Privacy Policy

This Privacy Policy explains how RAW Recovery LLC collects, uses, and protects personal information when you use our members-only client portal, available on the web at clients.emotionalfortitude.com and through the RAW app, our Kajabi-branded mobile app (together, the "Portal"). It is separate from the privacy policy for our public website, rawrecoveryandwellness.com.

The Portal is a password-protected space for members enrolled in The Fortitude Program™ and other RAW programs. It provides program curriculum, live and recorded sessions, a private community forum, and members-only content, delivered through our platform provider, Kajabi.

In this policy, "we," "us," and "RAW" mean RAW Recovery LLC, a California limited liability company. "You" means anyone who creates an account, accesses content, takes part in the community forum, or otherwise uses the Portal.

The Portal exists to support men doing the work of personal growth, emotional development, and nervous system health through The Fortitude Program™ and related RAW programs. The work you do here is personal, and we take the protection of your information seriously.

A. Account and Identity Information

When you create an account or enroll, we collect:

• Your name, email address, and password (stored in hashed form, never in plain text);
• Profile information you choose to add, such as a photo or short bio;
• Your program enrollment details; and
• Your communication preferences.

B. Payment and Billing Information

Payments are processed by Kajabi or Stripe, depending on how you enroll. We do not store full card or bank account numbers. We receive and keep:

• Transaction records (date, amount, and what was purchased);
• The last four digits of the card used, where the processor provides them;
• Your billing address, if provided at checkout; and
• Whether you paid in full or chose the three-payment plan, your payment dates, and any withdrawal or refund records.

C. Program Participation

As you use the Portal, we collect information about your participation, including:

• Which modules, lessons, and resources you have accessed and completed;
• Intake assessments, weekly check-ins, and exercises you submit;
• Attendance at live sessions on Zoom (date, time, and duration); and
• Written reflections or other work you submit through the Portal.

D. Community Forum Posts

If you post in the community forum, on the web or in the RAW app, we collect what you post, including comments, replies, and any media you upload. See Section 7 for more about the community forum.

E. Technical and Device Information

When you use the Portal, we and our platform provider automatically collect:

• IP address, browser type, and operating system;
• Device type and, in the RAW app, device identifiers and push notification tokens if you turn on notifications;
• Pages and screens viewed, time spent, and how you move through the Portal;
• Session timestamps and log data; and
• The page you came from before entering the Portal.

F. Communications

If you message your coach in the RAW app or on the web, or contact us by email, we keep a record of those communications, including any personal information you include. Program emails are sent through Kajabi.

You are never required to share this information. Anything you share, in written exercises, check-ins, community forum posts, or live sessions, is shared by choice.

How We Treat Sensitive Disclosures

• What you share in individual exercises, assessments, direct submissions, or messages with your coach is available to your assigned coach and to RAW program staff as needed to support your participation. It is not visible to other members.
• What you share in the community forum is visible to other members, as described in Section 7.
• We do not use your personal disclosures for advertising, profiling, or marketing.
• We do not sell or share your personal disclosures with third parties, except as required by law or as described in Section 5.

The Portal Is Not a Clinical Service

The Fortitude Program™ and all Portal content are coaching and educational services. They are not mental health treatment, psychotherapy, or clinical care, and nothing in the Portal creates a therapist-client, medical, or other licensed professional relationship. If you are in crisis, call or text the 988 Suicide & Crisis Lifeline (988) or call 911.

We do not use your Portal information to:

• Serve behavioral advertising or sell your data to advertisers;
• Build profiles for sale to data brokers;
• Train third-party artificial intelligence models on your personal disclosures; or
• Send you unrelated offers from other companies.

We use the following service providers to run the Portal and deliver programs. Each processes information on our behalf under its own privacy policy and applicable law.

We may also disclose information:

• To comply with the law: in response to a valid court order, subpoena, or other legal process;
• To protect safety: when we believe in good faith that disclosure is necessary to prevent imminent harm to you or others;
• In a business transfer: if RAW is acquired, merges, or sells its assets, your information may transfer as part of that transaction, and we will notify you; and
• With your consent: for any other purpose you explicitly approve.

We do not sell your personal information.

Recordings may be used to:

• Let enrolled members who could not attend live watch the replay;
• Support quality review and coach supervision by RAW staff; and
• Improve the program and curriculum, using de-identified excerpts only and only with your additional express permission.

We will tell you at the start of a session when it is being recorded. If you do not want to be recorded, you may turn off your camera or microphone, or contact us before enrolling to talk about accommodations. Some parts of a live session may require speaking to take part fully.

Recordings are stored on Zoom and in the Portal's Kajabi environment. They are available only to enrolled members of that program group, their coach, and RAW staff, and are never shared publicly. Members may not record, download, or share recordings except through the tools RAW provides. Doing so may lead to immediate suspension.

The community forum, on the web and in the RAW app, is where members post, comment, and reply to one another. Taking part is voluntary. Before you post, please understand the following.

What Other Members Can See

What you post is visible to other enrolled members who have access to the same space, along with your display name and profile photo if you have one. The forum is not public, since only verified members can see it, but it is not private between you and RAW.

License to Display Your Posts

When you post, you give RAW Recovery LLC a non-exclusive, royalty-free license to display, store, and moderate that content within the Portal so the community can function. We will not use your posts in outside marketing without your separate written consent.

Member Confidentiality

Under the Terms & Conditions, every member agrees to keep other members' disclosures confidential. Members may not:

• Screenshot, copy, or share another member's content without permission;
• Share another member's identity or disclosures outside the Portal; or
• Use the forum to solicit or collect contact information from other members.

Moderation

RAW may review, moderate, edit, or remove forum content that violates our community standards, the Terms & Conditions, or the law. Content that could cause harm, violates another member's privacy, or disrupts the safety of the community will be addressed, which may include suspension.

Your Posts After You Leave

When your Portal access ends, your forum posts may stay visible to current members unless you ask us to delete them. You can ask us to remove your posts at any time, before or after your access ends, using the contacts in Section 13.

The Portal uses cookies and similar technologies. Because it is a members-only space, these are used mainly to keep the Portal working and to understand how it is used, not for advertising.

We do not use advertising cookies, retargeting scripts, or cross-site tracking inside the Portal.

Kajabi Platform Cookies

Kajabi sets its own functional and analytics cookies to run the platform. These are covered by Kajabi's privacy policy as well as this one.

Managing Cookies

You can control cookies through your browser settings. Blocking strictly necessary cookies will prevent you from logging in to the Portal.

We keep personal information only as long as we need it for the purposes it was collected for, to keep business records, to meet legal obligations, to resolve disputes, and to enforce our agreements.

When we no longer need information, we delete it securely or de-identify it so it can no longer be linked to you.

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA):

Shine the Light (Civil Code §1798.83)

California residents may ask whether we disclosed personal information to third parties for their direct marketing in the previous calendar year. We do not disclose personal information to third parties for their direct marketing.

How to Make a Request

To exercise any of these rights, contact us using the details in Section 13. We will respond to verified requests within 45 days. We may need to confirm your identity first, usually by confirming the email address on your account. You may also have an authorized agent make a request for you. We will need your written authorization and may verify the agent's identity.

We take the security of your information seriously, especially given the personal nature of what members share. We maintain reasonable administrative, technical, and physical safeguards, including:

• SSL/TLS encryption for data sent to and from the Portal and app;
• Hashed password storage;
• Staff access to member information on a need-to-know basis;
• Kajabi's platform security for hosting and data storage; and
• PCI-DSS compliant payment processing through Kajabi and Stripe.

If a data breach materially affects your personal information, we will notify you as required by California law, including the California Data Breach Notification Law (Civil Code §1798.82).

We may update this Privacy Policy to reflect changes in our practices, the law, or Portal features. When we make material changes, we will:

• Post the updated policy on this page with a new "Last updated" date;
• Email the address on your Portal account; and
• For significant changes, show a notice in the Portal the next time you log in.

If you keep using the Portal after an update takes effect, you accept the revised policy. If you do not agree with a change, you may withdraw from your program and close your account before it takes effect.

For privacy questions, California privacy requests, security concerns, or anything else about how we handle your information, contact:

Mailing address: RAW Recovery LLC, PO Box 2157, 24001 Calle de la Magdalena, Laguna Hills, CA 92637

Response time: We acknowledge privacy requests within 5 business days and respond fully within 45 days. For security concerns, put "URGENT — SECURITY" in your email subject line so we can prioritize it.

See also the Member Portal Terms & Conditions.