Privacy Policy

Spirito, LLC DBA Blueprint to Sovereignty ("Blueprint to Sovereignty," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit www.blueprint-to-sovereignty.com and its subdomains (collectively, the "Website"), contact us, purchase or inquire about our services, or participate in our programs, assessments, community, events, or sessions.

This Privacy Policy applies to personal information collected online and through related services, forms, communications, and program activities.

By using the Website or providing personal information to us, you acknowledge the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Website or submit personal information to us.

1. Information We Collect

We collect personal information that you voluntarily provide, information collected automatically when you use the Website, and information received from service providers or other permitted sources.

Information You Provide Directly

Depending on how you interact with us, we may collect:

• Name and contact information, including email address, mailing address, telephone number, and professional contact information.
• Account information, including usernames, passwords, login credentials, preferences, and access records.
• Billing and transaction information, including payment details, purchase history, payment-plan information, and records of services purchased.
• Application, intake, assessment, and eligibility information.
• Information provided in consultations, coaching, educational, program, community, or support communications.
• Professional information, including job title, employer, industry, leadership responsibilities, and career-related information.
• Information voluntarily provided during burnout, trauma-recovery, internal emotional-work, intuitive, or tarot-related sessions.
• Communications, feedback, testimonials, survey responses, and other information you choose to provide.
• Marketing preferences and records of your communication consent.
• Photographs, video, audio, or other recordings where applicable and where appropriate notice or consent has been provided.

Sensitive Personal Information

Depending on what you voluntarily disclose, we may collect sensitive personal information, including:

• Mental or emotional health information.
• Trauma history or experiences.
• Information about emotional states, stress, burnout, or personal circumstances.
• Precise geolocation, where applicable.
• Account login information.
• Financial information used to access an account.
• Racial or ethnic origin, religious or philosophical beliefs, or union membership, if voluntarily provided.
• Information concerning sex life or sexual orientation, if voluntarily provided.
• Government-issued identification information, if needed for a specific administrative or legal purpose.
• Other information classified as sensitive personal information under applicable California law.

You are not required to provide sensitive personal information to use the Website. If you choose to provide it, we collect and use it only for limited purposes described in this Privacy Policy, including program delivery, client safety, administrative support, and appropriate client support.

Blueprint to Sovereignty is not a medical provider, mental-health care provider, psychologist, psychiatrist, therapist, or other licensed healthcare provider. We do not provide medical care, psychotherapy, diagnosis, treatment, or clinical mental-health services. Any health-related or emotional information you provide is voluntary and is provided for program-related purposes only.

Information Collected Automatically

When you visit or use the Website, we may automatically collect:

• Internet Protocol address.
• Browser type and version.
• Device type, operating system, and general device information.
• Pages viewed, links clicked, time spent on pages, and referring URLs.
• Approximate location derived from an IP address.
• Website activity, access dates, and usage information.
• Information about interactions with emails, forms, and digital content.
• Cookie identifiers, advertising identifiers, and similar technical information.

2. Sources of Personal Information

We collect personal information from the following categories of sources:

• Directly from you when you complete a form, book a call, purchase a service, register for a program, submit an application, communicate with us, or otherwise provide information.
• Automatically from your browser, device, and interactions with the Website.
• From payment processors and other service providers that process transactions or support our operations.
• From email, customer relationship management, scheduling, community, learning, analytics, and communication platforms.
• From advertising, marketing, or analytics tools, subject to your cookie settings and applicable law.
• From referrals, authorized representatives, or other individuals who provide your information with permission or as otherwise permitted by law.
• From publicly available sources, where permitted by law.

3. Cookies and Tracking Technologies

We may use cookies, pixels, software development kits, local storage, web beacons, and similar technologies to operate the Website and understand how it is used.

These technologies may include:

• Essential cookies required for Website functionality, security, and account access.
• Analytics tools, including Google Analytics and similar services.
• Advertising pixels, including Meta/Facebook Pixel or similar technologies, where enabled.
• Marketing automation and email interaction tools.
• Preference and functionality cookies.
• Security and fraud-prevention technologies.

We use these technologies for purposes such as:

• Operating and securing the Website.
• Remembering preferences.
• Understanding Website usage.
• Measuring communications and advertising performance.
• Improving content, services, and user experience.
• Supporting administrative and marketing functions.

Where required by applicable law, we will provide a cookie consent mechanism before placing non-essential cookies. You may manage cookie preferences through the Website's cookie settings tool, where available. You may also control cookies through your browser settings, including by blocking or deleting cookies.

Disabling cookies may affect Website functionality. Browser-based opt-out controls may not affect all tracking technologies. If our use of advertising or analytics technologies changes in a way that constitutes the sale or sharing of personal information under California law, we will update this Privacy Policy and provide any legally required opt-out mechanism.

4. How We Use Personal Information

We may use personal information for the following business and commercial purposes:

• Providing, administering, and improving our services and programs.
• Processing payments, purchases, registrations, applications, and refunds.
• Delivering program materials, communications, sessions, and support.
• Managing accounts, memberships, communities, and access credentials.
• Responding to questions, requests, and client-support inquiries.
• Scheduling and administering consultations, calls, sessions, and events.
• Conducting intake, assessments, eligibility reviews, and program administration.
• Supporting client safety and responding appropriately to information voluntarily provided by a client.
• Communicating about services, program updates, appointments, events, and administrative matters.
• Sending marketing communications where permitted and where you have provided appropriate consent.
• Operating, maintaining, securing, and improving the Website.
• Personalizing Website content and user experience.
• Conducting analytics, quality assurance, research, and internal business administration.
• Detecting, preventing, and addressing fraud, abuse, security incidents, and technical problems.
• Complying with legal obligations and enforcing agreements.
• Protecting the rights, property, safety, and security of Blueprint to Sovereignty, our clients, service providers, and others.
• Evaluating or completing a business transaction, such as a merger, financing, reorganization, acquisition, or sale of assets, subject to applicable law.
• Using information for other purposes disclosed at the time of collection or with your consent.

We do not use personal information to make medical or mental-health diagnoses. We do not make therapeutic or medical claims based on information provided to us.

5. Sensitive Personal Information

We may collect sensitive personal information when you voluntarily provide it through an intake form, assessment, program activity, consultation, communication, internal emotional-work session, trauma-recovery discussion, intuitive session, or tarot reading.

We collect and use sensitive personal information only as reasonably necessary and proportionate for the following limited purposes:

• Delivering or administering the program or service you requested.
• Understanding your stated goals, preferences, circumstances, and support needs.
• Supporting appropriate client communication and program administration.
• Responding to client safety concerns.
• Maintaining records necessary for legal, administrative, or business purposes.
• Complying with legal obligations.

We do not use sensitive personal information to infer characteristics about you. We do not sell sensitive personal information. We do not share sensitive personal information for cross-context behavioral advertising. We do not permit service providers to use sensitive personal information for their own marketing or advertising.

Sensitive personal information is disclosed only to service providers that need the information to perform services on our behalf, under contractual restrictions, or when disclosure is required or permitted by law.

You may request to limit the use and disclosure of your sensitive personal information as described in the California Privacy Rights section below. Because some sensitive information may be necessary to provide a service you specifically request, limiting its use may affect our ability to provide that service.

6. Sharing and Disclosure of Personal Information

We may disclose personal information to the following categories of recipients for business purposes:

• Payment processors and billing providers.
• Email and communications providers.
• SMS and text-messaging providers.
• Customer relationship management systems.
• Scheduling and calendar providers.
• Community, learning-management, and program-delivery platforms.
• Hosting, website, information-technology, and security providers.
• Analytics providers.
• Marketing automation providers.
• Advertising technology providers, where applicable and consistent with this Privacy Policy.
• Professional advisers, including legal, accounting, insurance, and compliance advisers.
• Government authorities, law-enforcement agencies, courts, or other parties when legally required or permitted.
• Parties involved in a business transaction, subject to appropriate confidentiality and legal protections.

These providers may access personal information only as reasonably necessary to perform services for us. We require service providers to maintain confidentiality, implement reasonable security measures, and use personal information only for authorized business purposes. We do not permit service providers to use personal information for their own marketing, advertising, or promotional purposes.

No Sale or Sharing for Marketing

We do not sell, rent, trade, or share personal information with third parties or affiliates for their own marketing or promotional purposes.

We do not sell or share personal information for cross-context behavioral advertising. We have not sold personal information or shared personal information for cross-context behavioral advertising in the preceding 12 months.

We do not share sensitive personal information for cross-context behavioral advertising.

We do not sell, rent, trade, or share client information in exchange for money or other valuable consideration.

We may disclose information to service providers acting on our behalf, as described above. These disclosures are not made for the service provider's own marketing or advertising purposes.

Because we do not currently sell or share personal information for cross-context behavioral advertising, we do not currently provide a "Do Not Sell or Share My Personal Information" link. If our practices change, we will update this Privacy Policy and provide any opt-out link, notice, or mechanism required by law.

7. California Privacy Rights

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to our processing of their personal information.

Categories of Personal Information Collected

During the preceding 12 months, we may have collected the following categories of personal information:

We do not knowingly collect biometric information, genetic information, or contents of mail, email, or text messages directed to another person unless you voluntarily provide that information to us or collection is otherwise permitted by law.

Sources and Purposes

The sources and purposes associated with these categories are described in the "Sources of Personal Information" and "How We Use Personal Information" sections of this Privacy Policy.

Categories Disclosed for Business Purposes

During the preceding 12 months, we may have disclosed the categories of personal information listed above to categories of service providers such as payment processors, communications providers, scheduling providers, customer relationship management systems, program-delivery platforms, hosting providers, security providers, analytics providers, marketing automation providers, professional advisers, and government or legal authorities where required.

These disclosures were made for business purposes such as providing services, processing transactions, administering programs, maintaining the Website, communicating with clients, security, analytics, compliance, and legal obligations.

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

California Consumer Rights

Subject to applicable exceptions and verification requirements, California residents may have the right to:

• Know and access personal information. Request the categories and specific pieces of personal information we collect, the categories of sources, the purposes for collection, and the categories of recipients to whom personal information is disclosed.
• Correct inaccurate personal information. Request correction of inaccurate personal information maintained by us.
• Delete personal information. Request deletion of personal information, subject to legal and operational exceptions.
• Limit use and disclosure of sensitive personal information. Request that we limit the use and disclosure of sensitive personal information to purposes authorized by California law.
• Opt out of sale or sharing. Direct a business not to sell or share personal information. We do not currently sell or share personal information for cross-context behavioral advertising.
• Non-discrimination. Exercise privacy rights without receiving discriminatory treatment prohibited by California law.
• Designate an authorized agent. Authorize another person or business to submit a request on your behalf, subject to applicable verification requirements.

California residents may also have rights concerning automated decision-making technology or other data practices if applicable law requires those rights and those practices apply to our business.

How to Submit a California Privacy Request

To submit a request to know, access, correct, delete, limit, or opt out, submit your request by email to info@blueprint-to-sovereignty.com or in writing to Spirito, LLC DBA Blueprint to Sovereignty, 28602 Canyon Rd, Valley Center, CA 92082.

You do not need to create an account to submit a privacy request. We will not require you to provide personal information that is unnecessary to process your request.

Verification

For requests to know, access, correct, or delete personal information, we may need to verify your identity before completing the request. Verification measures will be reasonably related to the type and sensitivity of the information requested and the risk of unauthorized disclosure, correction, or deletion.

We may verify your identity by matching information you provide with information reasonably maintained by us. We may request additional information only when reasonably necessary for verification, security, or fraud prevention.

We will not require highly sensitive information, such as a government-issued identification document, unless reasonably necessary and permitted by law. Any information collected solely for verification will be used for that purpose and deleted when no longer needed, unless retention is required by law.

Requests to opt out of sale or sharing, or to limit the use and disclosure of sensitive personal information, generally will not require identity verification beyond what is reasonably necessary to process the request.

If you submit a request through an authorized agent, we may require:

• Proof that you gave the agent signed permission to act on your behalf.
• Verification of your identity directly with us.
• Additional information reasonably necessary to confirm the agent's authority.

We may deny a request when permitted by law, including when we cannot reasonably verify the requester's identity, when an exception applies, or when completing the request would adversely affect the rights of another person.

Response Timing and Fees

We will generally acknowledge receipt of a privacy request within 10 business days when required or appropriate and will respond to a verifiable request within 45 calendar days.

If additional time is reasonably necessary, we may extend the response period by up to an additional 45 calendar days. We will notify you of the extension and the reason for it within the initial response period.

We do not charge a fee to process a privacy request unless permitted by applicable law. If a fee is permitted, we will explain the reason before proceeding.

8. SMS and Text Messaging

If you separately opt in to receive text messages from Spirito, LLC DBA Blueprint to Sovereignty, you consent to receive recurring automated and non-automated text messages relating to services, appointments, program updates, reminders, customer support, announcements, and marketing communications.

Your consent to receive SMS messages is not a condition of purchasing goods or services.

Message frequency varies. Message and data rates may apply.

You may opt out at any time by replying STOP to any message. After you reply STOP, you may receive one confirmation message, and you will no longer receive SMS messages unless you opt in again.

For assistance, reply HELP or contact us at info@blueprint-to-sovereignty.com.

Mobile carriers are not liable for delayed or undelivered messages.

All SMS opt-in data and consent records are excluded from the other information-sharing categories in this Privacy Policy. We do not sell, rent, trade, or disclose SMS opt-in data or consent records to any third party or affiliate for marketing, promotional, or unrelated purposes.

A contracted SMS delivery provider may receive limited information solely as necessary to deliver messages on our behalf, maintain opt-out records, prevent abuse, and comply with applicable law. That provider may not use the information for its own marketing, advertising, or promotional purposes.

9. Photo, Video, and Audio Recordings

Photography, video recording, audio recording, or other recording may occur during certain programs, events, trainings, community activities, or services.

Recordings may be used for program administration, documentation, educational materials, internal review, Website content, marketing, social media, or other business communications, where permitted by law and subject to any applicable consent or release.

If you do not want to be photographed, recorded, or included in media, notify us in writing at info@blueprint-to-sovereignty.com before the applicable event or activity. We will make reasonable efforts to honor a timely opt-out request, but we cannot guarantee removal from recordings that include multiple participants or have already been published or distributed.

Separate written permission may be requested for identifiable use of your name, image, voice, or likeness in promotional materials.

10. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, disclosure, or destruction.

These safeguards may include:

• Secure website connections using SSL/TLS encryption.
• Access controls and authentication procedures.
• Contractual confidentiality obligations for service providers.
• Reasonable data-minimization and retention practices.
• Monitoring and safeguards designed to detect unauthorized activity.

No method of transmitting or storing information is completely secure. We cannot guarantee that personal information will never be accessed, disclosed, altered, or destroyed through a security incident.

11. Data Retention

We retain personal information only for as long as reasonably necessary to:

• Provide requested services and administer programs.
• Maintain business and transaction records.
• Respond to requests and communications.
• Comply with legal, tax, accounting, insurance, and regulatory obligations.
• Resolve disputes and enforce agreements.
• Detect and prevent fraud, abuse, or security incidents.
• Protect our legal rights and the rights of others.

Retention periods vary depending on the nature of the information, the purpose for which it was collected, legal requirements, and operational needs. When personal information is no longer required, we will delete, de-identify, or securely dispose of it where reasonably practicable.

12. Third-Party Websites and Services

The Website may contain links to third-party websites, platforms, applications, or services. Those third parties may collect, use, and disclose information under their own privacy policies.

We are not responsible for the privacy, security, content, or practices of third-party websites or services. We encourage you to review their privacy policies before providing information or using their services.

13. Children's Privacy

Our services and programs are intended for adults aged 18 and older.

We do not knowingly collect personal information from children under 13. We do not knowingly offer our services to individuals under 18 without appropriate authorization. If we learn that we have collected personal information from a child in a manner prohibited by law, we will take reasonable steps to delete it.

If you believe a minor has provided personal information to us, contact us at info@blueprint-to-sovereignty.com.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal obligations, or privacy practices.

When we make changes, we will post the revised Privacy Policy on the Website and update the "Last updated" date. Where required by law, we will provide additional notice or obtain consent.

Your continued use of the Website after the updated Privacy Policy becomes effective means that you acknowledge the revised policy.

15. Contact Us

For questions, concerns, or requests relating to this Privacy Policy or our privacy practices, contact us at: Spirito, LLC DBA Blueprint to Sovereignty Privacy contact email: info@blueprint-to-sovereignty.com Mailing address: Spirito, LLC DBA Blueprint to Sovereignty, 28602 Canyon Rd, Valley Center, CA 92082