Website Privacy Policy

1. Introduction

Redeemed Arrow Behavior Consulting LLC (“Company,” “we,” “us,” or “our”) operates the website located at www.redeemedarrow.com (the “Website”). This Website Privacy Policy (this “Policy”) describes how we collect, use, disclose, and protect personal information that we receive from visitors to and users of the Website. This Policy applies solely to information collected through the Website and does not govern information collected through other means, including offline interactions or the Mighty Platform used to deliver our coaching services.

This Policy is incorporated by reference into our Website Terms and Conditions, which are available on the Website. By accessing or using the Website, you acknowledge that you have read and understand this Policy. Your continued use of the Website following the Effective Date constitutes your agreement to the data practices described in this Policy.

We reserve the right to update or modify this Policy at any time. Material changes will be indicated by a revised Effective Date posted at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Website after any modification constitutes your acceptance of the updated Policy.

2. User Acknowledgment and Consent

By accessing or using the Website, you acknowledge and consent to the following:

• (a) We collect the categories of personal information described in Section 3 of this Policy.
• (b) We use your personal information for the purposes described in Section 4 of this Policy.
• (c) We may share your personal information with the categories of third parties described in Section 5 of this Policy.
• (d) We use cookies and other tracking technologies as described in Section 6 of this Policy, and you consent to such use unless you exercise the opt-out rights described in Section 9.
• (e) The information you provide through this Website is not protected health information under HIPAA, as described in Section 7 of this Policy.

If you do not consent to the data practices described in this Policy, you must discontinue use of the Website. Certain features of the Website may not function properly if you opt out of particular data collection practices as described in Section 9.

3. Information We Collect

3.1 Information You Provide To Us Directly

We collect personal information that you voluntarily provide when you interact with the Website, including when you submit an inquiry through the Contact Us form, register for or purchase services, or otherwise communicate with us. The categories of personal information we may collect directly from you include:

• Name
• Email address
• Postal address
• Telephone number
• Customer number, order number, or other unique identifier
• Payment card information (collected and processed through a third-party payment processor)

3.2 Information Collected Automatically

When you visit the Website, certain information is collected automatically through cookies, web beacons, pixel tags, and similar tracking technologies. This automatically collected information may include:

• IP address
• Browser type and version
• Operating system
• Pages viewed and time spent on the Website
• Referring URL
• Website analytics data collected through Google Analytics or similar services
• Advertising tracking data collected through cookies, Facebook pixel, and similar tools

For more information about how we use cookies and tracking technologies, and how you may opt out, see Section 6 (Cookies and Tracking Technologies) and Section 9 (Your Choices and Opt-Out Rights).

3.3 Information We Do Not Intentionally Collect

We do not intentionally collect sensitive personal information such as Social Security numbers, government-issued identification numbers, financial account credentials, biometric data, precise geolocation data, or health or medical information through the Website. Please do not submit this type of information through the Contact Us form or any other feature of the Website. See Section 7 for important information regarding health information and HIPAA.

4. How We Use Your Information

We use the personal information we collect for the following purposes:

• (a) to respond to your inquiries submitted through the Contact Us form or other Website features;
• (b) to provide, administer, and improve our coaching services and Website;
• (c) to process transactions and send related information, including confirmations and receipts;
• (d) to send you administrative communications, such as updates to this Policy or our Terms and Conditions;
• (e) to send you marketing or promotional communications about our services, where you have not opted out of receiving such communications;
• (f) to analyze Website usage and improve user experience through analytics tools including Google Analytics;
• (g) to deliver targeted advertising and measure the effectiveness of advertising campaigns through tools such as the Facebook pixel;
• (h) to enforce our Website Terms and Conditions and protect the rights, property, and safety of the Company, our users, and others;
• (i) to comply with applicable legal obligations; and
• (j) to carry out any other lawful purpose.

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects without human review.

5. How We Share Your Information

We do not sell your personal information to third parties for their own independent marketing purposes, except as may be required to comply with our obligations to you or as otherwise described in this Policy. We may share your personal information in the following circumstances:

5.1 Service Providers

We share personal information with third-party vendors and service providers that perform services on our behalf, including:

• billing and invoicing platforms;
• payment card processors (who process payment card information directly and are subject to Payment Card Industry Data Security Standard requirements);
• website hosting and technology providers;
• email communication platforms; and
• analytics providers, including Google Analytics.

These service providers are authorized to use your personal information only as necessary to perform services for us and are subject to confidentiality obligations.

5.2 Social Media Platforms

The Website is connected to the Company's business pages on Facebook, Instagram, and X. If you interact with social media features on the Website, including social sharing buttons or embedded content, information about your interaction may be shared with those platforms in accordance with their respective privacy policies. We encourage you to review the privacy policies of any social media platform before interacting with its features.

5.3 Organizational Partners

We may share personal information with organizational partners in connection with the delivery of our coaching services to foster parents. Any such sharing is conducted pursuant to appropriate data sharing arrangements and limited to information necessary for the partner's role.

5.4 Mighty Platform

Our coaching services are delivered in part through the Mighty Platform operated by Mighty Networks. When you access our services through the Mighty Platform, information you provide in connection with those services is subject to the Mighty Networks privacy policy in addition to this Policy. We encourage you to review the Mighty Networks privacy policy, available here [           ] before creating an account on the Mighty Platform.

5.5 Third-Party List Sharing

The Company may maintain a list of companies with whom it shares, leases, or otherwise makes available client or user personal data for purposes related to the delivery of services. You may request a copy of that list by contacting us at info@redeemedarrow.com. Where applicable law requires us to provide notice of or obtain consent for such sharing, we will do so in accordance with that law.

5.6 Legal Requirements and Business Transfers

We may disclose personal information if we believe in good faith that such disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our Terms and Conditions or this Policy; (c) protect the rights, property, or safety of the Company, our users, or others; or (d) detect, prevent, or address fraud, security, or technical issues. We may also disclose or transfer personal information in connection with a merger, acquisition, financing, or sale of all or a portion of our assets, subject to standard confidentiality obligations.

6. Cookies and Tracking Technologies

We use cookies, pixel tags, web beacons, and similar tracking technologies to collect information about your use of the Website and to deliver advertising. The following categories of tracking technologies are used on the Website:

• (a) Essential cookies: necessary for the Website to function and cannot be disabled.
• (b) Analytics cookies: used to understand how visitors interact with the Website, including through Google Analytics. Google Analytics collects information such as pages visited, time on site, and referral source. Information generated by Google Analytics cookies is transmitted to and stored by Google. For more information, see Google's privacy policy at policies.google.com.
• (c) Advertising and retargeting cookies: used to deliver advertisements relevant to your interests and to measure advertising effectiveness, including through the Facebook pixel. Facebook pixel transmits certain Website usage data to Meta Platforms, Inc. For more information, see Meta's privacy policy at facebook.com/privacy/policy.

Most web browsers allow you to control cookies through browser settings. You may also opt out of specific tracking technologies as described in Section 9. Note that disabling certain cookies may affect the functionality of the Website.

7. Important Notice Regarding Health Information and HIPAA

Please read the following notice carefully before submitting any information through this Website.

The coaching services offered through this Website are intended to support and educate foster parents. They are not healthcare services and are not intended to constitute, and must not be used as a substitute for, professional medical advice, diagnosis, or treatment. Nothing on this Website creates a patient-provider, therapist-client, or any other clinical or treatment relationship.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to maintain business records, and to comply with applicable legal obligations. When personal information is no longer needed for these purposes, we take reasonable steps to delete or de-identify it. The specific retention period for a category of personal information depends on the nature of the information, the purpose for which it was collected, and applicable legal requirements. You may request deletion of your personal information as described in Section 9.

9. Your Choices and Opt-Out Rights

You have the following choices regarding our collection and use of your personal information:

9.1 Marketing Communications

If you no longer wish to receive marketing or promotional emails from us, you may opt out by clicking the “unsubscribe” link included in any marketing email we send you, or by contacting us at info@redeemedarrow.com with the subject line "Unsubscribe." Please note that even if you opt out of marketing communications, we may continue to send you transactional or administrative communications related to your use of our services.

9.2 Google Analytics

You may opt out of Google Analytics data collection by installing the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout. You may also adjust your browser settings to refuse cookies, which will limit Google Analytics tracking.

9.3 Facebook Pixel and Meta Advertising

You may opt out of interest-based advertising delivered through the Facebook pixel by adjusting your ad preferences in your Facebook account settings, or by visiting the Digital Advertising Alliance opt-out page at optout.aboutads.info. You may also use the Network Advertising Initiative opt-out tool at optout.networkadvertising.org.

9.4 Cookies Generally

Most web browsers allow you to refuse or delete cookies through browser settings. The method for doing so varies by browser; refer to your browser's help documentation for instructions. Note that disabling cookies may affect the functionality of the Website and may prevent certain features from working properly.

9.5 Do Not Track

Some browsers offer a “Do Not Track” (“DNT”) feature that sends a signal to websites requesting that your browsing activity not be tracked. The Website complies with applicable law with regard to the alteration of its data collection practices in response to DNT signals.

9.6 California Residents — CCPA/CPRA Privacy Rights

If you are a California resident, you may have certain rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if applicable to our business, including:

• (a) Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the purposes for collection and use, and the categories of third parties with whom we share it.
• (b) Right to Delete: You may request deletion of personal information we have collected about you, subject to certain exceptions.
• (c) Right to Correct: You may request correction of inaccurate personal information we maintain about you.
• (d) Right to Opt Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under the CCPA without providing a mechanism to opt out. If we do sell or share personal information, we will update this Policy and provide an opt-out mechanism as required by law.
• (e) Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information as defined under the CCPA and the law applies to our activities, you may have the right to limit our use of that information to purposes permitted by law.
• (f) Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To submit a CCPA rights request, contact us at info@redeemedarrow.com with the subject line “Data Request – California Resident.” We will respond to verifiable requests within the timeframe required by the CCPA as applicable to our business. We may ask you to verify your identity before processing your request.

9.7 Illinois Residents

If you are an Illinois resident, you may have rights under the Illinois Personal Information Protection Act (815 ILCS 530) with respect to the personal information you have shared with us. To submit a request to access, correct, or delete your personal information, contact us at info@redeemedarrow.com with the subject line “Data Request – Illinois Resident.” We will respond in accordance with applicable Illinois law. You will be notified in the event of any unauthorized disclosure of your information consistent with Illinois law.

10. Privacy of Minors

The Website is not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verifiable parental consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected personal information from a child under 18, please contact us at info@redeemedarrow.com.

11. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your personal information. You submit personal information through the Website at your own risk. If you believe your personal information has been compromised following your use of our Website, please contact us promptly at info@redeemedarrow.com.

Payment card information is processed directly by our third-party payment processor and is subject to that processor's security standards, including Payment Card Industry Data Security Standard (“PCI DSS”) compliance.

12. Third-Party Websites and Links

The Website contains links to third-party websites, including billing platforms, payment processors, informational resources, social media pages, and organizational partner websites. This Policy applies only to information collected through our Website. We are not responsible for the privacy practices of any third-party website, and we encourage you to review the privacy policy of any third-party website before providing personal information. The inclusion of a link to a third-party website does not constitute an endorsement of that website or its privacy practices.

13. Integration with Website Terms and Conditions

This Policy is incorporated by reference into and forms part of the Website Terms and Conditions of Redeemed Arrow Behavior Consulting LLC. In the event of a conflict between this Policy and the Terms and Conditions on matters of data collection, use, or disclosure, this Policy controls. Your use of the Website is also governed by the Terms and Conditions, which are available on the Website and address additional topics including intellectual property rights, disclaimers, limitations of liability, and warranties.

14. Contact Us

If you have questions about this Policy, wish to exercise your privacy rights, or wish to request a copy of our third-party data-sharing list, please contact us at:

Redeemed Arrow Behavior Consulting LLC
info@redeemedarrow.com
www.redeemedarrow.com