Privacy Policy

At Clo Bare LLC (“Clo Bare”, “we”, or “our”), we are committed to protecting your privacy. This Privacy Policy (the “Policy”) explains what information we receive from our Website (as defined below), in emails, texts, and other electronic communications (the “Communications”), as well as in connection to your purchase of our services (the “Services”) and how we use, maintain, and disclose this information.

 

Our “Website” means the following websites and assets: clobare.com, thelazyinvestorscourse.com, lazymoneymaster.com, instagram.com/clobaremoneycoach, tiktok.com/@clobaremoneycoach, The Money Bare podcast, our private online communities, and any other asset owned by Clo Bare.

 

This Policy does not cover offline data or data collected through other means.

 

1. Information Collection

We, directly or through our Third-Party Partners (as defined below), collect the following information about you when you use our Website and engage in Communications with us:

  • Basic Identifying Information. Information such as your full name, username, postal address, e-mail address, and account name.
  • Device Identifier and other Unique Identifiers. Information we collect automatically when you engage with our Website, or engage in Communications with us, such as information about the device you are using, including but not limited to the type of device you use, the temporary or persistent unique device identifier (UDID) placed by us or our service providers, the IP address of your device, your operating system, the type of browser you use, and data from the way you use our Website. For more information, see Cookies and Related Tracking Technologies.
  • Payment Information. Information such as your payment information, credit card information, and other forms of payment to permit you to purchase our Services. We may collect this information directly from you and from our Third-Party Partners.
  • Internet or Other Network Activity. Information such as your browsing or search history, and other information regarding your interactions with our Website, emails, applications, and advertisements. We obtain this information from our Third-Party Partners.
  • Geolocation Information. Information that permits us to determine your general location, such as zip code or physical location. We obtain this information from our Third-Party Partners.
  • Commercial Information. Information such as the nature of the Services purchased, obtained, or considered. This includes other purchase histories, consuming tendencies, and related information concerning your commercial activity. We obtain this information directly from you when you engage with our Website.
  • User Content. Information such as your Communications with us and any other content you provide to us, such as social media profiles, photographs, images, videos, survey responses, comments, reviews, testimonials, gender information and related demographic information you provide us with, professional or employment-related information you provide us with, and other content you provide to us.
  • Audio Information. Information such as recordings of your voice (such as when we record coaching calls for quality assurance). We obtain this information directly from you.
  • Usage Information. Information such as the features you use on our Website, the emails you open, links you click, and items you view, pages you visit, advertisements you view, the time of day you browse, and your referring and exiting pages. We receive this information from our Third-Party Partners, including but not limited to through third-party tracking pixels and unique links.
  • Location Data. Information such as imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) or the location of your device. We receive this information from our Third-Party Partners. Your device should require you to provide permission before our Third-Party Partners obtain precise geolocation information from a browser's geolocation API or from technologies like GPS, WiFi, and/or cell towers. We and our Third-Party Partners may use this approximate location and/or precise geolocation information, along with other information submitted by you, to monitor our compliance with export control laws. Most browsers and mobile devices allow users to enable or disable precise geolocation using pop-ups or controls located in the settings menu.
  • Data from Publicly Available Sources, such as data in the public domain and through widely available media sources, including social networks and internet service providers.
  • Inferences. Information such as inferences we may draw on the above information and your interaction with us, including regarding your preferences and characteristics. We obtain this information directly from you and from our Third-Party Partners.

 

2. Data Collection Methods 

Information We Collect Automatically From You

When you use our Website and engage in Communications with us, we automatically collect certain information from you, including your name, account name, email, postal address, and device’s IP address.

We do not use automated decision-making or profiling that produces legal or similarly significant effects.

Information We Collect About You From Third-Party Partners

We collect information about you from third parties (“Third-Party Partners”), including Google Analytics, service providers such as those who offer performance services on our behalf for advertising, data analytics, payment processing, operating systems and platforms, and other related services payment processors, email service providers, and customer relationship management platforms.

We are not responsible for the privacy practices or content of any of our Third-Party Partners. We encourage you to review the privacy policies of any third-party sites or services before providing them with your personal information.

Cookies and Related Tracking Technologies

We work with companies, analytics systems, and customer relationship management companies, including Google Analytics, to help us understand how users access and use the Website and view our Communications, as well as help us understand market trends and popularity of our Services. As part of this process, we may incorporate analytics and tracking technologies into our Website and some of our Communications such as e-mails.

Tools used include tracking pixels (also known as web beacons). This is a type of code that is embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contain JavaScript code). When you access our Website or view our Communications, the pixel permits us or a third party to monitor which links are clicked or when our Communications are opened. We may incorporate third party tracking pixels that allow us to track our Communications and advertise our Services to you.

You can learn more about such third-party analytics by visiting such third-party websites, and you can opt out of Google Analytics at tools.google.com/dlpage/gaoptout.

3. Use of Information

We use your information to:

  • Process your requests, such as price quotes, purchases, payments, and responses to email questions, and prevent fraud;
  • Support our core business functions, such as internal business process management and authentication;
  • Communicate with you about our services and promotions;
  • Personalize your Website experience and deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message;
  • Provide the Website to you;
  • For testing, research, analysis, and product development, including to develop and improve our Website and Services;
  • Create, maintain, and customize your account;
  • Improve our marketing and promotions;
  • Statistically analyze the usage of our Website, Services, and Communications;
  • Contact you to perform the Services;
  • Resolve disputes, investigate problems, and enforce our terms;
  • Help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business;
  • Respond to law enforcement requests as required by applicable law, court order, or governmental regulations;
  • Help diagnose problems with our server, manage our Website, including databases and other technology and business assets, to enhance our Services; and
  • Perform a business transaction, such as a merger, acquisition, sale of assets, bankruptcy, or related transactions in which personal information we hold about our Website users/consumers is among the assets transferred.

 

4. Disclosure of Information

 

We may disclose or make available your information in the following circumstances:

  • With Your Consent which may be obtained in writing, online, when you accept our terms for our Website, or orally (including during coaching calls).
  • With Third-Party Partners such as service providers, affiliates and subsidiaries, business partners, credit / debit card processing partners, Third-Party Partners that facilitate billing, shipping, and customer service, third-party auditors and law firms, marketing and advertising networks (including those that provide ad measurement services), internet service providers, data analytics providers, companies that help debug and identify and repair errors that may impair the functionality of our Website, and third parties that help protect against malicious, deceptive, fraudulent, or illegal activity.
  • In Business Transfers as part of a business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction.
  • For Legal Process & Protection to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) enforce or apply agreements, or initiate, render, or bill for use of the Website; (2) protect our rights or interests, property or safety or that of others; (3) in connection with claims, disputes, or litigation; (4) protect users of our Website and other carriers, providers, or partners from fraudulent, abusive, unlawful, or otherwise improper use of our Website; (5) facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.

We may transfer your information to service providers in states or countries outside your residence. For E.U. residents, we use Standard Contractual Clauses or other approved mechanisms to ensure adequate protection. By using our Website, you consent to such transfers.

5. Data Retention

 

We retain your information only as long as necessary to provide our Services, comply with our tax, accounting, and legal obligations, resolve disputes, and enforce our agreements. Our current retention period is seven (7) years. When no longer needed, we securely delete or anonymize your information.

In the event of data breach affecting your information, we will notify you as required by applicable law.

 

6. Your Rights 

 

You can control data use through:

 

  • Browser settings for cookies, and
  • Opt-out options for marketing communications.

 

You have the following rights (your “Rights”):

  • Right to Know, Access, and Portability. Request that we confirm whether we are processing your information, obtain details about the processing activities, and obtain a copy of such information, subject to exceptions.
  • Right to Delete. Request deletion of your information, except where information retention is required to comply with laws.
  • Right to Correct. Request correction of your information, except where the information is accurate, maintained for legal compliance or research purposes, or where correction is impossible or involves disproportionate effort.
  • Limit the Processing of Sensitive Personal Information. If you live in state where privacy laws require it (including California, Colorado, Connecticut, Virginia, Montana, Oregon, or Texas), you have a right to ask that Clo Bare limit how it processes your sensitive personal information, except to the extent necessary to perform the Services or where such information is maintained for legal compliance.
  • Opt-Out of Sharing or Targeted Advertising. We do not sell your information for monetary consideration. However, under certain state privacy laws (including California, Colorado, Connecticut, Virginia, Montana, Oregon, and Texas), our receipt of information about you from our Third-Party Partners through the use of certain online tracking technologies may be legally classified as a “sale” or “sharing” of personal information. You may opt-out of these marketing activities by clicking “unsubscribe” in any marketing email or by emailing us at [email protected]. We will process opt-out requests within ten (10) business days. Our Website does not currently respond to “Do Not Track” signals, but you may also exercise your right to opt-out of targeted advertising by using the Global Privacy Control (GPC) (on the browsers and extensions that support such a signal). If you choose to use the GPC signal, you will need to turn it on for each supported browser extension you use.
  • Right to Appeal. Appeal any denial of a right to access, delete, correct, or opt-out, as described above.

 

For residents of the E.U., we process your data based on consent, contract performance, or legal obligations, and you may withdraw your consent at any time by emailing [email protected].

 

To exercise all of your above Rights, please email your data request to [email protected]. We may require you to verify your identity before processing requests. You may designate an authorized agent to submit requests on your behalf by providing written authorization to [email protected]. We will respond to verified requests within 45 days (or as otherwise required by applicable law). We will not discriminate against you for exercising any of your Rights.

 

7. Children's Privacy

 

Our Website is directed to adults and we do not knowingly collect the personal information from children under the age of 18, unless they have lawfully registered with verifiable parental consent. If you are the parent or guardian of a child under the age of 18, and you believe your child has provided their personal information to us without your consent, please contact us.

 

8. Data Security

 

Although no system or website can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in accordance with all applicable laws and regulations, as appropriate to the sensitivity of your information.

 

9. Changes to Policy

 

Clo Bare may change this Privacy Policy from time to time. Clo Bare will notify you about changes to this Privacy Policy, as appropriate under applicable law, which may include notice posted on the Website or in Communications with you.

 

10. Contact Information

 

For questions about this Policy or to exercise any rights described herein, you may contact Clo Bare at [email protected].