Privacy Policy

1. WHO WE ARE

This website is operated by Sondra Imperati, founder and CEO of Persistent Courage LLC (referred to in this policy as “Persistent Courage,” “we,” “us,” or “our”).

Website: www.persistentcourage.com

Contact email: sondra@persistentcourage.com

For visitors in the European Union or United Kingdom, Sondra Imperati acts as the data controller for any personal data collected through this site.

2. WHAT INFORMATION WE COLLECT

A. Information You Give Us Directly

When you interact with this site, you may provide personal information voluntarily, including:

· Name and email address (when you contact us, join our email list, or book a consultation)

· Phone number (if provided during booking or inquiry forms)

· Payment information (processed securely through a third-party payment processor; we do not store your credit card or bank details)

· Information you share in coaching intake forms, questionnaires, or application forms

· Messages and communications you send through contact forms or email

B. Information Collected Automatically

When you visit this website, certain technical information is collected automatically:

· IP address and approximate geographic location (country/region)

· Browser type, operating system, and device type

· Pages visited, time spent on each page, and links clicked

· Referring website (how you found us)

· Date and time of your visit

This information is collected through cookies and analytics tools (see Section 5).

C. Information from Third-Party Platforms

If you book an appointment through a scheduling tool (such as Calendly or Acuity), enroll in a course through an online platform, or engage with us through social media, those platforms may collect and share information with us under their own privacy policies.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

· To respond to inquiries and communicate with you about our services

· To schedule and manage coaching consultations and appointments

· To deliver coaching programs, courses, and digital products you have purchased

· To send email newsletters, updates, and marketing communications (only if you have opted in — you may unsubscribe at any time)

· To process payments and manage billing

· To improve the design, content, and functionality of this website

· To analyze website traffic and understand how visitors find and use our site

· To comply with legal obligations and protect the rights of Persistent Courage LLC

We do not sell, rent, or trade your personal information to any third party for their marketing purposes. Ever.

4. LEGAL BASIS FOR PROCESSING YOUR DATA (EU/UK VISITORS)

If you are located in the European Union, United Kingdom, or another jurisdiction covered by the General Data Protection Regulation (GDPR) or equivalent law, we process your personal data on the following legal grounds:

· Consent: When you opt in to our email list, accept cookies, or submit a form, you are giving us consent to process your data for that specific purpose. You may withdraw consent at any time.

· Contract: When you purchase a product or service, we process your data to fulfill the terms of that agreement.

· Legitimate Interests: We use analytics data to improve our website and services, which we consider a legitimate business interest that does not override your rights.

· Legal Obligation: We may process data as required by applicable law.

5. COOKIES & TRACKING TECHNOLOGIES

This website uses cookies — small text files stored on your device — and similar tracking technologies. Cookies help us understand how visitors use the site and allow certain features to function properly.

Types of Cookies We Use

· Essential cookies: Required for the website to function. These cannot be disabled.

· Analytics cookies: Help us understand traffic patterns and visitor behavior (e.g., Google Analytics 4). These are only set with your consent.

· Marketing/Advertising cookies: If we run paid advertising campaigns, these may track whether you arrived from an ad. Only set with your consent.

· Functional cookies: Remember your preferences (such as language or region).

Your Cookie Choices

When you first visit this site, you will be presented with a cookie consent notice where you can accept or decline non-essential cookies. You may also manage cookies through your browser settings at any time. Disabling certain cookies may affect the functionality of parts of this site.

To opt out of Google Analytics tracking specifically, you may use the Google Analytics Opt-out Browser Add-on available at: tools.google.com/dlpage/gaoptout

6. HOW WE SHARE YOUR INFORMATION

We do not sell or share your personal data with third parties for their own marketing. We may share your information only in the following limited circumstances:

Service Providers

We work with third-party tools and platforms that process data on our behalf in order to operate our business. These include:

· Email marketing platforms (e.g., Mailchimp, ConvertKit, or Flodesk) for sending newsletters and automated communications

· Scheduling tools (e.g., Calendly, Acuity) for booking management

· Payment processors (e.g., Stripe, PayPal) for secure transaction processing

· Online course platforms (e.g., Teachable, Kajabi, Thinkific) for course delivery

· Website analytics (e.g., Google Analytics) for traffic analysis

· Customer relationship management (CRM) tools for managing client records

Each of these providers has its own privacy policy and data processing practices. We select providers who meet appropriate data protection standards.

Legal Requirements

We may disclose your information if required to do so by law, court order, or government authority, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Persistent Courage LLC, our clients, or others.

Business Transfers

In the unlikely event of a merger, acquisition, or sale of business assets, your information may be transferred as part of that transaction. You will be notified of any such change and your rights under this policy will be maintained.

7. EMAIL COMMUNICATIONS & MARKETING

If you subscribe to our email list, book a consultation, or purchase a product, you may receive emails from Persistent Courage. These may include:

· Newsletters, articles, and reflections on leadership and courage

· Information about new offerings, courses, workshops, or events

· Booking confirmations and session reminders

· Follow-up communications related to your coaching or consulting engagement

You may unsubscribe from marketing emails at any time by clicking the “Unsubscribe” link at the bottom of any email. Transactional emails related to purchases or active engagements may continue until your service period ends.

We comply with the CAN-SPAM Act (United States) and applicable email marketing regulations. We do not send unsolicited commercial email.

8. HOW LONG WE KEEP YOUR DATA

We retain your personal information only for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required by law.

· Email subscribers: Retained until you unsubscribe or request deletion.

· Client records: Retained for a minimum of 7 years following the end of an engagement to comply with business and tax record requirements.

· Website analytics data: Typically retained for 14 months (Google Analytics default), after which it is aggregated and anonymized.

· Payment records: Retained as required by tax and accounting law (typically 7 years).

When data is no longer needed, it is securely deleted or anonymized.

9. YOUR PRIVACY RIGHTS

Depending on where you live, you may have certain rights regarding your personal data.

For All Visitors

· Right to access: You may request a copy of the personal information we hold about you.

· Right to correction: You may ask us to correct inaccurate or incomplete information.

· Right to deletion: You may request that we delete your personal data, subject to legal retention requirements.

· Right to opt out: You may unsubscribe from marketing emails at any time.

For EU/UK Visitors (GDPR Rights)

· Right to restrict processing: You may ask us to limit how we use your data.

· Right to data portability: You may request your data in a portable format.

· Right to object: You may object to processing based on legitimate interests.

· Right to withdraw consent: You may withdraw any consent you have given at any time, without affecting the lawfulness of prior processing.

· Right to lodge a complaint: You have the right to complain to your local data protection authority (e.g., the ICO in the UK, or your national DPA in the EU).

For California Residents (CCPA Rights)

· Right to know: You may request details about the categories and specific pieces of personal information we have collected about you.

· Right to delete: You may request deletion of your personal information.

· Right to opt out of sale: We do not sell personal information. No opt-out is required, but it is your right.

· Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise any of these rights, contact us at: sondra@persistentcourage.com. We will respond within 30 days (or within the timeframe required by applicable law).

10. HOW WE PROTECT YOUR DATA

We take reasonable technical and organizational measures to protect your personal information from unauthorized access, disclosure, loss, or misuse. These measures include:

· Using reputable, secure platforms for email, payments, and course delivery

· Password protection and access controls on accounts that hold personal data

· Transmitting data over encrypted (HTTPS/SSL) connections

· Limiting access to personal data to those who need it to perform their role

No system is 100% secure. While we work diligently to protect your information, we cannot guarantee absolute security. In the event of a data breach that affects your rights or freedoms, we will notify you as required by law.

11. THIRD-PARTY LINKS

This website may contain links to external websites, social media platforms, podcast directories, book retailers, or other third-party services. These sites have their own privacy policies, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policy of any site you visit through a link on our website.

12. CHILDREN’S PRIVACY

This website is intended for adults and is not directed to children under the age of 13 (or under 16 for visitors in the EU/UK). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at sondra@persistentcourage.com and we will promptly delete it.

13. INTERNATIONAL VISITORS

Persistent Courage is based in the United States. If you are accessing this website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.

For visitors in the European Union or United Kingdom, we rely on appropriate safeguards for international data transfers, including the use of platforms and processors that comply with GDPR transfer mechanisms (such as Standard Contractual Clauses). By using this site, you consent to this transfer.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we do, we will update the effective date at the top of this page. For significant changes, we will notify active email subscribers with a summary of what changed.

We encourage you to review this policy periodically. Continued use of this website after any update constitutes your acceptance of the revised policy.

15. CONTACT US

If you have questions, concerns, or requests related to this Privacy Policy or the way we handle your personal data, please reach out:

Sondra Imperati · Persistent Courage LLC

Email: sondra@persistentcourage.com

Website: www.persistentcourage.com

We take privacy seriously and will respond to all inquiries promptly.