Privacy Policy

Agreement between User and Kathy Frank Training, LLC

This Privacy Policy applies to Kathy Frank Training, LLC, a Virginia limited liability company (the
“Company”), and governs data collection and usage, and across the Company’s website
www.kathyfranktraining.com, (the “Site”) and related mobile application (the “App”) (the Site and App
are collectively referred to herein as the “Platform”). For purposes of this Privacy Policy, unless
otherwise noted, all references to the Company include the Platform. By using or accessing the
Platform, you consent to the data practices described in this statement.

A. Collection of Your Personal Information.
The Company may collect your personally identifiable information (“PII”) when you access
the Platform, including but not limited to your name, address, phone number, and email
address. This information shall be used to improve our services, enhance the user
experience, and provide access to specialized fitness programming.
If you make a payment to the Company through the Platform, billing and payment details
may be collected and processed securely through a third-party processor. The Company will
not store credit card information.
The Company further does not collect personal information unless you voluntarily provide
it. However, certain features may require PII to function properly, such as account
registration and customer support.
The Company may also collect additional personal or non-personal information in the
future, in compliance with data protection laws.

B. Use of Your Personal Information.
The Company may use PII it collects from you to operate the Platform and provide access to
Platform features, including fitness and wellness programming. The Company may also use
your PII to communicate updates, new features, and special offers. The Company shall
retain PII only for as long as necessary to fulfill the purposes outlined herein, to comply
with any legal obligations, and to resolve disputes.

C. Security of Your Personal Information
The Company strives to take appropriate security measures to protect against unauthorized
access to or alteration of your personal information, including PII and personal health
information (“PHI”). When such information, such as a credit card number, is transmitted to
other websites, it is protected through encryption, such as the Secure Sockets Layer (SSL)
protocol. Unfortunately, no data transmission over the internet or any wireless network is
guaranteed to be fully secure. As a result, while the Company strives to protect your
personal information, you acknowledge that by using the Platform, there are security and
privacy limitations which are beyond the Company’s control. You also acknowledge that the
security, integrity, and privacy of any and all information and data exchanged between you
and the Company through the Platform cannot be guaranteed. In the event of a breach of
your PII, the Company shall provide you with notice in compliance with applicable laws.

D. Sharing Information with Third Parties.
The Company does not sell, rent or lease its user lists to third parties, but may, from time to
time, contact you on behalf of external business partners about a particular offering that

may be of interest to you. In those cases, your information, including PII or PHI, is not
transferred to the third party. The Company may share PII with trusted service partners
who assist with payment processing, customer support, communications, and analytics. . All
third parties are prohibited from using your personal information except to provide these
services to the Company and they are required to maintain the confidentiality of your
information. 
The Company may only disclose your personal information, without notice, if required to do
so by law or in the good faith belief that such action is necessary to: (a) conform to the
edicts of the law or comply with legal process served on the Company or the Platform; (b)
protect and defend the rights or property of the Company; and/or (c) act under exigent
circumstances to protect the personal safety of users of the Company or the public.

E. Health Information Privacy
The Platform provides wellness programming tailored specifically for the health of
pregnant individuals, as well as those who are post-partum. While these programs may
collect or reference general health-related information, this Platform is not a medical
service and does not provide medical advice, diagnoses, or treatment.
Notwithstanding the PII protections above, the Company will obtain consent and take all
reasonable measures to protect the privacy and security of any user health information
transmitted on the Platform in accordance with the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and other applicable laws. Said PHI may include but not
be limited to medical history or diagnoses of any kind. To that end, the Company shall only
use or disclose your PHI as you permit or as required by law. Any third parties with whom
we are permitted to share PHI are required to uphold similar privacy and security
standards.

Subject to the terms of this policy, the Company shall implement reasonable administrative
and technical safeguards to protect your PHI from unauthorized access, use, or disclosure.
However, you understand and acknowledge that the Company, to the fullest extent
permitted by law, disclaims liability for any unauthorized access, use, or disclosure of PHI
arising from security incidents beyond the Company’s reasonable control, your failure to
safeguard credentials, devices, or personal access, and communications or disclosures made
at your direction or with your consent. This limitation does not apply to disclosures
resulting from the Company’s willful misconduct or gross negligence.
You have the right to access, amend, and control the disclosure of your PHI as permitted by
law. If you have any questions about how your health information is used or would like to
exercise your rights, please contact us using the information at the bottom of this policy.

F. Tracking User Behavior.
The Company may keep track of the specific programs and pages accessed by users of the
Platform in order to determine which the Company services are most popular. This data is
used to deliver customized content and advertising within the Platform to users whose
behavior indicates that they are interested in a particular offering.

G. Automatically Collected Information.
Information about your computer hardware and software may be automatically collected
by the Company. This information can include but is not limited to your IP address, browser

type, domain name(s), access times, and referring website addresses. This information is
used for the operation of the Company’s services, to maintain quality of the services, and to
provide general statistics regarding use of the Platform. This information is generally
utilized in the aggregate and does not personally identify individual users unless combined
with PII.

H. Use of Cookies
The Platform may use “cookies” to help you personalize your online experience. A cookie is
a text file that is placed on your hard disk by a webpage server. Cookies cannot be used to
run programs or deliver viruses to your computer. Cookies are uniquely assigned to you
and can only be read by a web server in the domain that issued the cookie to you. One of the
primary purposes of cookies is to provide a convenience feature to save you time.
A cookie informs the web server that you have returned to a specific page. For example, if
you register with the Platform for the provision of services, a cookie helps to recall your
specific information on subsequent visits. This simplifies the process of recording your
information. When you return to the Platform, the information you previously provided can
be retrieved, so you can easily use the features that you customized. You have the ability to
accept or decline cookies. Most web browsers automatically accept cookies, but you can
usually modify your browser setting to decline cookies if you prefer. If you choose to decline
cookies, you may not be able to fully experience the interactive features of the Platform.

I. Links
Please be aware that the Company is not responsible for the content or privacy practices of
other websites. The Company encourages its users to be aware when they leave the
Platform and to read the privacy statements of any other website that collects personal
information.

J. Under the Age of Eighteen.
The Company never knowingly collects personal information from individuals under the
age of eighteen (18) on the Platform. If it is discovered that the Company has inadvertently
collected personal information from a user under eighteen, the Company shall promptly
delete that information.

K. Email Communications
From time to time, the Company may contact you via email for the purpose of providing
announcements, promotional offers, alerts, confirmations, surveys, and/or other general
communication. To further improve services, the Company may receive a notification when
you open an email from the Company or click on a link therein. If you would like to stop
receiving marketing or promotional communications via email from the Company, you may
opt out of such communications via an email link.

L. External Data Storage Sites.
The Company may store your data on servers provided by third party hosting vendors with
whom the Company has contracted.

M. Changes to the Privacy Policy.
The Company reserves the right to change this Privacy Policy from time to time, and will
notify you promptly about significant changes in the way it elects to treat personal
information by sending a notice to the primary email address specified in your account or

placing notice on the Platform. By continuing to utilize the Platform after such
modifications, you acknowledge and agree to the updated Privacy Policy.

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N. Contact Information.
The Company welcomes questions or comments regarding the Platform and Privacy Policy:

Email: kathy@kathyfranktraining.com

Effective as of March 26, 2025