Privacy Policy

Effective date: July 31, 2026
Last updated: July 31, 2026

This Privacy Policy explains how Debora T DiBiasie, doing business through the AVBrands, as applicable, collects, uses, retains, protects, and discloses personal information through AltaVidaSites.

For purposes of this Privacy Policy:

“We,” “us,” and “our” refer to Debora T DiBiasie, doing business through the AVBrands, as applicable, and, where appropriate, authorized service providers acting on our behalf.

“AVBrands” collectively means AltaVida Capital, AltaVida Unlimited, and AltaVida Offices.

“AltaVidaSites” collectively means:

  • altavidacapital.com;
  • altavidaunlimited.com;
  • altavidaoffices.com; and
  • their respective subdomains, applications, portals, calculators, assessments, forms, reports, downloads, email resources, and other digital services operated by us.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household. The precise meaning may vary under applicable law.

This Privacy Policy applies to personal information collected through AltaVidaSites and related communications unless a separate product, service, transaction, program, or written agreement provides a different privacy notice.

By using AltaVidaSites or submitting personal information, you acknowledge the practices described in this Privacy Policy.

  1. Scope of this Privacy Policy

This Privacy Policy applies to information collected through:

  • visits to AltaVidaSites;
  • contact and access forms;
  • email subscriptions;
  • assessments and questionnaires;
  • retirement and financial calculators;
  • generated reports and PDFs;
  • appointment requests;
  • account registration and authentication;
  • customer-support communications;
  • product or service inquiries;
  • downloadable educational materials;
  • applications and portals;
  • surveys, feedback, and correction requests;
  • business and professional communications; and
  • other interactions with an AVBrands.

This Privacy Policy does not govern the independent privacy practices of government agencies, financial institutions, insurers, employers, professional firms, social-media platforms, or other third parties whose websites, applications, or services may be linked to or accessible through AltaVidaSites.

  1. Information you provide directly

Depending on how you use AltaVidaSites, we may collect the following categories of information.

  1. Identifiers and contact information

This may include:

  • first and last name;
  • email address;
  • telephone number;
  • mailing address;
  • state or country;
  • account username;
  • user or submission identifier; and
  • other contact information you choose to provide.
  1. Account and authentication information

When an account or protected application is offered, we may collect:

  • login email;
  • password-related authentication data;
  • verification status;
  • access permissions;
  • account activity;
  • account preferences;
  • authentication timestamps; and
  • security-related records.

Passwords are intended to be processed through secure authentication systems and should not be retained by us in readable form.

  1. Assessment and planning information

Our assessments and calculators may collect information concerning:

  • age or age range;
  • anticipated retirement date;
  • employment or service status;
  • military or federal employment category;
  • retirement system;
  • years of service;
  • household composition;
  • marital or family status;
  • survivor-planning considerations;
  • benefits awareness;
  • retirement-income estimates;
  • TSP or retirement-account information;
  • savings and investment ranges;
  • insurance coverage;
  • debt or household-obligation ranges;
  • housing considerations;
  • healthcare-planning considerations;
  • business-planning information;
  • financial goals;
  • selected answers;
  • educational planning indicators; and
  • other information entered into a Tool.

“Tool” means an assessment, calculator, questionnaire, report generator, or similar interactive resource offered through AltaVidaSites.

Tools are designed for educational planning. Unless specifically requested through an approved secure process, users should provide estimated amounts or ranges rather than complete financial statements or unnecessary sensitive records.

  1. Insurance-related information

When a user requests insurance information or contact from a licensed professional, we may collect information such as:

  • state of residence;
  • age or age range;
  • general coverage interests;
  • existing coverage information;
  • estimated coverage needs;
  • preferred contact method;
  • household or business-planning objectives; and
  • information reasonably necessary to route the inquiry.

A formal insurance application may require additional information under separate carrier forms, disclosures, agreements, and privacy notices.

  1. Business and professional information

For business tools, office services, invoices, referrals, or professional inquiries, we may collect:

  • business name;
  • business contact information;
  • industry or trade;
  • company role;
  • project or job information;
  • client or customer information submitted by an authorized user;
  • invoice, proposal, or estimate details;
  • service interests;
  • account preferences;
  • office or mailing-service inquiries; and
  • related communications.

Users must have lawful authority to submit information concerning another individual or business.

  1. Communications and submitted content

We may collect information contained in:

  • emails;
  • contact forms;
  • customer-support requests;
  • chat or messaging interactions;
  • appointment requests;
  • correction reports;
  • comments;
  • feedback;
  • testimonials;
  • documents;
  • photographs;
  • audio;
  • files; and
  • other material voluntarily submitted.
  1. Transaction information

If paid products or services are offered, we may collect:

  • purchaser name;
  • billing address;
  • transaction date;
  • product or service purchased;
  • payment status;
  • transaction identifier;
  • refund or dispute information; and
  • limited payment-related information provided by the payment processor.

Complete payment-card information is intended to be processed by independent payment processors rather than stored directly by us.

  1. Information collected automatically

When you access or use AltaVidaSites, certain information may be collected automatically through technologies active on the applicable site, such as server logs, cookies, analytics tools, authentication systems, and similar technologies.

This information may include:

  • Internet Protocol address;
  • browser type;
  • device type;
  • operating system;
  • approximate geographic region derived from an IP address;
  • referring page;
  • pages viewed;
  • links clicked;
  • date and time of access;
  • session duration;
  • language and display preferences;
  • form or application events;
  • error logs;
  • authentication events;
  • security events;
  • cookie identifiers; and
  • interactions with emails, where permitted.

Additional information about these technologies, their purposes, and available user choices is provided in our Cookie Policy.

  1. Information received from other sources

We may receive personal information from:

  • service providers operating on our behalf;
  • email and communication platforms;
  • hosting and database providers;
  • authentication providers;
  • payment processors;
  • analytics providers;
  • appointment or scheduling services;
  • social-media platforms when a user interacts with our public accounts;
  • professional referral sources;
  • insurance professionals or carriers, when legally authorized;
  • business partners;
  • public records;
  • government or official sources;
  • users who lawfully provide information concerning another person; and
  • other sources permitted by law.

When another person provides information about you, that person represents that they have lawful authority to do so.

  1. Information that must not be submitted

AltaVidaSites does not request or require users to submit the following information through site forms, assessments, calculators, email, social-media messaging, chat, or other ordinary communication channels:

  • Social Security numbers;
  • DoD identification numbers;
  • government account credentials;
  • financial-account usernames or passwords;
  • complete bank-account numbers;
  • complete payment-card numbers;
  • authentication or security codes;
  • private encryption keys;
  • classified, controlled, or otherwise restricted government information;
  • complete tax returns;
  • unredacted medical records;
  • genetic or biometric identifiers;
  • complete military personnel files;
  • complete credit reports;
  • copies of passports or government-issued identification; or
  • other highly sensitive information not reasonably necessary to use AltaVidaSites.

Users should not submit information concerning another individual unless they have lawful authority to provide it and the information is reasonably necessary for the requested interaction.

If unsolicited sensitive information is submitted, we may delete it, restrict access to it, securely dispose of it, or retain it only when legally or operationally necessary.

Any information required for a formal insurance application must be submitted through the separate, authorized process identified by the applicable licensed insurance professional, insurance agency, or carrier. That information is subject to the privacy notices, forms, security procedures, and legal requirements applicable to that insurance process.

  1. How we use personal information

We may use personal information to:

  • provide, operate, maintain, and improve AltaVidaSites;
  • provide requested educational resources;
  • process assessment and calculator inputs;
  • generate results, scores, reports, or PDFs;
  • deliver requested reports by email;
  • create and administer accounts;
  • authenticate users;
  • respond to questions and requests;
  • schedule appointments;
  • provide customer support;
  • route inquiries to the appropriate internal or external resource;
  • maintain submission and consent records;
  • improve Content and Tools;
  • test functionality;
  • identify and correct errors;
  • maintain backups and support service continuity;
  • analyze site performance and usage;
  • protect the security and integrity of AltaVidaSites;
  • detect and prevent fraud, misuse, abuse, and unauthorized access;
  • enforce our Terms of Use and other agreements;
  • maintain legal, compliance, and business records;
  • comply with applicable legal obligations;
  • respond to lawful requests and legal process;
  • investigate complaints, disputes, or suspected violations;
  • send transactional communications;
  • send marketing communications when permitted;
  • process purchases, payments, and refunds where paid products or services are offered;
  • administer referrals or professional introductions when requested;
  • protect our rights and the rights, safety, and property of others; and
  • carry out other purposes disclosed at the time the information is collected.

We will not use personal information for a materially different purpose without providing additional notice or obtaining consent when required by applicable law.

  1. Assessments, scores, calculations, and automated processing

AltaVidaSites may use automated rules, formulas, calculations, answer mappings, scoring systems, or AI-assisted processes to:

  • calculate educational estimates;
  • organize answers;
  • identify planning subjects;
  • generate educational planning indicators;
  • produce reports;
  • recommend educational resources;
  • route a user to a relevant section or resource; and
  • flag information for further review.

These processes are intended to provide educational organization and general planning information.

They are not intended to:

  • determine eligibility for government benefits;
  • adjudicate a claim;
  • make an employment decision;
  • make a credit or lending decision;
  • make an insurance-underwriting decision;
  • make a healthcare decision;
  • make a legal determination;
  • make a securities or investment decision;
  • deny access to a legal right; or
  • replace human review or advice from a qualified professional.

A score, label, estimate, recommendation, or priority generated by a Tool is not an official or legally binding determination.

Where applicable law grants rights concerning automated decision-making or profiling, we will provide required notices, reviews, and controls.

  1. Artificial intelligence and technology-assisted services

We may use artificial intelligence and other technology-assisted services to help:

  • draft, organize, translate, or format educational content;
  • assist with search and research;
  • identify errors or inconsistencies;
  • support customer-service functions;
  • summarize or organize user-submitted information;
  • generate educational reports or resources; and
  • improve administrative and operational workflows.

When an AI-assisted service processes personal information submitted by a user, we will limit the information used to what is reasonably necessary for the stated purpose and provide additional notice when required by applicable law.

We do not intentionally submit highly sensitive personal information to a general-purpose AI service unless:

  • the processing is reasonably necessary for an authorized purpose;
  • the service has been approved for that purpose;
  • appropriate privacy, contractual, and security controls are in place; and
  • the processing is permitted by applicable law.

Users should not enter confidential or highly sensitive information into an open-text field unless the field specifically requests that information and explains how it will be handled.

AI-assisted outputs may contain errors or omissions and should not be treated as official, professional, or legally binding determinations.

  1. Email and electronic communications

We may send transactional and marketing communications as described below.

  1. Transactional communications

Transactional communications may include:

  • access links;
  • requested reports;
  • account-verification messages;
  • password-reset messages;
  • appointment information;
  • responses to questions or support requests;
  • security alerts;
  • purchase or transaction confirmations;
  • policy notices; and
  • other service-related communications.

Transactional communications may continue after a user unsubscribes from marketing when reasonably necessary to provide a requested service, administer an account, complete a transaction, protect security, or comply with applicable law.

  1. Marketing communications

With consent or as otherwise permitted by applicable law, we may send:

  • educational articles;
  • newsletters;
  • announcements concerning new resources;
  • invitations;
  • product or service information;
  • event notices; and
  • related updates.

Recipients may unsubscribe from marketing communications by using the unsubscribe link provided in the message or by contacting us.

An unsubscribe request may not remove information that must be retained for suppression-list, legal, security, transaction, recordkeeping, or compliance purposes.

  1. Cookies and similar technologies

AltaVidaSites may use:

  • essential cookies;
  • authentication cookies;
  • security cookies;
  • preference cookies;
  • performance cookies;
  • analytics cookies; and
  • other similar technologies active on the applicable site.

Essential technologies may be necessary to operate AltaVidaSites, authenticate users, maintain security, remember requested settings, or provide requested functions. These technologies may not be disabled through ordinary consent controls when they are strictly necessary for the requested service.

Nonessential technologies will be used and managed in accordance with applicable notice, consent, and opt-out requirements.

Our Cookie Policy provides additional information concerning:

  • the categories of technologies used;
  • their purposes;
  • relevant providers;
  • typical duration;
  • available choices; and
  • how users may change their preferences.

The technologies used may vary among AltaVidaSites. Users should review the Cookie Policy and consent controls displayed on the applicable site.

  1. How we disclose personal information

We may disclose personal information in the circumstances described below.

  1. Service providers and contractors

We may disclose personal information to service providers and contractors that perform functions such as:

  • website and application hosting;
  • content management;
  • cloud storage;
  • database services;
  • authentication;
  • email delivery;
  • marketing communications;
  • form processing;
  • document and PDF generation;
  • analytics;
  • security and fraud prevention;
  • backups and service recovery;
  • appointment scheduling;
  • payment processing;
  • customer support;
  • software development; and
  • legal, accounting, compliance, or other professional services.

Service providers and contractors may process personal information only for authorized purposes and subject to applicable contractual, confidentiality, security, and legal restrictions.

  1. Business partners, professional referrals, and requested introductions

AltaVidaSites may allow users to request information, services, demonstrations, consultations, referrals, or introductions involving selected independent business partners and professionals.

Depending on the user’s request, these recipients may include:

  • business technology and automation providers;
  • marketing and customer-management providers;
  • licensed insurance professionals and insurance agencies;
  • financial education or planning-program providers;
  • attorneys;
  • tax professionals;
  • accountants;
  • benefits specialists;
  • office-service providers; and
  • other independent professionals or businesses relevant to the request.

When a user requests or affirmatively authorizes an introduction, we may disclose information reasonably necessary to respond to the request, such as:

  • name;
  • business name;
  • email address;
  • telephone number;
  • state of residence or operation;
  • service or product interest;
  • preferred contact method;
  • appointment information;
  • general planning objectives; and
  • other information the user authorizes us to provide.

The receiving business or professional may use the information to contact the user, provide requested information, evaluate service needs, schedule a consultation, administer the requested service, or perform other purposes disclosed when the information is collected.

We retain the primary client relationship and control of its contact database. Providing limited information to an authorized professional, closer, case designer, agency, carrier, or service partner does not transfer ownership or control of the client relationship or authorize the recipient to add the individual to an unrelated marketing list.

Except where independently required by law or necessary to administer the requested transaction, recipients may use the information only for the specific purpose authorized by the user.

Independent recipients may maintain their own privacy policies, security practices, professional responsibilities, eligibility requirements, and terms of service. Users should review any separate privacy notice provided by the receiving professional or organization.

We may receive referral fees, commissions, revenue-sharing payments, marketing compensation, or other business benefits when a user purchases or obtains a product or service through one of these relationships. Any effect on the user’s price will be disclosed when legally required.

We will not disclose a user’s information to an independent business or professional for direct marketing unrelated to the user’s request without the user’s authorization or another lawful basis.

  1. Affiliate links and third-party merchants

AltaVidaSites may contain affiliate links, product recommendations, promotional links, or other links to independent merchants and service providers.

When a user selects an affiliate link:

  • the user may be redirected to an independent third-party website or application;
  • the third party may collect device, browser, referral, cookie, account, transaction, and purchase information under its own privacy policy;
  • the link may contain an affiliate or referral identifier that allows the third party to attribute the visit or transaction to us; and
  • we may receive a commission, referral fee, or other compensation if the user completes a qualifying purchase or transaction.

We do not control the independent merchant’s collection, use, retention, disclosure, or security of personal information.

Unless expressly disclosed, we do not receive or store a user’s complete payment-card information, account password, or complete transaction record from an affiliate merchant. We may receive limited information concerning referral activity, conversion status, commission eligibility, or the category of a qualifying purchase.

The presence of an affiliate link does not mean that the merchant sponsors, controls, or endorses the AVBrands. Product and service availability, pricing, warranties, returns, delivery, customer service, and transactions are governed by the independent merchant’s terms.

  1. Legal, security, and safety purposes

We may disclose personal information when reasonably necessary to:

  • comply with applicable law;
  • respond to a subpoena, court order, warrant, or lawful government request;
  • protect legal rights, property, or safety;
  • investigate suspected fraud, misuse, or unauthorized activity;
  • prevent, investigate, or respond to security incidents;
  • enforce agreements;
  • establish, exercise, or defend legal claims; or
  • cooperate with lawful investigations.
  1. Business transactions

Personal information may be disclosed in connection with a proposed or completed:

  • merger;
  • acquisition;
  • financing;
  • reorganization;
  • asset transfer;
  • sale of a business or business division;
  • bankruptcy;
  • due-diligence review; or
  • transfer to a successor or affiliate.

Recipients will be expected to handle personal information in accordance with applicable law and relevant contractual obligations.

  1. With the user’s consent or direction

We may disclose personal information when a user directs us to do so, requests the disclosure, or provides legally valid consent.

  1. No sale or distribution of contact lists

We do not sell, rent, license, publish, or distribute contact lists or databases containing users’ names, email addresses, telephone numbers, assessment responses, or other personal information.

We do not permit business partners, referral recipients, affiliate merchants, or other third parties to browse, access, or obtain our complete contact database.

We do not disclose personal information to unrelated third parties for their independent, unsolicited marketing.

When a user expressly requests a product, service, consultation, demonstration, referral, or professional introduction, we may provide the minimum information reasonably necessary to the specific business or professional identified to the user at the time of the request.

Before making such a disclosure, we will provide notice describing:

  • the identity or category of the intended recipient;
  • the information that will be disclosed;
  • the purpose of the disclosure;
  • how the recipient may contact the user;
  • whether the recipient operates independently; and
  • whether we may receive compensation arising from the referral or resulting transaction.

We may receive a referral fee, commission, revenue-sharing payment, or other compensation if the user completes a purchase or transaction. We will not disclose the user’s information to additional recipients merely because the initial referral did not result in a transaction.

Recipients may be required by contract to:

  • use the information only for the authorized request;
  • maintain reasonable confidentiality and security;
  • refrain from selling, renting, or redistributing the information;
  • refrain from using the information for unrelated marketing;
  • honor applicable communication preferences and opt-out requests;
  • restrict access to authorized personnel; and
  • delete or return information when it is no longer reasonably necessary, subject to applicable legal and recordkeeping obligations.

Depending on the circumstances and applicable law, a compensated disclosure may be legally characterized as a “sale” even when no contact list is sold and the disclosure occurs at the user’s request. If a disclosure is legally treated as a sale or sharing of personal information, we will provide any notice, consent, opt-out mechanism, and other rights required by applicable law.

Affiliate links ordinarily do not involve us providing the merchant with our contact database. When a user voluntarily selects an affiliate link, the user interacts directly with the independent merchant, and the merchant collects information under its own privacy policy. We may receive limited referral, conversion, or commission information, but we do not provide the merchant with our complete contact database.

  1. Service providers and technology platforms

We use third-party service providers and technology platforms to support AltaVidaSites and related services.

These providers may perform functions such as:

  • website hosting and content management;
  • application hosting and development;
  • cloud infrastructure;
  • database storage;
  • authentication;
  • email delivery;
  • marketing communications;
  • form and submission processing;
  • document and PDF generation;
  • analytics;
  • appointment scheduling;
  • payment processing where offered;
  • customer support;
  • security monitoring;
  • backups and recovery;
  • error detection;
  • software maintenance; and
  • legal, accounting, compliance, or other professional services.

These providers may process personal information only as reasonably necessary to perform authorized services or as otherwise permitted by applicable law and relevant agreements.

The specific providers used may differ among AltaVidaSites and may change as our technology and operational needs change.

Material changes affecting our privacy practices will be reflected in this Privacy Policy, the Cookie Policy, or another applicable notice.

  1. Data retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including:

  • providing requested services and resources;
  • maintaining and administering accounts;
  • processing assessments and producing requested reports;
  • documenting consent and privacy preferences;
  • managing communications;
  • maintaining marketing-suppression lists;
  • supporting security, fraud prevention, backups, and service recovery;
  • resolving questions, complaints, and disputes;
  • complying with legal, tax, accounting, insurance, regulatory, and recordkeeping obligations;
  • enforcing agreements; and
  • protecting legal rights.

Retention periods may vary according to:

  • the type and sensitivity of the information;
  • the purpose for which it was collected;
  • the user’s reasonable expectations;
  • legal and contractual requirements;
  • security and fraud-prevention needs;
  • applicable limitation periods;
  • the existence of an ongoing relationship;
  • backup and recovery schedules; and
  • whether deletion is technically and legally feasible.

When a Tool or separate privacy notice states a specific retention period, that stated period will apply to the covered information, subject to disclosed legal, security, backup, transaction, and dispute-related exceptions.

When personal information is no longer reasonably necessary, we may delete, deidentify, aggregate, or securely dispose of it, subject to applicable legal, contractual, security, and recordkeeping requirements.

Deletion from active systems may not immediately remove information from encrypted backups, archival systems, fraud-prevention records, legal holds, transaction records, or records that must be retained by law. Information retained in backups will remain protected and will be deleted or overwritten according to the applicable backup schedule.

  1. Data security

We use administrative, technical, and physical safeguards designed to protect personal information according to its nature, sensitivity, and the risks associated with its processing.

Safeguards may include:

  • access controls;
  • authentication;
  • encryption during transmission;
  • encryption at rest where supported and appropriate;
  • role-based permissions;
  • database security policies;
  • least-privilege access;
  • logging and monitoring;
  • backups and service-recovery procedures;
  • software updates and vulnerability remediation;
  • vendor and service-provider review;
  • confidentiality obligations;
  • rate limiting;
  • spam and abuse controls; and
  • incident-response procedures.

No security system is perfect. We cannot guarantee that unauthorized access, loss, misuse, alteration, or disclosure will never occur.

Users are responsible for protecting their devices, passwords, accounts, access links, and copies of information. Users should notify us promptly if they suspect unauthorized access or misuse.

  1. Security incidents

If we discover a security incident involving personal information, we may take appropriate steps to investigate, contain, remediate, document, and respond to the incident.

Depending on the circumstances, those steps may include:

  • investigating the nature and scope of the incident;
  • containing and remediating the issue;
  • securing affected accounts or systems;
  • preserving relevant evidence;
  • notifying affected service providers, contractors, or business partners;
  • engaging cybersecurity, legal, insurance, or forensic professionals;
  • evaluating applicable notification obligations;
  • notifying government authorities when required by law; and
  • notifying affected individuals when required by law.

Users should notify us promptly if they suspect unauthorized access to an account, access link, report, submission, or communication associated with AltaVidaSites.

  1. Your choices

Depending on the user’s interaction with AltaVidaSites and applicable law, users may be able to:

  • decline to provide optional information;
  • update account or contact information;
  • correct assessment inputs;
  • unsubscribe from marketing communications;
  • manage cookie preferences;
  • request access to personal information;
  • request correction or deletion;
  • request a copy of certain information;
  • close an account;
  • withdraw consent where legally available;
  • object to or restrict certain processing;
  • opt out of legally defined sale, sharing, or targeted advertising;
  • revoke permission for future contact; and
  • request information concerning authorized disclosures.

Some requests may be limited by:

  • identity and authority-verification requirements;
  • legal or regulatory obligations;
  • security and fraud-prevention needs;
  • contractual rights;
  • transaction and recordkeeping requirements;
  • litigation holds;
  • technical limitations;
  • the rights and privacy of other persons; or
  • exceptions available under applicable law.

Withdrawing consent or requesting deletion will not necessarily affect processing or disclosures that lawfully occurred before the request was received.

  1. California privacy disclosures

This section applies to the extent we are subject to the California Consumer Privacy Act or another applicable California privacy law.

Depending on the circumstances, California consumers may have rights to:

  • know the categories of personal information collected;
  • know the sources of personal information;
  • know the purposes for collection, use, disclosure, sale, or sharing;
  • know the categories of recipients;
  • access specific pieces of personal information;
  • request deletion;
  • request correction;
  • receive certain information in a portable format;
  • opt out of legally defined sale or sharing;
  • limit certain uses or disclosures of sensitive personal information;
  • exercise qualifying rights through an authorized agent; and
  • exercise privacy rights without unlawful discrimination or retaliation.

Whether a particular right applies depends on the applicable law, the nature of the request, the information involved, statutory thresholds, and available exceptions.

  1. Categories of personal information potentially collected

Depending on the user’s interaction, we may collect:

  • identifiers and contact information;
  • customer-record information;
  • commercial and transaction information;
  • internet or electronic-network activity;
  • approximate geolocation;
  • professional, employment, military-service, or business information;
  • financial and retirement-planning information;
  • audio, electronic, or visual information;
  • assessment responses;
  • inferences or educational indicators generated from assessment responses; and
  • information that may qualify as sensitive personal information when voluntarily submitted.

The specific information collected depends on the applicable site within AltaVidaSites, Tool, form, transaction, or communication used.

  1. Categories of sources

Sources may include:

  • the consumer;
  • the consumer’s authorized representative;
  • devices and browsers;
  • service providers and contractors;
  • referral and business partners;
  • professional contacts;
  • public records and official sources; and
  • other persons authorized to provide information.
  1. Business and commercial purposes

We may collect, use, retain, and disclose personal information for the purposes described in Sections 6 through 13 of this Privacy Policy.

  1. Categories of recipients

Depending on the user’s request and interaction, recipients may include:

  • hosting, database, authentication, email, analytics, security, and other technology providers;
  • payment and transaction providers;
  • professional advisers;
  • licensed insurance professionals, agencies, and carriers;
  • authorized case designers and closing professionals;
  • business and service partners identified to the user;
  • independent merchants selected through affiliate links;
  • government authorities when legally required; and
  • other recipients acting at the user’s direction or with legally valid authorization.

We do not sell, rent, license, publish, or distribute contact lists or permit third parties to access our complete contact database.

  1. Other United States privacy rights

Residents of certain states may have additional rights concerning:

  • access;
  • correction;
  • deletion;
  • data portability;
  • targeted advertising;
  • legally defined sale or sharing of personal information;
  • profiling or automated processing;
  • sensitive personal information;
  • withdrawal of consent;
  • appeals of denied requests; and
  • requests submitted through authorized agents.

The availability and scope of these rights vary by jurisdiction and may depend on statutory thresholds, exemptions, the type of information involved, and the nature of the user’s relationship with us.

We will respond to valid requests as required by applicable law. When legally required, we will provide instructions for appealing a denied request.

  1. Do Not Track and opt-out preference signals

Some browsers offer a “Do Not Track” setting. Because there is no single uniform standard governing ordinary Do Not Track signals, AltaVidaSites may not respond to every Do Not Track setting.

Where required by applicable law, we will process legally recognized opt-out preference signals, such as a valid Global Privacy Control signal, for the applicable browser or device.

A browser-based preference signal may not apply to personal information associated with another browser, device, account, or offline interaction unless legally required and technically identifiable.

  1. Children’s privacy

The general AltaVidaSites are not directed to children under 13 and are not intended to collect personal information directly from children under 13.

Financial-literacy materials intended for children or families must be accessed and administered by:

  • parents;
  • legal guardians;
  • educators;
  • caregivers; or
  • other responsible adults.

Children should not independently:

  • create accounts;
  • subscribe to email communications;
  • submit contact forms;
  • make purchases;
  • upload content;
  • provide names or contact information;
  • provide photographs or voice recordings;
  • provide school or precise-location information; or
  • submit financial or other personal information.

If we learn that personal information was submitted directly by a child under 13 without legally sufficient authorization, we may delete the information, restrict access to it, disable the associated account or submission, and take other appropriate steps to prevent further collection.

Certain family educational programs offered through the AVBrands, including NAMA’s Little Money Lab, may provide supplemental privacy notices addressing their specific practices. Those supplemental notices should be read together with this Privacy Policy and will control for the applicable program if a conflict exists.

  1. Third-party links and embedded content

AltaVidaSites may link to, display, recommend, or embed content from:

  • government agencies;
  • educational resources;
  • social-media platforms;
  • video providers;
  • mapping services;
  • scheduling tools;
  • financial institutions;
  • insurers;
  • software and technology providers;
  • affiliate merchants;
  • business and referral partners; and
  • other independent third parties.

Third parties may collect information through their websites, applications, embedded content, cookies, pixels, referral identifiers, accounts, or transaction processes under their own privacy policies.

We do not control the privacy, security, accessibility, availability, pricing, terms, or business practices of independent third parties.

A link, recommendation, referral, introduction, or embedded resource does not necessarily mean that the third party sponsors, controls, or endorses the AVBrands.

Users should review the applicable third party’s privacy policy, cookie notice, and terms before submitting information, creating an account, or completing a transaction.

  1. Social media

When users interact with the AVBrands through a social-media platform, both we and the platform may receive information concerning the interaction.

This information may include:

  • account name or public profile information;
  • comments;
  • reactions;
  • shares;
  • direct messages;
  • submitted content;
  • referral information; and
  • other information made available through the platform.

The platform’s collection, use, retention, and disclosure of information are governed by its own privacy policy and settings.

Public comments, shares, reactions, photographs, videos, and posts may be visible to other users and the general public.

Users should not post sensitive, confidential, financial, insurance, benefits, health, identification, or account information publicly.

  1. Processing in the United States and other locations

We are based in the United States. Personal information may be stored or processed in the United States or in other countries where authorized service providers operate.

Privacy and data-protection laws in those locations may differ from the laws in the user’s jurisdiction.

We will use service providers and contractual or technical safeguards appropriate to the nature of the information and the services performed.

This section does not represent that the AVBrands actively market or offer services in every country where a service provider may maintain infrastructure.

  1. Authorized representatives

A person submitting a privacy request for another individual may be required to provide:

  • proof of identity;
  • proof of authority;
  • signed authorization;
  • guardianship documentation;
  • power-of-attorney documentation; or
  • other legally sufficient evidence.

We may contact the affected individual directly to verify the representative’s authority when permitted by applicable law.

Information submitted to establish identity or authority will be used only for verification, security, recordkeeping, and compliance purposes.

We may also contact the individual directly to verify authorization where permitted.

  1. Verification of privacy requests

To protect personal information, we may verify a privacy request by comparing information provided with information reasonably available in our records.

The verification process may vary according to:

  • the type of request;
  • the sensitivity of the information;
  • the risk of unauthorized access or harm;
  • whether an account exists;
  • the information maintained in our records; and
  • applicable legal requirements.

We will request only the information reasonably necessary to verify identity and authority.

We may decline, delay, or limit a request when identity or authority cannot be reasonably verified or when another exception applies under applicable law.

  1. Non-discrimination

Where required by applicable law, we will not unlawfully discriminate or retaliate against an individual for exercising a privacy right.

This does not prevent us from:

  • verifying a request;
  • declining or limiting a request subject to a legal exception;
  • protecting security and preventing fraud;
  • maintaining legally required records;
  • complying with contractual or regulatory obligations;
  • charging a lawful price;
  • offering a lawful service difference; or
  • limiting or discontinuing a feature when the requested personal information is reasonably necessary to provide that feature.

Any financial incentive or price or service difference involving personal information will be administered in accordance with applicable notice and consent requirements.

  1. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in:

  • the AVBrands;
  • AltaVidaSites;
  • Tools and applications;
  • information practices;
  • service providers and business partners;
  • affiliate relationships;
  • legal or regulatory requirements;
  • security procedures;
  • business operations; or
  • products and services.

The revised Privacy Policy will display an updated “Last updated” date.

When required by applicable law, we may provide additional notice, request renewed consent, or obtain new authorization before applying a materially different practice to previously collected personal information.

Previous versions may be retained for legal, compliance, security, and operational records.

  1. Contact information

Questions, concerns, privacy requests, and requests to exercise applicable privacy rights may be directed to:

AltaVidaSites
Operated by: Debora T DiBiasie, doing business through the AVBrands
Email: wealth@altavidacapital.com

Please include sufficient information to identify the nature of the request, but do not send Social Security numbers, account passwords, complete financial-account numbers, medical records, identification documents, or other unnecessary sensitive information by ordinary email.

We may request additional information through an appropriate process when reasonably necessary to verify identity or authority.

Contacting the AVBrands or AltaVidaSites does not create a legal, financial, benefits, insurance, tax, healthcare, fiduciary, or other professional relationship.