Privacy Policy
Privacy Policy
1. Introduction
This Privacy Policy describes how Career Coaching Plus, LLC, operating under the brand name “Passport to Life”, collects, uses, discloses, stores, and protects your personal information when you engage with our services. These services include, but are not limited to, our website, online content, educational programs, coaching sessions, event registrations, and any affiliated mobile or digital platforms (collectively referred to as “Digital Services” available at https://www.passporttolife.org).
By accessing or using any of our Digital Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information in accordance with its terms.
2. Information We Collect
We collect various types of information in connection with your use of our Digital Services, as available at https://www.passporttolife.org. This includes:
a. Personal Data You Provide to Us Directly
When you interact with Passport to Life, you may voluntarily provide us with the following types of personal information:
- Your name, email address, phone number, billing and shipping addresses
- Payment information (processed securely via third-party payment platforms)
- Information submitted via forms, surveys, registration pages, or purchase checkouts
- Comments, feedback, testimonials, or other content you provide (“Customer Content”)
- Login credentials or identifiers for Passport to Life accounts or third-party logins (e.g., Facebook)
b. Automatically Collected Information
When you access our Digital Services, we automatically collect certain technical data, including:
- Your Internet Protocol (IP) address and general location
- Browser type and operating system
- Referring and exit pages, time of visit, and session duration
- Clickstream and browsing behavior
- Device identifiers, cookies, beacons, pixel tags, and analytics data
This data helps us maintain the functionality and security of our platform, understand user behavior, improve our offerings, and ensure compliance with legal obligations
c. Sensitive or Special Category Data
In limited circumstances, you may submit information that qualifies as special category or sensitive data (e.g., health-related information or religious affiliation via event registration or delivery addresses). We process such data only as necessary and with appropriate legal safeguards.
d. Third-Party and Indirect Sources
We may receive personal information about you from:
- Referral sources or gift senders
- Publicly available sources or social media platforms
- Payment processors or logistics partners (e.g., order delivery status)
We take reasonable steps to ensure any third-party sources have a lawful basis to share your information with us.
3. How We Use Your Information
We use the personal information we collect from you for a variety of legitimate business purposes, which may include:
a. To Fulfill a Contract or Provide Requested Services
- Processing and delivering product orders or event tickets
- Managing subscriptions, appointments, or class registrations
- Sending transaction confirmations, receipts, and reminders
- Managing user accounts and access to protected content
- Responding to your inquiries or service requests
- Providing technical assistance and troubleshooting
- Sending necessary administrative updates (e.g., policy changes)
c. For Legal, Compliance, and Security Purposes
- Fulfilling obligations under applicable laws and regulations
- Investigating fraud or misuse of services
- Maintaining internal records for accounting and legal
defense - Enforcing our Terms of Use or responding to legal requests
d. For Business Optimization and Development
- Improving our website and digital content
- Conducting internal analytics and performance evaluation
- Testing new features, promotions, or offerings
e. With Your Consent (where required)
- Sending you newsletters or promotional communications
- Personalizing your experience based on your preferences
- Offering third-party promotions or co-branded campaigns
We process your information only when we have a lawful basis for doing so—such as fulfilling a contract, meeting legal obligations, pursuing legitimate business interests, or with your consent where required by law.
4. Legal Bases for Processing
We process your personal information only when we have a valid legal basis to do so under applicable data protection laws. These legal bases include:
a. Performance of a Contract
We process your data to fulfill our contractual obligations—such as completing a purchase, delivering a service, or
responding to a service request.
b. Your Consent
Where required by law (e.g., for sending marketing communications or using non-essential cookies), we rely on your prior and explicit consent. You may withdraw your consent at any time by contacting us or adjusting your settings.
c. Legitimate Interests
We may process your data where necessary for our legitimate business interests, such as:
- Improving user experience and service quality
- Securing our digital platforms
- Preventing fraud or misuse
- Understanding user engagement and trends
We balance our interests with your rights and expectations and process data only in ways that are proportionate and
respectful of your privacy.
d. Compliance with Legal Obligations
We may process your data to comply with applicable laws, such as tax, accounting, anti-fraud, or consumer protection regulations.
e. Protection of Vital Interests
In rare cases, we may process your data to protect your safety or the safety of others, especially in the context of
event operations or emergencies.
5. Cookies and Tracking Technologies
a. What Are Cookies?
Cookies are small text files placed on your device when you visit a website. They allow the site to recognize your browser and
remember certain information such as user preferences, authentication tokens, and session data.
We may also use:
- Web beacons or pixel tags
- HTML5 local storage
- Embedded scripts
- Software development kits (SDKs)
These technologies help us understand how users interact with our site, which pages are visited most often, and how we can improve
our offerings.
We categorize cookies as follows:
- Essential Cookies – Necessary for site functionality (e.g., logging in, completing transactions)
- Performance & Analytics Cookies – Help us understand usage patterns using tools like Google Analytics
- Functionality Cookies – Remember user settings such as region or language
- Advertising Cookies – Used to personalize ads and measure the effectiveness of campaigns (only with your consent)
c. Third-Party Cookies and Tools
We may allow third-party service providers to place cookies on our site for analytics, social sharing, or advertising. These third
parties may include:
- Google Analytics
- Facebook Pixel
- Shopify, Klaviyo, Zendesk, and Return Magic (eCommerce infrastructure and support tools)
d. We may also use “X” (formerly Twitter) for advertising, audience engagement, and analytics. This may include the use of tracking technologies such as pixels or cookies provided by X to deliver customized content, measure campaign effectiveness, and
retarget users who have interacted with our Digital Services. Your interactions with such features are governed by X’s privacy policy.
We provide a cookie banner to give you control over non-essential cookies. You can choose to:
- Accept all cookies
- Customize your cookie preferences
- Reject non-essential cookies
Most browsers also allow you to block or delete cookies through settings. Please note that disabling certain cookies may limit the functionality of our website.
f. Do Not Track Signals
We do not currently respond to browser-based “Do Not Track” signals.
g. Treatment of Cookie Data as Personal Data
Where applicable law considers cookies or tracking data (e.g., IP address, device ID) as Personal Data, we treat such data accordingly
and apply the same privacy protections as set out in this Policy.
6. Sharing of Personal Data
comply with legal obligations. We do not sell your Personal Data. We only disclose information under the conditions outlined below:
a. Service Providers and Business Partners
We may share your Personal Data with third-party vendors, contractors, and service providers that perform services on our behalf, such as:
- Payment processors (e.g., PayPal, Apple Pay)
- E-commerce platforms (e.g., Shopify, Printful)
- Email marketing tools (e.g., Klaviyo)
- Customer support services (e.g., Zendesk, Return Magic)
- Delivery, logistics, and fulfillment services
These providers are contractually obligated to protect your information and may not use it for any purpose other than
delivering services to us.
If you opt into a co-branded or partner promotion, we may share limited Personal Data with such partners solely to administer the
program. This may include sweepstakes, events, or bundled services. These partners must process your information in accordance with their own privacy policies.
c. Legal Compliance and Law Enforcement
We may disclose your Personal Data:
- To comply with legal obligations, subpoenas, court orders, or law enforcement requests
- To investigate fraud, security breaches, or potential violations of our Terms of Use
- To protect the rights, property, or safety of our business, users, or the public
d. Business Transfers
will take reasonable steps to notify users in advance via email or public notice.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to:
- Provide the services you have requested
- Complete your transactions
- Comply with our legal, regulatory, accounting, or reporting obligations
- Resolve disputes and enforce our agreements
- Protect against fraud, misuse, or unauthorized access
a. General Retention Period
We retain user data only as long as it is relevant for business and legal purposes. For example:
- Order records and transaction data may be retained for up to 7 years to comply with tax and audit requirements
- Customer support correspondence may be retained for up to 3 years for quality assurance and follow-up
- Website usage and analytics data may be retained for 1–2 years, subject to cookie settings and consent
b. Marketing Data
If you opt-in to receive marketing communications, we will retain your contact information until you unsubscribe or withdraw consent. If you opt out, we will maintain your request on a suppression list to avoid further contact.
If you provide third-party data (e.g., to send a gift or refer a friend), we will retain that data only as necessary to fulfill the request and for fraud prevention, after which it will be deleted or anonymized.
Even after deletion or deactivation, some data may remain stored in backups or archives for a limited time where legally permissible.
8. Your Rights and Choices
Where we rely on legitimate interests as our basis for processing, you may object to such processing on grounds relating to your particular situation. We will honor your objection unless we have compelling legitimate grounds to continue.
You may request that we restrict the processing of your personal data if:
- You contest its accuracy
- Processing is unlawful and you oppose deletion
- We no longer need the data but you require it for a legal claim
- You have objected and we are verifying our grounds
Where processing is based on your consent (e.g., marketing),you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before the withdrawal.
You may opt out of receiving marketing communications by:
- Clicking the “unsubscribe” link in our emails
- Emailing us directly at unsubscribe@passporttolife.org
h. Right to Non-Discrimination
We will not deny services, charge different prices, or provide a different level of quality based solely on your exercising of privacy rights under applicable law.
To exercise any of these rights, please contact us using the information provided in the “Contact Us” section below. We may request proof of identity where necessary to protect your information.
9. International Transfers
- For users located in the EEA, UK, or Switzerland, we rely on Standard Contractual Clauses (SCCs) or equivalent safeguards approved by the European Commission or relevant data protection authority
- We ensure our third-party service providers have appropriate data protection safeguards in place (e.g., Data Processing Agreements or adherence to Privacy Shield principles, where applicable)
- Where required, we obtain your explicit consent prior to such transfers
b. Your Acknowledgment
10. Data Security
- Secure server infrastructure and firewall protection
- Industry-standard encryption during transmission of sensitive data (e.g., payment information)
- Password protection, role-based access controls, and authentication protocols
- Regular monitoring and vulnerability assessments
b. Organizational Safeguards
- Employee access to personal data is limited to those who require it to perform their job duties
- Confidentiality agreements and security training for personnel and contractors
- Data processing agreements with vendors and sub-processors
c. Payment Processing Security
11. Children’s Privacy and Age Restriction
We do not knowingly collect, use, or disclose personal information from individuals under 21 without verified parental or legal guardian consent, where such consent is permissible and required by law.
a. U.S. and International Compliance
- In the United States, we comply with the Children’s Online Privacy Protection Act (COPPA), which restricts the collection of personal data from children under 13 without verified parental consent.
- In the European Economic Area (EEA), UK, and similar jurisdictions, we comply with the local age of digital consent (typically 16), while maintaining our own platform minimum of 21.
- In all jurisdictions, our services are intended only for persons aged 21 or older, unless otherwise authorized
b. Prohibited Use by Underage Individuals
If we become aware that we have collected personal data from an individual under 21 without the proper authorization, we will take steps to immediately delete that information. Individuals under 21 are not permitted to:
- Create an account or register for classes
- Submit Customer Content (e.g., reviews, testimonials, media)
- Participate in events, coaching programs, or other services
- Engage in transactions, contests, or communications through our platform
If you believe that someone under the age of 21 has submitted personal information through our Services in violation of these terms, please contact us at privacy@passporttolife.com . We will investigate promptly and take all appropriate action to ensure compliance and data deletion where applicable.
12. California Privacy Rights (CCPA/CPRA)
You have the right to request that we disclose:
- The categories and specific pieces of personal information we have collected about you
- The sources from which we collected your personal information
- The business or commercial purposes for which we collected or shared your information
- The categories of third parties with whom we have disclosed your information
- Whether we sold or shared your personal information (we do not)
You may request a copy of the personal information collected about you in a readily usable and transferable format.
d. Right to Correct
You may request that we correct any inaccurate personal information that we maintain about you.
We do not sell or share your personal information as defined under the CCPA/CPRA. If that changes in the future, we will provide a clear mechanism to opt out.
f. Right to Limit Use of Sensitive Personal Information
If we collect sensitive personal information (as defined under CPRA), you have the right to limit its use to essential services only.
13. Changes to This Policy
We encourage you to review this Privacy Policy periodically. In cases where the changes are material, we will:
- Provide a prominent notice on our website or Digital Services
- Contact you via email (if we have your contact information). You may also reach us via our website at https://www.passporttolife.org.
- Request renewed consent if required under applicable law
changes. If you do not agree with the modified terms, you should discontinue use of the services and may contact us to
request the deletion of your data.
14. Business Transfers
b. Assignment of Rights
of our assets or business may continue to use your personal data as set forth in this Policy.
- A public notice on our website, and/or
- Direct email communication where feasible
15. Contact Us
privacy@passporttolife.comSubject Line: “PRIVACY – [Include Your Website or Service]”
Mail your inquiry to: Chief Privacy Officer
c/o VP-Finance
126 Thresher Lane
Stafford, VA 22554
If you are a California resident and wish to make a data rights request under the CCPA/CPRA, please include:
- “California Privacy Rights Request” in your subject line or letter
- Your full name and a valid California address for verification
- A description of your request and relationship with Passport to Life
