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Privacy Policy

This Privacy Policy governs AFIREFI LLC’s privacy practices, including the manner in which AFIREFI LLC collects, uses, maintains, protects, and discloses information collected from users (each, a “Student”) of AFIREFI LLC. This Privacy Policy applies to AFIREFI LLC and all Courses offered by AFIREFI LLC, whether through AFIREFI LLC’s website, mobile application, or any other software application (the “Service”).


By using the Service, you signify your acceptance of this Privacy Policy and you recognize and consent to AFIREFI LLC’s right to collect, use, maintain, and disclose, consistent with the terms of this Privacy Policy and AFIREFI LLC’s Terms of Use, any and all data and personal information you provide.  Your continued enrollment in and/or use of the Service following the posting of changes to this Privacy Policy effectuates your acceptance of those changes.


Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.  If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of the Service.  If you have any questions or concerns about our Privacy Policy or our practices with respect to your personal information, please contact us at


1. Information We Collect

We collect the following types of information.


Information you provide us directly​

In Short: We collect personal information that you provide to us, such as email address, username, and password.


We collect personal information that you voluntarily provide to us.  This information can include the following:

  • Information provided when you register your Student account, including username, password, e-mail address, and unique identifying “nickname.”

  • Payment information, including Student name, payment source, such as credit card or bank information, and other validating information.  We do not store or retain your payment information, which is transmitted for processing by our third-party payment processing vendor.

  • Communications between you and the Service. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Likewise, we may collect and store Student inquiries, questions, and other requests.



Information automatically collected 

In Short: Some information—such as IP address and/or browser and device characteristics—is collected automatically when you use the Service.


We automatically collect certain information when you use the Service.  This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, geographic location, information about how and when you use the Service, and other technical information.  We use this information to maintain the security and operation of the Service and for our internal analytics and reporting purposes. 


More specifically, the log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a webpage or app. Log file information can also be provided when the content of the webpage or app is downloaded to your browser or device.  When you use our Service, our servers automatically record certain log file information, including your web request, IP address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Students which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Device identifiers and cookies

In Short: With your consent, we may collect information on your activities in accessing the Service using device identifiers, cookies, and similar technologies.


Like many businesses, we also collect information through device identifiers, cookies, and similar technologies.  When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more device identifiers. Device identifiers are small data files or similar data structures stored on or associated with your mobile device that uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by the Service.


Likewise, if you are accessing the Service through an internet browser on a personal computer or laptop, we may access, collect, monitor, store on your device, and/or remotely store one or more cookies.  Cookies are files containing information sent by a website that records a user’s browsing activities.  The files are extremely small and may be stored, like a device identifier, remotely or on the user’s hard drive.  Their purpose is to remember a user’s previous browsing activity so as to optimize the user’s website experience in the future.  For example, a website might use a cookie to auto-fill a user’s login information the next time he or she visits that website.


The Service uses device identifiers, cookies, and the like for browsing optimization and analytics.  A device identifier or cookie may deliver information to us or to a third-party partner about how and how long you access the Service, how you navigated to the Service, and certain other information. These technologies do not store any personal information about you.


When you signed up for the Service, you acknowledged and accepted our use of device identifiers and cookies.    You can withdraw your acceptance of our cookie use at any time by discontinuing your use of the Service.


Web browser applications, such as internet explorer, safari, etc., also permit a user to alter browser settings to reject cookies.  A user may prevent all cookies or allow cookies from select websites and applications only.  The process for managing cookies varies depending on the web browser used.  Refer to your web browser’s help menu for further information.


Please note that some features of the Service may not function as well if use or availability of these technologies is impaired or disabled.

Information collected through mobile applications

In Short: We may collect information regarding your geo-location, mobile device, and push notification preferences when you access the Service using your mobile device.


If you access the Service using a mobile device, we may also collect the following information:


  • Geo-location information.  We may request access or permission to and track location-based information from your mobile device, continuously or while you are accessing the Service, to provide location-based services.  If you wish to change our access or permissions, you may do so in your device’s settings.

  • Mobile device access.  We may request access or permission to certain features from your mobile device, including your photos.  If you wish to change our access or permissions, you may do so in your device’s settings.

  • Mobile device data.  We may automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.

  • Push notifications.  We may request to send you push notifications regarding your account.  If you wish to change your preferences regarding push notifications, you may do so in your device’s settings.


Information collected from other sources

In Short: We may collect limited data from public databases, social media platforms, and other outside sources.


We may obtain information about you from other sources, such as public databases, social media platforms (such as Facebook and Instagram), and other third parties.  Examples of information we receive from other sources may include certain social media profile information, such as age, gender, geographic location and other information you choose to make public.

2. How We Use Your Information

In Short: We process your information with your freely given consent to fulfill our obligations to Students, to comply with legal obligations, and to advance our legitimate business interests, including the efficient and effective administration of the Service.


We use personal information about Students to the limited extent needed to advance and effectuate our business.  We process your personal information for these purposes with your consent (“Consent”), to fulfill our obligations to Students (“Contractual Reasons”), to comply with legal obligations (“Legal Reasons”), and for our legitimate business purposes (“Business Purposes”).


We use information from Students for the following:

  • To facilitate account creation and login.
    With your consent, we use information you have provided to create your account and ensure you secure access to the Service, including remembering username and password information so you don’t need to reenter it each time you access the Service if you so choose.

  • To enable Student interaction with the Service and other Students. 
    With your consent, we may use information you have provided to facilitate communications between Student and Service.

  • To enforce our terms, conditions, and policies. 
    For Contractual Reasons, Legal Reasons, and/or Business Purposes, we may use your information to ensure compliance with our terms, conditions, and policies.

  • To respond to legal requests and prevent harm or illegal activities. 
    If we receive a legal request, such as a subpoena, or other information indicating a Student is engaging in illegal activities using the Service, we may use Student information for Legal Reasons.

  • For our Business Purposes. 
    We may use your information for our Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of promotional campaigns, monitoring, testing, improving, and updating the Service, diagnosing and repairing technical problems, and developing, testing, and providing new products and features.

3. Sharing of Your Information

In Short: We share User information only with your consent and/or to the limited extent necessary to comply with laws, protect your rights, and fulfill our business purposes and obligations.


We will only share your information in the following circumstances:


  • Compliance with Legal Requirements.
    We may disclose your information when we are legally required to do so in order to comply with applicable laws and regulations, governmental requests and requirements, and judicial proceedings, court orders, and other legal processes, including subpoenas, warrants, and other requirements of public authorities for law enforcement and national security purposes.

  • Vital Interests and Legal Rights. 
    We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud or other illegal activities, situations involving threats to the safety of any person, animal, or other entity, or as evidence in any litigation, arbitration, or other legal processes in which we are involved.

  • Vendors, Consultants, and Other Third-Party Service Providers. 
    We may share your data with third-party vendors, service providers, contractors, agents, or other third parties who perform services for us or on our behalf and require access to such information to do that work.  Examples may include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts.  With your consent, we may allow select third parties to use tracking technologies on the Service, which allow them to collect data about how you interact with the Service over time.  This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and optimize the Service.

  • Business Transfers. 
    We may share or transfer your information in connection with, or during negotiations for, any merger, sale of company assets, financing, or acquisition of all or any portion of our business to any other entity or individual.

4. Storing and Protecting Your Data

In Short: We process, store, and retain your information as outlined in this Privacy Policy only to the extent necessary to operate and fulfill the purposes of the Service, and we aim to protect your information from threats using a system of organizational and technical security measures.


Storage and Processing:

We do not store any personal information about Students other than your username, password, email address, and unique identifying nickname.  Our payment processing vendor may store additional personal information relating to payment processing.


AFIREFI LLC maintains its servers and facilities in the United States.  Whatever location you access the Service from, please be aware that your information may be transferred to, stored, and processed by us in the United States and/or by our affiliates and third-party service providers in the United States or in any other country in which they maintain servers or facilities.


If you are a resident of the European Economic Area, note that the countries in which your information is processed and stored may not have data protection laws as comprehensive as those in your country of residence.  We will, however, always take all necessary steps to protect your information in accordance with this Privacy Policy and applicable law.



 We have implemented appropriate technical and organizational security measures designed to protect the security of all of our Users’ information.  Our security measures include employing technology to prevent attacks on our databases.  We also take commercially reasonable steps to ensure only you can access your account, including verifying your identity through your unique login information. However, we cannot guarantee all information is 100% secure at all times, and while we use best efforts to protect all your information, you provide all information at your own risk. 


Please do what you can to help us keep your information safe, including maintaining the secrecy of your unique login information, restricting access to emails between you and the Service, and accessing the Service only within a secure environment.



 We will only keep your personal information for as long as necessary to fulfill the Service’s purposes as set out in this Privacy Policy, unless longer retention periods are required or permitted by law (such as for tax or accounting requirements).  Upon cancellation of your subscription, we will delete your information from our databases; if we cannot do so immediately (for example because your personal information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.

5. Policy Regarding Minor Children


In Short: We do not knowingly collect information from or market to children under 18 years of age.


We do not knowingly solicit information from or market to children under the age of 18.  By using the Service, you represent that you are at least 18 years old or that you are the parent or guardian of a minor and consent to the minor’s use of the Service and our limited processing of that minor’s information. If we learn that we have collected personal information from a Student under the age of 18 without a parent or guardian’s consent, we will terminate the account and take reasonable measures to promptly delete the minor’s information from our records.  If you believe that we have collected information from a child under the age of 18 without proper consent, please contact us using the contact information below.

6. Your Rights/Choices About Your Privacy and Information


In Short: Your enrollment in and use of the Service constitutes your agreement to our use of your information in accordance with this Privacy Policy. You may terminate your account at any time, at which time we will remove your information from our databases.  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.


In some regions, such as the European Economic Area, you have certain rights under applicable data protection laws.  These rights may include the right to request access to and obtain a copy of your personal information, request rectification or erasure of certain information, restrict the processing of your personal information, and data portability.  In certain circumstances, you may also have the right to object to the processing of your personal information.  Please submit any such request in writing using the contact information provided below.  We will review, consider, and act upon any request in accordance with applicable data protection laws.


If you are a resident of the European Economic Area and you believe we are unlawfully processing and storing your personal information, you have the right to complain to your local data protection supervisory authority.  You can find the appropriate contact details by searching for “National Data Protection Authorities” online.


If you previously consented to our data processing and storage policies, you may withdraw that consent at any time by terminating your account and ceasing use of the Service.  Please note that any such termination will not affect the lawfulness of our processing of your information prior to the termination.  Upon termination of your account, we will delete your information from our active databases.  However, we may retain some information as needed to prevent fraud, troubleshoot problems with the Service, comply with legal requirements, assist with law enforcement and national security investigations, and enforce our Terms of Use.


You can also unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications.  Note, however, that you may not opt-out of Service-related communications, such as account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices, etc.

7. Privacy Rights Specific To Residents Of California


In Short: If you are a resident of the State of California in the United States, you have specific rights regarding access to your personal information.


California Civil Code Section 1798.83 permits California residents to request and obtain, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we have shared personal information in the immediately preceding calendar year. 


We do not share user information with third party advertisers and will confirm this policy in compliance with California Civil Code Section 1798.83 upon receipt of a Student’s request in writing using the contact information provided below.

8. Updates To The Privacy Policy


In Short: We will update this Privacy Policy periodically as necessary to comply with relevant laws.


We may modify and update this Privacy Policy from time to time.  The updated versions will be indicated by an updated “Last modified on” date above and will be effective as soon as accessible.  If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this Privacy Policy frequently and immediately after any modifications so as to stay informed about how we are protecting your information.

9. How To Contact Us


If you have any questions about this Privacy Policy, please contact our Data Protection Officer, Patricia Whittaker, via email at

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