Privacy Policy

This Privacy Policy describes how Routine Evolution LLC, a Wyoming limited liability company with its registered office at 30 N Gould Street, Suite R, Sheridan, Wyoming 82801, United States ("Company," "we," "us," "our"), collects, uses, processes, and discloses your personal data when you access or use any of our websites (including www.kyrabolzan.com), digital programs, services, online content, and affiliated tools or platforms, including Kajabi and Stripe (collectively referred to as the "Services").

By using the Services, you agree to the terms of this Privacy Policy.

1. PERSONAL DATA WE COLLECT

When you interact with our Services, we may collect the following categories of data:

Information you provide to us directly:

Full name
Email address
Billing address
Payment details (processed via Stripe)
Account login credentials (Kajabi platform)
User-generated content or feedback
Questionnaire or form responses

Automatically collected data:

IP address
Device identifiers
Browser type
Usage activity on our site or platform (Kajabi analytics)
Referral source

Sensitive data: We do not intentionally collect sensitive personal data (e.g., health data, biometric data, religious beliefs). If such data is shared voluntarily (e.g., in a coaching intake form), it will be handled in accordance with applicable data protection laws. By submitting such information, you consent to our limited use of that data strictly for the purpose of providing the Services. We do not use, sell, or process sensitive data beyond what is necessary for your requested interaction.

2. HOW WE USE YOUR INFORMATION

We use your personal data for the following purposes:

To deliver purchased digital products, programs, and services
To manage your account and user access via Kajabi
To process payments securely through Stripe
To send transactional and marketing communications (via Kajabi’s email system)
To provide customer support and technical assistance
To improve the performance and usability of our Services
To comply with legal obligations

We process your data only where we have a lawful basis to do so under Article 6 of the GDPR, including:

Contractual necessity – to provide the Services and manage payments
Consent – for sending marketing communications (you can withdraw your consent at any time)
Legitimate interests – for fraud prevention, analytics, and improving Services
Legal obligation – where required by applicable law

You can unsubscribe from marketing emails by clicking the "unsubscribe" link in any message or by contacting us at [email protected]. Transactional or essential service-related messages will still be sent.

3. SHARING OF YOUR INFORMATION

We do not sell or rent your personal data. We may share your data only under the following circumstances:

Service Providers: Kajabi (course platform), Stripe (payment processor), Google Meet (video conferencing), and other GDPR-compliant tools we use to deliver the Services.
Legal Requirements: If we are legally required to disclose information by law, court order, or regulatory authority.
Business Transfers: If our business is sold or merged, your data may be transferred as part of that transaction.

All service providers are contractually obligated to protect your data and process it only under our instruction.

4. DATA RETENTION

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy and to meet legal, tax, and accounting obligations.

5. INTERNATIONAL DATA TRANSFERS

Some of our service providers (such as Kajabi and Stripe) may transfer your personal data outside of your country of residence, including to the United States and other jurisdictions that may not provide the same level of data protection as your home country.

For individuals located in the European Economic Area (EEA) or United Kingdom, we rely on legally recognized safeguards under the General Data Protection Regulation (GDPR), such as Standard Contractual Clauses or adequacy decisions, to ensure your personal data remains protected during cross-border transfers.

If you are located outside the United States, you acknowledge and agree that your information may be transferred to and processed in the United States or other countries where our service providers operate.

6. YOUR RIGHTS UNDER GDPR

If you are located in the EEA, you have the following rights under the General Data Protection Regulation (GDPR):

Right to access – Request a copy of the personal data we hold about you
Right to rectification – Request correction of inaccurate or incomplete data
Right to erasure – Request deletion of your data, where lawful
Right to restrict processing – Request limited use of your data under certain circumstances
Right to data portability – Request your data in a machine-readable format
Right to object – Object to data processing, including for direct marketing
Right to withdraw consent – Withdraw your consent at any time

To exercise your rights, email us at [email protected]. We will respond within 30 days as required by law.

6.1 ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS (CCPA/CPRA)

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), including:

Right to know – What categories of personal data we collect, the purposes, and with whom we share it
Right to access – Request a copy of your personal data
Right to correct – Request correction of inaccurate information
Right to delete – Request deletion of personal information, subject to legal exceptions
Right to opt out – We do not sell or share your personal information
Right to limit use – We do not collect or process sensitive personal data for advertising or profiling
Right to non-discrimination – You will not be penalized for exercising your rights

You can exercise these rights by contacting us at [email protected]. We may need to verify your identity before fulfilling your request.

7. SECURITY MEASURES

We implement technical and organizational safeguards to protect your personal data, including:

Encrypted payment processing via Stripe
Secure login controls for Kajabi accounts
Two-factor authentication on internal systems
Access restrictions to sensitive data

While we implement industry-standard safeguards, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for all activities occurring under your login. Please notify us immediately if you suspect unauthorized access.

8. COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar technologies to improve your browsing experience, analyze traffic, and personalize content. You can control cookie preferences through your browser settings or the cookie banner shown when you first visit our site.

We currently use:

Kajabi’s built-in analytics
Google Analytics (if applicable)
Email tracking pixels (within Kajabi email campaigns)

9. CHILDREN’S PRIVACY

Our Services are not intended for children under the age of 18. We do not knowingly collect personal data from minors. If we discover that a minor’s data has been collected, we will delete it promptly.

10. THIRD-PARTY LINKS

Our websites and Services may contain links to third-party websites. We are not responsible for their content or privacy practices. Please review their policies before submitting personal data.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The "Last Updated" date at the bottom of this policy indicates when changes were last made.

12. CONTACT

If you have questions about this Privacy Policy or how we handle your personal data, you may contact us at:

Routine Evolution LLC
30 N Gould Street, Suite R
Sheridan, Wyoming 82801
United States
📧 Email: [email protected]
🌐 Website: www.kyrabolzan.com

Last Updated: 15th July 2025