Privacy Policy

PRIVACY POLICY

Effective Date: [May 18, 2026]

Introduction
Who We Are
Information We Collect
How We Collect Your Information
How We Use Your Information
Sharing Your Information
Third-Party Service Providers
Session Recording
Email Marketing
Cookies
Data Retention
Data Security
Your Rights
GDPR — Rights of EEA and UK Residents
California Privacy Rights (CCPA)
Children's Privacy
Third-Party Links
Sensitive Information
Changes to This Policy
Contact Us

1. INTRODUCTION

This Privacy Policy explains how THE LIVING MA LLC ("we," "us," or "our") collects, uses, stores, and protects your personal information when you visit or use our website at www.avaorah.com (the "Site"), purchase or enrol in any of our services or programs, subscribe to our email list, or interact with us in any way through our digital platforms.

Please read this policy carefully. By using the Site or engaging with our services, you confirm that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, please discontinue use of the Site.

We serve a global audience and are committed to handling your personal data with care, transparency, and respect — wherever in the world you are based.

2. WHO WE ARE

This Site and its associated services are operated by THE LIVING MA LLC, based in Vermont, United States.

Contact: [email protected]

Our mailing address will be updated on this page once our registered business address is confirmed. In the meantime, all privacy-related enquiries can be directed to the email address above.

3. INFORMATION WE COLLECT

We collect two types of information: Personal Data and Non-Personal Data.

Personal Data is information that identifies you or could reasonably be used to identify you. Depending on how you interact with us, this may include:

Full name
Email address
Phone number
Billing and mailing address
Payment information (processed securely through Stripe or PayPal — we do not store your full payment details directly)
Date of birth (where voluntarily provided)
Information you share in the course of participating in our programs, sessions, or community spaces
Any other personal information you choose to share with us directly

Non-Personal Data is information that does not directly identify you, including:

Browser type and version
Device type and operating system
IP address and approximate geolocation
Pages visited and time spent on the Site
Referring website addresses
Session and usage data

4. HOW WE COLLECT YOUR INFORMATION

We collect your information in the following ways:

When you purchase a program, course, container, or subscription through our Site
When you register for or attend a live event, group container, or channeled transmission
When you book a session or appointment through our scheduling system
When you subscribe to our email list, whether through a freebie opt-in or a direct newsletter subscription invitation
When you submit a contact form, application, or enquiry on the Site
When you participate in any community features, comment sections, or interactive areas on the Site
When you interact with us via social media platforms
Automatically, through cookies and similar tracking technologies when you visit the Site (see Section 10)

5. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

To deliver the services, programs, courses, and content you have purchased or enrolled in
To process payments and manage your account
To send you transactional communications, including purchase confirmations, receipts, and programme-related updates
To send you our weekly newsletter and any other email communications you have opted into
To respond to your enquiries, applications, and support requests
To schedule and facilitate sessions and appointments
To provide access to recorded content where applicable
To improve the Site and our offerings based on how users interact with them
To comply with our legal obligations
To protect the security and integrity of our Site and services
To enforce our Terms and Conditions

We will not use your personal data for purposes incompatible with those stated above without your knowledge and, where required, your consent.

6. SHARING YOUR INFORMATION

We do not sell, rent, or trade your personal data to any third party for their own marketing purposes. Full stop.

We may share your information in the following limited circumstances:

With service providers who assist us in operating our business (see Section 7)
With legal or regulatory authorities where we are required to do so by law, court order, or regulatory obligation
In the event of a business transfer — if our business is acquired, merged, or transferred, your data may be transferred as part of that transaction. We will notify you in advance where possible and require any acquiring party to honour the terms of this Privacy Policy
With your explicit consent for any purpose not covered above

7. THIRD-PARTY SERVICE PROVIDERS

We work with the following third-party platforms and service providers who may access or process your personal data in the course of providing services to us. Each operates under its own privacy policy, which we encourage you to review.

Kajabi Our primary business platform, used for our website, course and membership delivery, email marketing, scheduling, and CRM. Kajabi may collect and process data about your account activity, purchases, and engagement with our content. Privacy Policy: kajabi.com/privacy

Stripe Our primary payment processor, integrated through Kajabi. Stripe handles payment card data securely and is PCI-DSS compliant. We do not store your full card details on our systems. Privacy Policy: stripe.com/privacy

PayPal An alternative payment option available at checkout. If you pay via PayPal, your transaction is governed by PayPal's privacy policy. Privacy Policy: paypal.com/privacy

Zoom We use Zoom to conduct live sessions, group calls, and channeled transmissions. Zoom may collect technical and usage data in connection with your participation. Please see Section 8 for our session recording policy. Privacy Policy: zoom.us/privacy

Google Analytics We may use Google Analytics to understand how visitors use our Site. This tool collects non-personal usage data via cookies. You can opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout. Privacy Policy: policies.google.com/privacy

If we add new service providers in the future that materially affect how your data is handled, we will update this section and revise the effective date of this policy.

8. SESSION RECORDING

Live sessions conducted via Zoom — including 1:1 mentorship sessions, group container calls, and DiYeena LIVE transmissions — may be recorded.

By participating in any live session, you acknowledge and consent to the possibility that the session may be recorded. Where recordings are made:

Participants will be notified at the start of each session
Recordings are used for the purpose of providing replay access to participants and for our internal records
1:1 session recordings are shared privately with the relevant client only
Group container and DiYeena LIVE recordings are shared with enrolled participants or subscribers as applicable
Recordings are not shared publicly or used for marketing purposes without explicit consent

If you have concerns about being recorded in any session, please contact us at [email protected] prior to attending.

9. EMAIL MARKETING

When you subscribe to our email list — whether through a freebie opt-in, a direct newsletter subscription, or any other invitation on the Site — you are consenting to receive our weekly newsletter and occasional communications about our offerings, programs, and events.

We will only email you with content relevant to what you signed up for
Every email we send includes an unsubscribe link. You may opt out at any time
Unsubscribing from marketing emails will not affect transactional communications related to purchases you have made
We use Kajabi to manage our email list and communications
We do not add people to our email list without their explicit opt-in

10. COOKIES

Cookies are small text files stored on your device when you visit a website. We use cookies to improve your experience on the Site and to understand how it is being used.

Types of cookies we use:

Session Cookies — temporary cookies that expire when you close your browser. Used to maintain your login state and manage your session on the Site.

Persistent Cookies — stored on your device until they expire or are deleted. Used for authentication, language preferences, and remembering your settings between visits.

Functionality Cookies — allow us to remember choices you have made to personalise your experience.

Performance Cookies — collect anonymous information about how visitors use the Site, such as which pages are visited most often. This information helps us improve the Site.

Third-Party Cookies — our service providers, including Kajabi and Google Analytics, may set their own cookies when you use the Site. These are governed by the respective providers' privacy policies.

Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Site. For more information on managing cookies, visit allaboutcookies.org.

11. DATA RETENTION

We retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specifically:

Account and purchase data is retained for a minimum of seven (7) years for tax and accounting purposes
Email marketing data is retained for as long as you remain subscribed, plus a reasonable period thereafter for record-keeping
Session and programme records are retained for the duration of your programme plus up to three (3) years following completion
Session recordings are retained for the duration of the relevant programme or subscription period, unless you request earlier deletion
Enquiry and contact data is retained for up to two (2) years from the date of last contact

When data is no longer needed, we will delete or anonymise it in a secure manner.

12. DATA SECURITY

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, alteration, or disclosure.

These measures include:

HTTPS encryption across the Site
Secure, PCI-DSS compliant payment processing through Stripe and PayPal
Password-protected access to internal systems
Use of reputable, security-conscious third-party platforms

However, no method of transmission over the internet or electronic storage is completely secure. While we do everything reasonably within our power to protect your data, we cannot guarantee absolute security. If you believe your data has been compromised, please contact us immediately at [email protected].

In the event of a data breach that affects your rights and freedoms, we will notify you and any relevant regulatory authorities as required by applicable law.

13. YOUR RIGHTS

Regardless of where you are based, you have the following general rights regarding your personal data:

Right to access — you may request a copy of the personal data we hold about you
Right to correction — you may request that we correct any inaccurate or incomplete data
Right to deletion — you may request that we delete your personal data, subject to any legal retention obligations
Right to withdraw consent — where we process your data based on consent, you may withdraw that consent at any time
Right to object — you may object to our processing of your data in certain circumstances
Right to data portability — you may request that we provide your data in a structured, commonly used format

To exercise any of these rights, please contact us at [email protected]. We will respond within a reasonable timeframe and in accordance with applicable law.

14. GDPR — RIGHTS OF EEA AND UK RESIDENTS

If you are based in the European Economic Area (EEA) or the United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR applies to our processing of your personal data. This section sets out additional information relevant to you.

Lawful Basis for Processing

We process your personal data on the following lawful bases:

Contract — where processing is necessary to deliver a service you have purchased or enrolled in
Legitimate interests — where processing is necessary for our legitimate business interests, such as improving our services, maintaining security, and communicating with you about relevant offerings, provided those interests are not overridden by your rights
Consent — where you have given explicit consent, such as subscribing to our email list
Legal obligation — where processing is required to comply with a legal or regulatory requirement

Your Additional Rights Under GDPR

In addition to the rights set out in Section 13, you have the right to:

Restrict processing — request that we limit how we use your data in certain circumstances
Lodge a complaint — if you believe we have handled your data unlawfully, you have the right to lodge a complaint with your local data protection authority. In the UK this is the Information Commissioner's Office (ico.org.uk). In the EU, contact your national supervisory authority.

International Data Transfers

Our business is based in the United States. When you provide us with personal data, it may be transferred to and processed in the United States. We take steps to ensure that any such transfers are carried out in accordance with applicable data protection law, including by working with service providers who maintain appropriate safeguards.

15. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you specific rights regarding your personal information.

You have the right to:

Know what personal information we collect, use, disclose, and sell
Request deletion of your personal information, subject to certain exceptions
Opt out of the sale of your personal information — we do not sell your personal information
Non-discrimination for exercising your CCPA rights

To exercise your California privacy rights, contact us at [email protected].

Additionally, under California Civil Code Section 1798.83, California residents may request information about our disclosure of personal information to third parties for direct marketing purposes. We do not share your personal information with third parties for their direct marketing use.

California residents under the age of 18 who are registered users may request removal of content they have publicly posted. Please contact us at [email protected] to make such a request.

California Do Not Track Disclosure

We respond to Do Not Track signals from your browser. Some third-party services we use may track browsing activity for their own purposes. Please refer to the privacy policies of those services for more information.

16. CHILDREN'S PRIVACY

Our Site and services are not directed to children under the age of 13 in the United States or under the age of 16 in the European Union. We do not knowingly collect personal data from children under these ages.

If we become aware that we have inadvertently collected personal data from a child under the applicable age threshold without verifiable parental consent, we will take immediate steps to delete that information. If you believe we may have collected data from a child, please contact us at [email protected].

17. THIRD-PARTY LINKS

Our Site may contain links to third-party websites. This Privacy Policy applies only to our Site and services. We are not responsible for the privacy practices of any third-party website and encourage you to review the privacy policy of any site you visit via a link from our Site.

18. SENSITIVE INFORMATION

The nature of our work means that you may, in the course of participating in our programs or sessions, voluntarily share sensitive personal information — including details about your emotional wellbeing, personal history, spiritual experiences, or other private matters.

Any such information shared in the context of our services is treated with the utmost care and confidentiality. It is used solely for the purpose of delivering the service you have engaged with and is never shared with third parties except where required by law.

We encourage you to share only what you are comfortable sharing and to contact us at [email protected] if you have any concerns about how your information is handled.

19. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal obligations. When we make material changes, we will update the Effective Date at the top of this page and, where appropriate, notify you by email.

Your continued use of the Site following any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.

20. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

[email protected]

Our registered business address will be added to this page once our LLC formation is complete.

This Privacy Policy was last reviewed and updated on [May 18, 2026].