Privacy Policy

Effective date: 06/03/2026

By using the Services, you agree to this Privacy Policy. If you do not agree, please discontinue use.

Scope. This Policy applies to all visitors and users of our sites and apps (e.g.,GIARA Capital LLC, app subdomains, and GIARA Capital LLC), purchasers of playbooks/merch, attendees of webinars/retreats, coaching and DFY clients, and SaaS account holders (including authorized users within client accounts).

1) Who We Are & Roles

Controller.GIARA Capital LLC. is the “controller” of personal information you provide for your account, billing, marketing, and site/app usage.

Processor. For customer/contact data you upload to the GIARA Capital LLC (e.g., contact lists, messages, pipelines), we act as your processor on a white-label platform. We process such data only per your instructions and applicable agreements (e.g., MSA/SOW, Data Processing Addendum).

2) What We Collect

We collect information you provide, information we obtain automatically, and information from integrations/partners.

A. Information you provide

Account & Identity: name, email, phone, company, role, login credentials.

Billing & Payments: billing address and payment details (processed by our payment providers; we do not store full card numbers).

Content & CRM Data (Processor role): leads/contacts, messages, calls/text logs, appointments, tasks, files, campaign settings, and other data you upload or generate in the platform.

Communications: support requests, surveys, testimonials, call/chat/email interactions.

Preferences: marketing and cookie preferences.

B. Information collected automatically

Usage/Device/Analytics: IP address, device IDs, browser/OS, pages/views, feature use, session times, crash and performance logs, coarse location (derived from IP).

Cookies/Tracking: cookies, web beacons, pixels, and similar technologies for authentication, security, performance, analytics, and (where applicable) advertising measurement (see Section 7).

C. From third parties & integrations

Platform & Sub-processors: data necessary to provide hosting, analytics, email/SMS/voice delivery, support, and payments.

Optional Integrations you enable: email providers, calendars, CRMs, social platforms, telephony/SMS, and payment gateways. We receive data from and share data with these services per your settings and their policies.

Sensitive data. We do not seek to collect sensitive personal information (e.g., precise geolocation, health, or government IDs) except where needed for compliance (e.g., A2P 10DLC business registration or fraud prevention) and only with appropriate safeguards.

3) How We Use Personal Information (Purposes)

Provide the Services: create/manage accounts, authenticate users, deliver CRM/automation/funnel/SMS/email/voice features, and fulfill digital products, webinars, coaching/DFY services, and events.

Process payments & billing: subscriptions, invoices, refunds (where applicable), charge prevention.

Support & communications: respond to requests, send service/transactional notices (e.g., receipts, system alerts), and product updates.

Improve & secure: monitor performance, debug, prevent fraud/abuse/spam, maintain integrity of messaging (TCPA/A2P), and develop new features.

Legal & compliance: enforce terms, comply with law, and maintain records.

Marketing (optional): send newsletters, offers, and event updates where permitted; you can opt out at any time.

We may de-identify or aggregate data for statistics, benchmarking, and product improvement; such data is not used to identify you.

4) Legal Bases (GDPR/UK GDPR)

Where applicable, we rely on: contract (to provide the Services), legitimate interests (e.g., security, product improvement), consent (for marketing/certain cookies), and legal obligations.

5) Sharing & Disclosures

We do not sell personal information. We share only as described:

Service providers / sub-processors: hosting, data storage, email/SMS/voice, analytics, customer support, and payment processing (e.g., Stripe; ACH providers). They are bound by confidentiality and data-protection terms and may use data only to perform services for us.

Integrations you authorize: when you connect third-party tools (e.g., email, calendars, payment gateways), we share data as necessary to operate that connection.

Legal / safety: to comply with laws, lawful requests, or to protect rights, safety, and security.

Business transfers: in mergers, acquisitions, or asset sales; we will notify you of material changes.

With consent: for any other sharing you explicitly authorize.

6) SMS/MMS Opt-In and Messaging Disclosure

How you opt in. By providing your mobile phone number through any of our forms, checkout pages, booking pages, or by texting a keyword to our short code or phone number, you expressly consent to receive SMS/MMS messages fromGIARA Capital LLC. Consent may also be collected verbally (e.g., during a sales or support call) or through a third-party integration you authorise. Opting in to SMS is not a condition of purchasing any goods or services.

Types of messages. You may receive: appointment reminders and confirmations, order and billing notifications, account alerts and verification codes, promotional offers, event updates, and marketing messages (if you have opted in to marketing communications).

Message frequency. Message frequency varies based on your account activity and preferences. You may receive recurring messages.

No mobile information sharing. We do not sell, rent, loan, trade, lease, or otherwise share your mobile phone number or any information collected through our SMS programme with any third party for promotional or marketing purposes. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. All other data disclosures are subject to this Privacy Policy.

Opt-out. You may opt out of SMS messages at any time by replying STOP to any message you receive from us. After opting out, you will receive a single confirmation message and will no longer receive SMS messages from us unless you re-subscribe.

Help. For assistance, reply HELP to any message or email [email protected].

Message and data rates. Standard message and data rates may apply, depending on your mobile carrier and plan.

Carrier liability. Carriers (e.g., T-Mobile) are not liable for delayed or undelivered messages.

7) Retention

We keep personal information only as long as needed for the purposes above:

Account & billing records: typically for the life of the account plus the period required by law/tax/audit (often 3 to 7 years).

Platform (processor) data: retained while your account is active and deleted or returned at your instruction or upon termination, subject to backup/archival cycles.

Marketing records: until you opt out or your consent is withdrawn, or as required by law.

We may retain and use limited information to comply with obligations, resolve disputes, and enforce agreements.

8) Cookies & Tracking Choices

We use:

Essential cookies for login, security, and core functions.

Functional/performance cookies to improve features and measure usage.

(Optional) advertising/measurement cookies in our marketing sites/funnels.

Your controls: Most browsers let you block/clear cookies. Some features may not function without essential cookies. Where required, we present a cookie banner/controls to manage non-essential cookies.

Do Not Track: There’s no industry standard response; we do not alter behavior solely in response to DNT signals. You can manage tracking via browser or our cookie controls.

9) Your Rights & Choices

Your rights depend on your location. Subject to verification and legal limits, you may request to:

Access and correct your information.

Delete your information.

Restrict or object to certain processing.

Receive a portable copy of certain data.

Opt out of marketing emails at any time (unsubscribe links included).

SMS: You can opt out by replying STOP; for help, reply HELP. Message and data rates may apply.

U.S. state privacy laws (including Texas TDPSA & California CCPA/CPRA)

Residents of certain U.S. states may also:

Request details about categories of data collected, sources, purposes, and disclosures.

Request deletion/correction and to access specific pieces of personal information.

Opt out of “sale” or “sharing” of personal information or targeted advertising.

We do not sell personal information or share it for cross-context behavioral advertising.

Use an authorized agent to submit requests.

We will not discriminate against you for exercising your rights.

How to submit a request: email [email protected] with “Privacy Request,” your state/country, and details of the request. We will verify identity and respond within the timeframes required by law (e.g., 45 days under CCPA; extendable where permitted).

EEA/UK residents

You may lodge a complaint with your local supervisory authority. We welcome the chance to address concerns first.

10) International Transfers

We operate in the U.S., and our providers may process data in the U.S. or other countries. Where required for EEA/UK transfers, we use Standard Contractual Clauses or other approved safeguards.

11) Security

We implement administrative, technical, and physical safeguards appropriate to the nature of the data, including encryption in transit (TLS), role-based access controls, audit logging, and vendor diligence. No system is perfectly secure; if we learn of a breach affecting your personal information, we will notify you in accordance with applicable law.

HIPAA/PHI. Our Services are not intended to store or process Protected Health Information unless we have a signed BAA. Please do not upload PHI.

12) Children’s Privacy

Our Services are not directed to children under 13 (U.S. COPPA). We also do not knowingly target individuals under 16 in jurisdictions where consent is required. If you believe a minor provided personal information, contact us and we will delete it where required.

13) Data Processing Addendum (DPA)

For SaaS customers who process personal data of others in the platform, our DPA supplements this Policy and governs processor obligations (including sub-processors, SCCs, and deletion/return). Request a copy at [email protected].

14) Changes to this Policy

We may update this Policy from time to time. We will post the updated version with a new effective date and, where required, provide additional notice. Your continued use of the Services after the effective date constitutes acceptance.

15) Contact Us

GIARA Capital LLC
Address: 10 West 37th Street, 10th Floor, New York, NY 10018, United States
Email: [email protected]

Phone: +1 917-232-3698

Short “Notice at Collection” (CCPA/CPRA summary)

We collect the following categories of personal information for the purposes in Section 3 and retain them as described in Section 7: identifiers (e.g., name, email, IP), customer records (billing), commercial information (purchases), internet/network activity (usage), geolocation (coarse/IP-based), professional/employment info (if provided), and inferences (product interests). We do not sell or share personal information as defined by CPRA, and we do not use sensitive personal information to infer characteristics. Sources include you, your devices, our service providers, and integrations you connect. Disclosures are to service providers and as otherwise described in Section 5.