1. Scope and roles
This Policy applies to personal information we process as a controller (we decide the purposes and means) when you visit the Site, request a workflow diagnostic, or communicate with us.
When we process Customer Data on your behalf as part of the Service — for example, leads, client records, or mailbox content you authorize us to access — we act as a processor / service providerunder your instructions and the data-processing terms in your Order. Your privacy notice to your own customers and contacts governs that data; we help you honor it. Customer Data is addressed further in Sections 4, 5, and 7.
If we later serve visitors in the European Economic Area or United Kingdom, we will supplement this Policy with GDPR-specific disclosures and a lawful-basis table before intentionally targeting those regions.
2. Information we collect
We collect the following categories of personal information, depending on how you interact with us:
Provided directly by you
- Contact and account information — name, business name, email, phone, role, and messages you send us.
- Meeting and sales information — scheduling details, discovery notes you share, and Order information.
- Payment information — billing contact and transaction metadata; payment card data is handled by our payment processor, not stored on our servers.
- Support and feedback — content of support requests and survey responses.
Collected automatically on the Site
- Device and usage information — IP address, browser type, pages viewed, referring URL, and timestamps.
- Cookie and similar-technology data — see Cookie Policy and Section 6.
Service and Customer Data (processor role)
- Customer Data you authorize — e.g., CRM, inbox, and calendar content scoped to the integrations and workflows in your Order. We access only what you approve.
- Operational metadata — logs, queues, and approval records necessary to run, monitor, and audit workflows.
We do not intentionally collect sensitive personal information (as defined by the CCPA) beyond what is necessary to provide the Service, and we do not infer sensitive characteristics about you.
3. Sources
We collect personal information directly from you, automatically from your device when you use the Site, from integrations you authorize, and from service providers that help us operate (e.g., hosting, analytics, scheduling, payment processing).
4. How we use information
We use personal information to:
- Provide, secure, and improve the Site and — per your instructions — the Service.
- Respond to inquiries, schedule and conduct workflow diagnostics, and communicate about the Service.
- Process transactions, manage Orders, and provide support and handoff documentation.
- Personalize content and measure Site performance (using cookies only as described in our Cookie Policy and subject to your consent where required).
- Comply with law, enforce our Terms, and protect rights, safety, and security.
- With your consent or as otherwise permitted, send updates about services, availability, and offerings — you may opt out at any time.
We do not use personal information to make solely automated decisions with legal or similarly significant effects without human involvement, and we do not use AI to provide licensed professional judgment.
5. How we share information
We share personal information only as described below:
- Service providers / processors — vendors that help us operate, such as hosting (Vercel), AI model providers you approve or that we use to power features, email and scheduling tools, and payment processors. They may use information only to provide services to us and subject to contractual safeguards.
- Integrations you authorize — when you connect a third-party system, data flows to that system per its terms.
- Business transfer — if we form the dedicated operating company, undertake a financing, merger, acquisition, or asset transfer, personal information may be transferred as part of that transaction subject to this Policy.
- Legal and safety — to comply with law, respond to lawful requests, or protect rights and safety.
- With your direction or consent — for example, when you ask us to share information with a colleague or partner.
6. Cookies and similar technologies
We use essential cookies to run the Site (load balancing, security, remembering your consent choices) and, only with your consent where required, functional and analytics cookies to understand Site use and improve it. We do not use analytics or advertising cookies before you have a chance to consent, and you may withdraw consent at any time. See the Cookie Policy for categories, examples, retention, and controls.
7. Retention
We retain personal information only as long as necessary for the purposes described in this Policy, to provide the Service, to comply with legal and accounting obligations, and to resolve disputes. Site inquiry and marketing contact data is typically retained for up to 24 months after last contact unless you ask us to delete it sooner or you become a customer (in which case Order terms apply). Customer Data retention is governed by your Order; at termination we return or delete Customer Data per the Order and then delete residual copies within a reasonable period, subject to legal holds and backup retention.
8. Security
We use administrative, technical, and physical safeguards appropriate to the nature of the data, including encryption in transit, access controls, least-privilege integrations, and scoped approvals. No system is perfectly secure, so we cannot guarantee absolute security. If we learn of a data incident affecting your personal information we will notify you as required by law and take steps to mitigate it.
9. Your choices
- Marketing email: Every marketing email includes an unsubscribe link or instructions. You may also email brian@allebs.com. Transactional and Service notices are not marketing.
- Cookies: Use the consent banner and your browser controls described in the Cookie Policy to accept or decline non-essential cookies. Declining does not affect essential Site functions.
- Access and deletion: You may request access, correction, or deletion of your personal information as described in Section 10. Customers may also use in-Service export and data-return provisions in the Order.
- Do Not Track / GPC: See Section 14.
10. California privacy rights (CCPA/CPRA)
This section applies to California residents and supplements the rest of this Policy. For purposes of the CCPA/CPRA, Empowered.Guru LLC is the “business” for Site data and a “service provider / processor” for Customer Data processed on your behalf.
Categories we collect and disclose
In the past 12 months we have collected — and disclosed to service providers for business purposes — the following CCPA categories from the sources in Section 3:
- Identifiers (name, email, phone, account identifiers, IP address)
- Customer records (business contact and transaction information)
- Internet/network activity (Site usage, device, and cookie data — only with consent for non-essential cookies)
- Professional information (role, business name, discovery notes you share)
- Inferences drawn from the above to improve the Site and, for customers, to configure workflows — not sensitive inferences
We retain each category as described in Section 7.
Sale, share, and targeted advertising
We do not sell personal information for money. We do not currently “sell” or “share” personal information as those terms are defined under the CCPA for cross-context behavioral advertising, and we do not knowingly sell or share personal information of consumers under 16. If we later use analytics or advertising cookies or pixels that could constitute a “sale” or “share” under the CCPA, we will update this Policy, honor your opt-out preference signals (Section 14), and provide the opt-out rights described below before engaging in that activity.
Sensitive personal information
We do not collect or use sensitive personal information to infer characteristics, and we do not use it beyond what is necessary to provide the Service you request.
Your CCPA rights
Subject to exceptions and verification, California residents have the rights to:
- Know / access — the categories and specific pieces of personal information we collected about you, sources, purposes, and categories of disclosure.
- Delete — request deletion of personal information we collected from you.
- Correct — request correction of inaccurate personal information.
- Opt out of sale/share and targeted advertising — to the extent we ever engage in activity that qualifies; you may exercise this at any time via the methods below and via GPC (Section 14).
- Limit use of sensitive personal information — applicable if we collect it beyond what is necessary; you may request we limit it to what is necessary.
- Non-discrimination — you will not be discriminated against for exercising these rights.
How to exercise
Email brian@allebs.com with subject “Privacy request” or call 218-420-1097. You may authorize an agent to act on your behalf with signed permission. We will verify your request (which may include confirming details you previously provided) and respond within the time required by law (typically 45 days, extendable once). We will not charge a fee unless the request is manifestly unfounded or excessive.
Customers: requests about Customer Data held as a processor will be directed to the business customer that controls that data, unless the customer instructs us otherwise or the law requires us to act directly.
Shine the Light
California residents may also request information about our disclosure of personal information to third parties for their own direct marketing purposes in the prior calendar year (Civil Code § 1798.83). To make such a request, use the contact above with subject “Shine the Light.”
11. Other U.S. state rights
Residents of other states with comprehensive privacy laws (including Colorado, Connecticut, Utah, and Virginia, among others) may have similar rights to access, correct, delete, and opt out of targeted advertising and sales of personal information. We honor those rights as applicable. To exercise them, use the contact in Section 10. We will treat a universal opt-out signal as described in Section 14 as a valid opt-out where the law requires.
12. International visitors and transfers
The Site and Service are operated in the United States. If you visit from outside the U.S., your information is transferred to and processed in the U.S., where data-protection laws may differ. By using the Site or Service you consent to that transfer. If we expand internationally we will add appropriate transfer mechanisms and disclosures.
13. Children
The Site and Service are not directed to children under 16 and we do not knowingly collect personal information from them. If you believe a child has provided personal information, contact us and we will delete it.
14. Do Not Track and Global Privacy Control
Some browsers send “Do Not Track” (DNT) signals and others send the Global Privacy Control (GPC) signal. There is no uniform DNT standard, but we treat GPC as a valid opt-out of any future sale, share, or targeted-advertising activity to the extent required by applicable law. When we detect GPC, we will treat the browser as having opted out of non-essential cookies and any qualifying sale/share without requiring you to take further steps. You may also manage cookies via the Cookie Policy controls.
15. Changes and contact
We may update this Policy from time to time. Material changes will be posted with a new effective date; for customers, we will also give notice by email or in-Service notice at least 30 days before material changes take effect where required. Continued use after the effective date is acceptance.
Contact for privacy matters: Empowered.Guru LLC — brian@allebs.com · 218-420-1097. Mailing address to be added upon entity formation. For verified privacy-rights requests use the methods in Section 10.