagnostic information.
  • Security and fraud-prevention data.

Some information is necessary for requested website functions. Other information may be associated with analytics, attribution, or optional tracking.

4.5 Communications

We may process information received through:

  • Contact forms.
  • Email.
  • Telephone or SMS.
  • Customer-support requests.
  • Professional inquiries.
  • Membership or provider applications.
  • Program administration.
  • Other business communications.

Communications may be retained to address requests, administer a relationship, maintain legitimate records, or comply with applicable obligations.

4.6 Live Program and Group Participation

Participation may involve:

  • Attendance.
  • Educational questions.
  • Professional case discussions.
  • Workplace experiences.
  • Relational observations.
  • Emotional or embodied experiences.
  • Comments shared during facilitated activities.
  • Relevant feedback or educational submissions.

Some disclosures may be sensitive.

Ordinary participation does not authorize unrestricted recording, publication, advertising reuse, or unrelated research use.

4.7 Educational Assessment Responses

  1. Certain educational offerings may invite participants to provide:

    • Structured questionnaire responses.
    • Written reflections.
    • Descriptions of workplace circumstances.
    • Perceptions of burnout or stress.
    • Relationship and communication experiences.
    • Emotional responses.
    • Embodied or physical experiences.
    • Professional challenges.
    • Perceived behavioral patterns.
    • Personal goals and difficulties.

    We may also generate educational indicators, observations, or feedback derived from the submitted information.

    Depending on the content and circumstances, this information may qualify as sensitive personal information, special-category personal data, or consumer health data under applicable law.

4.8 Research Information

  1. Research activities may collect:

    • Survey and interview responses.
    • Research questionnaires.
    • Experiential observations.
    • Relevant background or demographic information.
    • Audio or video recordings where authorized.
    • Research-derived themes, classifications, or analyses.

    Separate project notices identify the categories actually collected for a particular study.

4.9 Professional Member and Provider Information

  1. We may collect:

    • Professional biographies.
    • Education and training.
    • Credentials and licenses.
    • Professional experience.
    • Business contact details.
    • Work samples.
    • Proposed offerings.
    • Insurance and compliance documentation.
    • Contractual and compensation information.
    • Tax information required for lawful reporting.
    • Relevant professional references.

    Certain professional profile information may be published when authorized as part of the member’s or practitioner’s public profile.

5. Sources of Personal Information

We obtain information from the following sources:

Directly from individuals: Through registration, purchases, forms, communications, educational activities, assessments, applications, and research participation.

From Company-operated systems: Through account activity, checkout, enrollment, program administration, and website use.

From service providers: Through payment confirmations, technical logs, scheduling, communications, and other authorized service functions.

From independent practitioners and organizational collaborators: Where they lawfully provide information necessary for an authorized activity.

From publicly available professional sources: Where relevant to professional qualifications, business inquiries, or collaboration.

From website technologies: Through browser storage, referral attribution, security tools, and analytics where enabled.

Information collected for one purpose is not automatically authorized for unrelated uses.

6. Purposes for Which We Process Personal Information

6.1 Platform Operation

To maintain the website, provide accounts, support registration, operate necessary features, and administer services.

6.2 Educational Services

To enroll participants, deliver learning materials, administer courses, support attendance, maintain relevant progress records, and provide educational activities.

6.3 Personalized Educational Feedback

To interpret information voluntarily supplied through educational assessments and provide feedback connected to the relevant offering.

Additional information is provided in Section 7.

6.4 Purchases and Contract Administration

To process payments, administer refunds, provide access, maintain financial records, and fulfill contractual obligations.

6.5 Communications and Support

To respond to inquiries, provide assistance, send operational notices, and manage legitimate professional or organizational relationships.

6.6 Marketing

To provide newsletters, announcements, and promotional communications where permitted by applicable law.

Marketing communications are subject to relevant consent and opt-out requirements.

6.7 Research

To undertake appropriately disclosed and legally authorized research activities.

Research is addressed separately in Section 8.

6.8 Website Security

To protect accounts, maintain service integrity, prevent fraud, identify security incidents, and investigate unauthorized use.

6.9 Analytics and Service Improvement

To understand website functionality, evaluate permitted engagement information, correct technical problems, and improve services.

Optional tracking is subject to applicable consent and opt-out requirements.

6.10 Legal and Regulatory Obligations

To comply with applicable legal obligations, maintain required records, respond to lawful requests, and establish or defend legal claims.

7. Personalized Educational Assessments and Feedback

Some educational offerings invite participants to complete questionnaires, self-assessments, or reflective exercises concerning their experiences, relationships, work, and wellbeing. These activities may be used to provide educational observations or individualized feedback. They are not medical diagnoses or psychotherapy.

7.1 Information Processed

Depending on the particular activity, processing may include:

  • Submitted answers.
  • Written reflections.
  • Selected response categories.
  • Educational scores or indicators.
  • Derived themes or patterns.
  • Individualized feedback.
  • Relevant account or course identifiers.

When responses or derived information can identify a participant, directly or indirectly, they are treated as personal information.

7.2 How Feedback Is Generated

Educational feedback may be developed through structured questionnaires, scoring methods, established interpretation rules, or facilitator review. The relevant program notice explains how responses are used and who may access them.

7.3 Educational Interpretation and Profiling

Individualized feedback may identify patterns in a participant’s responses or experiences. Its purpose is educational reflection and learning. It is not a clinical diagnosis and is not used to determine eligibility for employment, credit, insurance, medical treatment, or other similarly significant decisions.

7.4 Special-Category Information Under EU and UK Law

Where processing is subject to the EU GDPR or UK GDPR, an appropriate Article 6 lawful basis must be established.

For information objectively necessary to deliver a purchased educational service, Article 6(1)(b), performance of a contract, may be used where its requirements are satisfied.

If voluntary assessment responses also qualify as special-category personal data, a separate condition under Article 9 is required.

For voluntary sensitive educational assessments, the Company’s selected approach is Article 9(2)(a), explicit consent, where consent can be freely given and otherwise meets the applicable legal requirements.

Before relying on explicit consent, the assessment must:

  1. Explain the sensitive information collected.
  2. Identify the specific processing purpose.
  3. Obtain a separate affirmative statement of explicit consent.
  4. Explain applicable withdrawal rights and the consequences for participation or feedback.
  5. Limit the information to what is necessary for the authorized purpose.
  6. Apply appropriate safeguards and access restrictions.

Explicit consent to sensitive assessment processing is separate from cookie consent, marketing preferences, and optional research participation.

If a valid Article 6 basis and Article 9 condition cannot be established, the relevant special-category processing must not proceed.

Other jurisdictions may impose additional or different conditions.

7.5 Separation from Advertising and Marketing

Private assessment responses, individualized sensitive feedback, and identifiable research information are not used for behavioral advertising or unrelated marketing. We do not authorize this information to be transmitted to advertising platforms or ordinary marketing databases. Information necessary for enrollment, course administration, purchases, and communications is handled separately.

7.6 Access to Assessment Information

Access to identifiable assessment information is limited to persons or service providers with an authorized role in the relevant activity.

An employer, sponsor, independent member, or other organizational participant does not automatically receive individual assessment answers or feedback.

Any additional disclosure requires an appropriate lawful basis and applicable notice or authorization.

7.7 Retention

The standard maximum retention period selected for identifiable responses and linked feedback in new Company-administered educational assessment programs is 12 months after the relevant course or assessment cycle ends, unless a shorter period is required or a narrowly applicable legal obligation justifies a longer period.

Retention of existing questionnaire records collected under earlier arrangements must be assessed according to their original purpose, applicable notices, and legal requirements.

Additional details appear in Section 14.

8. Research Activities and Separate Authorization

Research and methods development are part of emotive.energy’s activities.

However, purchasing an educational product or completing an educational assessment does not automatically enroll someone in a separate research study.

Where information is collected or used for a distinct research purpose, an applicable research notice or consent process will explain:

  1. The purpose of the research.
  2. The categories of information collected.
  3. Whether participation is voluntary.
  4. The applicable legal basis and consent requirements.
  5. Whether information is anonymous, pseudonymous, or identified.
  6. Who may access or receive the information.
  7. How findings may be analyzed or published.
  8. Retention and deletion arrangements.
  9. Relevant withdrawal rights.
  10. Any required independent ethics review.

Identifiable educational information will not automatically be repurposed for unrelated research merely because it is available to the Company.

Appropriately aggregated or de-identified research findings may be used where lawful.

The Company does not guarantee that information is anonymous merely because a privacy-oriented survey tool is used or a questionnaire does not request a name.

Where a research project requires institutional review board approval, an ethics committee determination, or another formal review, that requirement must be satisfied before the relevant research begins.

Not every educational or research activity necessarily requires an institutional review board.

9. Legal Bases for Processing

Where the EU GDPR, UK GDPR, or comparable laws apply, processing must be supported by the appropriate legal basis.

9.1 Performance of a Contract

GDPR Article 6(1)(b) may apply to information objectively necessary for:

  • Account administration.
  • Purchases and enrollment.
  • Delivery of contracted educational services.
  • Certain requested educational feedback.
  • Other necessary performance of accepted agreements.

A contract does not justify unrelated processing merely because the Company includes broad language in its terms.

9.2 Consent

GDPR Article 6(1)(a) may apply where valid consent is obtained for a specified purpose.

Examples may include certain optional tracking, marketing, or separately authorized processing.

Where consent is the legal basis, individuals may withdraw consent for future processing.

Withdrawal does not retroactively invalidate previous lawful processing.

9.3 Legal Obligations

GDPR Article 6(1)(c) may apply where information is necessary to comply with applicable tax, financial, regulatory, or other legal obligations.

9.4 Legitimate Interests

GDPR Article 6(1)(f) may apply to certain business activities, including security, fraud prevention, legitimate service administration, and appropriate business communications.

This basis is used only where the applicable requirements, including balancing individual rights and interests, are satisfied.

9.5 Special-Category Information

Where Article 9 applies, an Article 6 lawful basis alone is insufficient.

For voluntary sensitive educational assessments, the selected Article 9 condition is explicit consent under Article 9(2)(a) where legally valid.

Separate research or specialized activities may require a different independently justified condition.

9.6 Marketing and Electronic Communications

Electronic marketing must also comply with applicable communications and privacy laws.

An Article 6 lawful basis does not replace a separate consent requirement under applicable electronic communications rules.

9.7 Other Jurisdictions

Where Washington, Nevada, California, Brazil, or another jurisdiction requires a separate basis, notice, or authorization for sensitive information, those requirements must be evaluated independently.

10. Service Providers, Website Components, and Processing Roles

The Company uses software installed within WordPress and separately operated external services.

An installed plugin does not necessarily constitute a separate external recipient of personal information.

A provider may act as a processor for some activities and as an independent controller for others.

10.1 Website Hosting and Infrastructure

SiteGround: Website hosting and related infrastructure. SiteGround generally acts as a processor for customer information hosted on the Company’s behalf, while certain service-account or administrative activities may involve separate controller responsibilities.

WordPress and Elementor: Website presentation, content management, and account-related functions.

Additional WordPress software: WordPress extensions support website design, forms, security, administration, and other functions. These components generally operate within our website, although particular services may process information under their own applicable terms.

Cloudflare and Cloudflare Turnstile: Website delivery, traffic management, security, and bot protection. Processing roles depend on the applicable Cloudflare services and contractual arrangements.

Wordfence: Website security and threat detection.

WPVibe: Authorized website administration and related assistance. Administrative access is subject to the permissions and capabilities provided through the Company’s WordPress account.

10.2 Commerce and Payments

WooCommerce: Product listings, customer accounts, checkout, orders, and commercial administration within WordPress.

Installed commerce extensions support features including product bundles, add-ons, pricing, checkout configuration, promotions, and related functions.

Stripe: Payment processing, transaction security, fraud prevention, and related financial services.

Under its applicable data-processing arrangements, Stripe may act as a data processor for processing performed on behalf of the Company and as an independent data controller for specified activities such as regulated payment functions, fraud prevention, compliance, and other independently determined purposes.

Stripe’s independent processing is also governed by its own applicable privacy information.

10.3 Course Delivery

Sensei LMS and Sensei Pro: Course enrollment, lessons, learner progress, and educational administration within WordPress.

Related installed course extensions support cohorts, certificates, and additional learning functions.

Sensei LMS is primarily installed software operating within the Company’s hosting environment, not automatically a separate external processor of all learner records.

Any separately enabled external services or telemetry must be evaluated according to their actual operation.

10.4 Surveys and Assessments

BlockSurvey may be used to administer educational questionnaires, surveys, and research activities. Depending on the particular questionnaire, it may process submitted responses, session information, and information necessary to deliver the requested activity.

The applicable program or research notice explains the purpose of the questionnaire, who may access responses, and how information is retained and used.

10.5 Communications and Customer Management

ONTRAPORT: Contact management, forms, communications, and business automation.

ONTRAPORT acts as a processor for permitted customer-controlled information under its applicable data-processing arrangements.

Its published Data Processing Agreement restricts submission of sensitive information, including information concerning health and other identified sensitive categories.

Raw sensitive assessments, confidential consultation narratives, and identifiable sensitive research records are not authorized for routine submission to ONTRAPORT.

Pipedrive: Professional contact and relationship management where used. Its processor or controller responsibilities depend on the relevant service and agreement.

Google Workspace: Business email, document collaboration, and productivity functions. Google may act as a processor for customer-controlled content and as an independent controller for certain separate service activities, under applicable terms.

FluentSMTP: WordPress-based email routing through configured mail services.

WP Fusion: WordPress integration software used to connect permitted account, course, and commerce information with configured external systems.

Quo: Business telephone and SMS communications where used.

10.6 Live Programs and Publications

Zoom: Live online meetings, classes, and consultations where used. Processing roles depend on the meeting activity and applicable terms.

Substack: Separately operated publication and newsletter platform at https://connect.emotive.energy.

Substack maintains its own platform infrastructure and may determine purposes for certain account, publication, and service-related processing.

10.7 Analytics, Fonts, and External Resources

Relevant services include:

  • Google Tag Manager, used to manage configured website tags.
  • Google Analytics 4, where enabled.
  • Meta Pixel (Meta Platforms), loaded through Google Tag Manager only after advertising consent, to measure page views and purchase-related actions (product views, add-to-cart, checkout started, and purchases) for selected products.
  • Google Fonts, for externally delivered font resources where used.
  • Font Awesome, for icons and related resources.
  • cdnjs, including resources delivered through cdnjs.cloudflare.com.
  • YouTube or other embedded media services where used.

The presence of Google Tag Manager does not establish that every analytics or advertising tag is enabled.

Externally requested fonts, stylesheets, and scripts may disclose technical request information, such as an IP address, without necessarily setting a cookie.

Optional tracking is subject to applicable privacy and consent requirements.

10.8 Cookie-Consent Management

We use iubenda to manage cookie preferences and applicable consent choices. See our Cookie Policy for information about these technologies and how to manage your preferences.

10.9 Processing Roles

The principal relationships can be summarized as follows:

ServicePrincipal Relationship
emotive.energy LLCController of Company-determined processing
SiteGroundGenerally processor for Company-hosted information
WordPress, WooCommerce, Sensei LMSPrimarily installed software, not automatically separate external processors
CloudflareProcessing role depends on infrastructure and security activity
StripeController for certain functions; processor for others
ONTRAPORTProcessor for permitted Company customer/contact information
BlockSurveySurvey provider; applicable processing role and safeguards depend on the specific service and agreement
Pipedrive and Google WorkspaceGenerally processors for customer-controlled content under applicable arrangements; separate roles may also apply
ZoomRole depends on the meeting or service activity
SubstackIndependently operated publication platform with service-specific controller relationships
Independent practitionersIndependent or joint controllers, or processors, according to actual professional arrangements

The Company must establish appropriate agreements and safeguards wherever legally required.

11. Disclosure and Sharing of Personal Information

Personal information may be disclosed to the following recipient categories when reasonably necessary and lawful.

11.1 Infrastructure and Technology Providers

Hosting, website-security, payment-processing, course-delivery, communications, and survey providers may receive information necessary for their authorized functions.

11.2 Independent Practitioners

An approved practitioner may receive information necessary to prepare for and deliver the offering in which a participant enrolls.

Sensitive information is subject to purpose-specific access limitations.

11.3 Professional Advisers

Legal counsel, accountants, auditors, insurers, and other advisers may receive information as reasonably necessary for their lawful professional work.

11.4 Organizational Customers

An employer, institution, or sponsor may receive authorized administrative or aggregated information relevant to a purchased engagement.

Such arrangements do not automatically permit disclosure of private individual assessment answers or confidential participation narratives.

11.5 Other Participants

In a live group or community, other authorized participants may hear or view information voluntarily shared in that setting.

The Company establishes appropriate confidentiality expectations, but cannot guarantee that every participant will preserve information disclosed to them.

11.6 Legal Authorities

Information may be disclosed where legally required, pursuant to lawful process, or where otherwise lawfully necessary to protect rights or respond to serious unlawful conduct.

11.7 Business Transactions

Information may be disclosed in connection with a lawful financing, restructuring, acquisition, merger, or transfer of assets, subject to applicable safeguards and obligations.

12. Marketing, Advertising, Sale, and Sharing

We use contact and transaction information to communicate about our services, publications, and programs, subject to applicable marketing preferences and opt-out rights.

Our website uses analytics and advertising technologies, including Google Analytics, Google Tag Manager, WooCommerce attribution, and the Meta Pixel. These technologies may transmit browser identifiers, website activity, referral information, and purchase-related events to their respective providers.

The Meta Pixel is used for advertising measurement on selected products and is subject to our advertising-consent controls. Our Global Privacy Control protections are described in Section 13.4.

Some disclosures through advertising technologies may constitute a sale, sharing, or targeted advertising under applicable privacy laws, even without monetary payment for personal information.

We do not sell customer databases or authorize private educational assessment answers, confidential consultation narratives, or identifiable research responses for advertising purposes.

Cookie preferences and applicable privacy rights are described in Sections 13, 17, and 18.

13. Cookies, Browser Storage, and Consent Controls

The website and certain embedded services use cookies, local storage, session storage, and related technologies.

These may support:

  • Account access and security.
  • Shopping carts and checkout.
  • Payment security.
  • Website performance.
  • Forms and questionnaires.
  • Course functionality.
  • Referral and campaign attribution.
  • Analytics and measurement.
  • Embedded content.
  • Consent preferences.

 

Additional information appears in the Cookie Policy.

13.1 Cookie Preferences

You can manage your optional cookie and tracking preferences through our Cookie Preferences control. Where prior consent is legally required, the relevant optional technologies are not enabled until consent is provided. Technologies necessary to deliver a requested website function may operate without optional consent where permitted by law.

13.2 Prior Consent

Where applicable law requires consent before nonessential storage, access, or tracking, the Company must obtain valid consent before the relevant activity occurs.

Where a legal exemption applies to a technology genuinely necessary for a requested function or another permitted purpose, that technology may operate within the limits of the exemption.

13.3 Withdrawal and Preferences

Where consent is the basis for processing, individuals have the applicable right to withdraw it for future processing.

Browser settings may also permit removal or restriction of stored information.

Removing browser storage does not necessarily delete information retained separately in Company or service-provider systems.

13.4 Global Privacy Control

Our website does not currently respond to legacy Do Not Track browser signals. Global Privacy Control is a separate privacy signal, addressed below.

Global Privacy Control is a browser-based signal communicating certain privacy preferences.

Where applicable law requires recognition of valid opt-out preference signals, the Company must honor the relevant rights, including qualifying opt-outs from sale or sharing.

When our website detects a Global Privacy Control signal from a visitor in the United States, it restricts advertising consent and prevents the Meta Pixel from running for that browser, even if advertising cookies are otherwise accepted. Google Analytics and other technologies are governed by their applicable consent and privacy controls.

The signal applies only to the browser and device that send it.

Individuals may contact admin@emotive.energy to communicate an applicable privacy request.

13.5 Separately Hosted Services

Preferences recorded on the main WordPress website do not automatically govern every third-party site, survey domain, or separately hosted publication.

Additional provider-specific information or controls may apply.

14. Data Retention and Deletion

The Company retains information only for as long as reasonably necessary for an identified lawful purpose, subject to applicable legal obligations, relevant agreements, and legitimate recordkeeping requirements.

14.1 Accounts and Enrollment

Account, enrollment, and learning-progress records may be retained during the relevant customer or program relationship and afterward as reasonably necessary for permitted administration, support, contractual rights, or legal obligations.

14.2 Transactions and Financial Information

Transaction, payment, accounting, and tax records are retained according to applicable financial and legal recordkeeping requirements.

14.3 Marketing

Marketing information is used until the applicable permission is withdrawn, an unsubscribe is received, or another lawful limit applies.

Limited suppression records may be retained to honor marketing opt-outs.

14.4 Communications

Customer-support and business correspondence may be retained while the relevant matter is active and afterward for lawful administration, disputes, or other justified purposes.

14.5 Educational Assessments

For new Company-administered individualized educational assessment programs, the selected maximum standard retention period for identifiable raw answers and linked feedback is 12 months after the relevant course or assessment cycle ends.

Information must be deleted or irreversibly de-identified earlier where required by law or when no longer needed for its authorized purpose.

Retention beyond the standard period is permitted only where a specific applicable legal obligation, legal hold, or other independently lawful basis justifies retaining the necessary information for an appropriate additional period.

A separately authorized research copy is governed by the relevant research notice and lawful retention requirements.

Records collected under earlier questionnaire arrangements are reviewed according to their original notices, purposes, applicable rights, and lawful retention requirements.

14.6 Research

Research information is retained according to the applicable research notice, authorized purposes, and legal or institutional requirements.

14.7 Professional Provider Records

Professional contracts, qualifications, payment records, and relevant compliance materials are retained for appropriate business, contractual, and legal purposes.

14.8 Technical and Security Logs

Technical and security information is retained as reasonably necessary for system protection, incident response, investigations, and lawful obligations.

14.9 Deletion Requests

Deletion requests are evaluated according to applicable privacy laws and lawful exceptions.

Deletion of browser cookies does not automatically delete transaction records, account information, assessment records, or information stored elsewhere.

15. Information Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the information we process. These include measures addressing access control, account security, confidentiality, data minimization, service-provider security, and protection of sensitive information.

No electronic system can guarantee absolute security. We respond to suspected security incidents and provide notifications when required by applicable law.

16. International Processing and Data Transfers

emotive.energy LLC is based in the United States.

Personal information may be processed, stored, or accessed in the United States or other countries where authorized providers operate.

Where applicable law restricts international transfers, the relevant transfer must be supported by a lawful mechanism and any required safeguards.

16.1 European Economic Area

Where an international transfer is subject to the EU GDPR, legally available transfer mechanisms may include:

  • An applicable European Commission adequacy decision.
  • European Commission Standard Contractual Clauses using the relevant modules.
  • The EU-U.S. Data Privacy Framework for an eligible, currently certified recipient.
  • Another lawful mechanism authorized by the GDPR.

Use of Standard Contractual Clauses may require assessment of the recipient country and supplementary safeguards.

A service provider’s participation in the Data Privacy Framework must be verified before that certification is relied upon.

The Company does not assert that it is itself certified under the framework.

16.2 United Kingdom

Where an international transfer is subject to UK law, available mechanisms may include:

  • Applicable UK adequacy regulations.
  • The UK International Data Transfer Agreement.
  • The UK Addendum to the EU Standard Contractual Clauses.
  • The UK Extension to the EU-U.S. Data Privacy Framework for an eligible certified recipient.
  • Another mechanism lawfully available under UK data-protection legislation.

The appropriate mechanism depends on the actual recipient and transfer.

16.3 Switzerland

Where Swiss data-protection law applies, transfers are evaluated under the Federal Act on Data Protection.

Potential mechanisms include:

  • Applicable Swiss adequacy determinations.
  • Standard Contractual Clauses recognized under Swiss law, with necessary Swiss-specific adaptations.
  • The Swiss-U.S. Data Privacy Framework for an eligible certified recipient.
  • Other mechanisms permitted by Swiss law.

Swiss requirements are evaluated separately from EU and UK requirements.

16.4 Brazil

Where Brazil’s Lei Geral de Proteção de Dados Pessoais (LGPD) applies, international transfers must satisfy the applicable provisions of that law.

Potential mechanisms include:

  • An applicable adequacy decision.
  • Standard Contractual Clauses approved by Brazil’s Autoridade Nacional de Proteção de Dados (ANPD).
  • Other transfer mechanisms available under the LGPD.

Where relevant, the Company must comply with ANPD Resolution CD/ANPD No. 19/2024, including applicable transparency requirements.

Where required, the Company must provide an accessible Portuguese-language disclosure identifying the transfer’s purpose, duration, destination, recipient categories or identities as applicable, safeguards, responsibilities, and relevant rights.

16.5 Transfer Information

Information about applicable international-transfer safeguards may be requested by contacting admin@emotive.energy.

17. General Privacy Rights and Requests

Depending on applicable law, individuals may have rights to:

  1. Access personal information held about them.
  2. Correct inaccurate information.
  3. Delete eligible personal information.
  4. Restrict certain processing.
  5. Object to certain uses.
  6. Receive a portable copy of certain information.
  7. Withdraw consent where processing relies on consent.
  8. Opt out of qualifying sale, sharing, targeted advertising, or profiling.
  9. Limit certain sensitive-information processing where applicable.
  10. Complain or appeal where relevant law provides those rights.

These rights are subject to applicable conditions and legal exceptions.

17.1 Submitting a Privacy Request

Send requests to:

admin@emotive.energy

Suggested subject:

Privacy Rights Request

Please identify the relevant account, interaction, or information and describe the request.

The Company may require reasonable identity verification before disclosing or modifying information.

Unnecessary sensitive information should not be submitted for verification.

17.2 Authorized Agents

Where applicable law allows an authorized agent to submit a request, the Company may require appropriate authorization and verification.

17.3 Response and Appeal

Requests will be addressed within the time periods required by applicable law.

Where a request is denied or restricted, the Company will provide any required explanation and available appeal procedure.

Where a statutory appeal right applies, requests may be sent to:

admin@emotive.energy

Subject:

Privacy Appeal

The Company does not unlawfully discriminate against individuals for exercising protected privacy rights.

18. Additional Rights and Requirements by Jurisdiction

The applicability of privacy laws depends on the nature of the processing, the relevant individuals, and each law’s jurisdictional requirements.

18.1 California and Other United States Privacy Laws

Where the California Consumer Privacy Act, as amended, applies to the Company and the relevant processing, California residents may have rights to:

  • Know what categories of personal information are collected.
  • Access eligible personal information.
  • Correct inaccurate information.
  • Request deletion.
  • Opt out of qualifying sale or sharing.
  • Limit certain uses or disclosures of sensitive personal information.
  • Exercise applicable rights concerning automated decision-making.
  • Receive legally required notices and protections.

The Company must also provide any disclosures required by law concerning categories of information collected, sources, purposes, recipients, and qualifying sales or sharing during the relevant reporting period.

Other United States state laws may provide rights concerning targeted advertising, sensitive data, profiling, and privacy-request appeals.

These rights apply according to the relevant statute, including applicable business-coverage thresholds and exemptions.

18.2 Washington and Nevada Consumer Health Data

Washington’s My Health My Data Act and Nevada’s consumer health data requirements may apply to qualifying information concerning physical or mental health even when the organization is not a conventional healthcare provider.

Educational assessment responses concerning burnout, stress, wellbeing, bodily experience, or related subjects may constitute consumer health data depending on their content and context.

Where Washington’s law applies, the Company must maintain a separate Consumer Health Data Privacy Policy, with a prominent link on the website homepage.

Covered collection, use, and sharing must satisfy the statute’s applicable requirements, including separate consent for sharing where required, subject to the statutory exceptions for providing a requested service.

The Company must not begin new processing subject to such additional requirements without the necessary notice, legal basis, and safeguards.

Nevada’s separate consumer health data requirements must be evaluated independently.

18.3 European Economic Area

Where the EU GDPR applies, individuals may have the following rights, subject to its conditions and exceptions:

  1. The right to be informed.
  2. The right of access.
  3. The right to rectification.
  4. The right to erasure.
  5. The right to restrict processing.
  6. The right to data portability.
  7. The right to object to certain processing.
  8. The right to withdraw consent where consent is relied upon.
  9. Rights concerning qualifying automated decision-making and profiling.
  10. The right to lodge a complaint with the competent data-protection supervisory authority.

Special-category processing requires the applicable Article 6 and Article 9 conditions.

International transfers are addressed in Section 16.

18.4 United Kingdom

Where UK data-protection legislation applies, individuals have the applicable rights provided under UK law, subject to statutory conditions and exceptions.

These include:

  1. Right to be informed: Receive information about the purposes and methods of processing.
  2. Right of access: Request access to eligible personal information.
  3. Right to rectification: Request correction of inaccurate or incomplete information.
  4. Right to erasure: Request deletion where legally available.
  5. Right to restrict processing: Request limitations on eligible processing.
  6. Right to data portability: Obtain certain information in a reusable format.
  7. Right to object: Object to qualifying processing, including direct marketing.
  8. Automated-decision safeguards: Exercise applicable protections concerning solely automated decisions and profiling, including relevant rights to information, representations, challenge, or human intervention.
  9. Right to withdraw consent: Withdraw consent where processing relies upon it.
  10. Right to complain: Raise concerns with the UK Information Commissioner’s Office.

Special-category processing remains subject to the relevant legal conditions.

The UK Data (Use and Access) Act 2025 has amended certain data-protection rules, including automated-decision provisions, and applicable rights are interpreted under the law in force for the relevant processing.

18.5 Canada

Where Canadian federal or provincial privacy legislation applies, individuals may have applicable rights concerning access, correction, consent, and complaints.

Relevant complaints may be directed to the appropriate federal or provincial privacy authority.

18.6 Australia and New Zealand

Where applicable privacy legislation provides rights concerning access, correction, handling of personal information, and complaints, those rights remain available.

18.7 Switzerland

Where the Swiss Federal Act on Data Protection applies, individuals may have rights concerning:

  • Information about processing.
  • Access.
  • Correction.
  • Deletion or appropriate restrictions in qualifying circumstances.
  • Objection to unlawful processing.
  • Data portability where statutory conditions are met.

Individuals may raise concerns with the Swiss Federal Data Protection and Information Commissioner (FDPIC).

International transfers are addressed separately in Section 16.3.

A foreign private controller must appoint a representative in Switzerland under Article 14 FADP when all applicable statutory conditions are met, including processing related to offering goods or services or monitoring behavior in Switzerland, large-scale processing, regular processing, and high risk to individuals.

Where legally required, the representative’s name and address must be publicly available.

18.8 Brazil

Where Brazil’s LGPD applies, individuals may exercise the rights provided under that law, subject to applicable requirements and exceptions.

These may include:

  1. Confirmation of processing.
  2. Access to personal information.
  3. Correction of incomplete, inaccurate, or outdated information.
  4. Anonymization, blocking, or deletion in applicable circumstances.
  5. Data portability where available.
  6. Information concerning relevant sharing recipients.
  7. Information about consent and the consequences of refusing it.
  8. Withdrawal of consent.
  9. Applicable deletion rights concerning consent-based processing.
  10. Objection to unlawful processing.
  11. Applicable rights concerning decisions made solely through automated processing that affect an individual’s interests.

Individuals may contact the Company and may exercise available rights to petition or complain to the ANPD.

Where sensitive personal data is processed, the Company must establish an applicable condition under Article 11 of the LGPD, including specific and highlighted consent where that is the selected legal basis.

International transfers are addressed in Section 16.4.

18.9 EU, UK, and Swiss Representatives

Certain privacy laws require organizations established outside the relevant jurisdiction to designate a local representative.

European Union: Article 27 of the EU GDPR may require a representative when a non-EU organization offers goods or services to individuals in the EU or monitors their behavior and does not qualify for a statutory exemption.

United Kingdom: Article 27 of the UK GDPR may separately require a representative for covered activity involving individuals in the UK, subject to the applicable exemption.

Switzerland: Article 14 FADP contains a distinct test, including regular, large-scale processing presenting high risk.

These determinations depend on actual commercial targeting, monitoring, frequency, processing scale, sensitive information, and associated risks.

The fact that a website is technically accessible from another country does not, by itself, establish that every territorial or representative requirement applies.

However, routine sales or monitoring of individuals in the relevant jurisdiction may trigger obligations even without a local office.

Where a representative is required, the Company must designate that representative and publish the legally required name and contact details.

This Policy does not claim that an EU, UK, or Swiss representative has already been appointed.

Where an appointment is required, the Company must complete it before undertaking the relevant regulated processing, rather than treating its United States contact details as a substitute.

18.10 Other Jurisdictions

Additional rights, notices, obligations, or remedies may apply under the laws of other jurisdictions.

Nothing in this Policy is intended to remove mandatory privacy protections.

19. Children's Privacy

The Company’s educational offerings, professional services, memberships, and research participation are intended exclusively for adults.

Participants must be at least 18 years old and have reached the legal age of majority in their jurisdiction.

The Company does not provide a parental-consent pathway allowing minors to participate in these offerings.

If we become aware that personal information has been collected from an ineligible minor in connection with Company services, we will take appropriate action according to applicable law.

Concerns may be reported to:

admin@emotive.energy

20. Changes to This Privacy Policy

The Company may revise this Policy as its services, technologies, information practices, or legal obligations change.

The current version will be available at:

https://emotive.energy/privacy-policy/

The revision or effective date will be updated as appropriate.

Material changes will be communicated where required by law.

A revised Policy does not retroactively authorize unrelated uses of sensitive information where additional notice or consent is legally required.

New activities requiring additional lawful bases, safeguards, or permission must satisfy those requirements before implementation.

21. Contact Information

For questions concerning this Privacy Policy, personal information, educational assessments, research, or privacy rights, contact:

emotive.energy LLC
1968 S. Coast Hwy, Suite 3310
Laguna Beach, CA 92651
United States

Email: admin@emotive.energy

Website: https://emotive.energy

Privacy Policy: https://emotive.energy/privacy-policy/

Cookie Policy: https://emotive.energy/cookie-policy/

Terms of Use: https://emotive.energy/terms-of-use/

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