Avodah Dynamics APPI Privacy Policy

Effective Date: October 26, 2025
Last Updated: October 26, 2025

1. Introduction

Avodah Dynamics ("we," "our," or "us") is committed to protecting your personal information in accordance with Japan's Act on Protection of Personal Information (APPI) and other applicable privacy laws. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website at https://avodahdynamics.com or use our services.

2. Contact Information

Data Controller:
Avodah Dynamics
6809 Main Street unit 93
Cincinnati, Ohio 45244, United States

Contact Details:
Email: info@avodahdynamics.com
Phone: +1 518-864-3967
Website: https://avodahdynamics.com

For privacy-related inquiries, please contact us using the information above.

3. Personal Information We Collect

3.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, mailing address
• Account Information: Username, password, profile information
• Payment Information: Credit card details, billing address, transaction history
• Communication Records: Messages, feedback, support inquiries, survey responses
• Program Participation: Coaching session notes, goal tracking, progress assessments
• Event Registration: Workshop attendance, seminar participation, community event details

3.2 Automatically Collected Information

• Technical Data: IP address, browser type, device information, operating system
• Usage Data: Pages visited, time spent on site, click patterns, referral sources
• Cookies and Tracking: Session cookies, preference settings, analytics data

3.3 Third-Party Sources

• Social Media: Information from social media platforms when you interact with our content
• Business Partners: Data from authorized partners and service providers
• Public Sources: Publicly available information relevant to our services

4. Purposes of Use

We use your personal information for the following purposes:

4.1 Service Provision

• Delivering coaching and consulting services
• Processing payments and managing accounts
• Providing customer support and responding to inquiries
• Facilitating community engagement and events

4.2 Business Operations

• Improving our services and website functionality
• Conducting market research and analytics
• Managing business relationships and partnerships
• Ensuring security and preventing fraud

4.3 Communication and Marketing

• Sending service updates and important notices
• Providing marketing communications (with consent)
• Sharing inspirational content and educational materials
• Announcing events and program opportunities

4.4 Legal Compliance

• Fulfilling legal obligations and regulatory requirements
• Protecting our rights and interests
• Responding to legal process and governmental requests

5. Legal Basis for Processing

Under APPI and applicable laws, we process your personal information based on:

• Consent: When you have given explicit consent for specific purposes
• Contract Performance: To fulfill our service agreements with you
• Legitimate Interests: For business operations that do not override your privacy rights
• Legal Obligations: To comply with applicable laws and regulations

6. Sharing of Personal Information

6.1 Service Providers

We may share your information with trusted third-party service providers who assist us in:

• Payment processing and financial services
• Website hosting and technical support
• Email marketing and communication platforms
• Analytics and performance monitoring
• Customer relationship management

6.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity.

6.3 Legal Requirements

We may disclose your information when required by law, court order, or to protect our rights and the safety of others.

6.4 Consent-Based Sharing

We may share your information with third parties when you have provided explicit consent for such sharing.

7. Cross-Border Data Transfers

Your personal information may be transferred to and processed in countries outside of Japan, including the United States where our primary operations are located. We ensure appropriate safeguards are in place for such transfers through:

• Adequacy decisions by relevant authorities
• Standard contractual clauses
• Binding corporate rules
• Your explicit consent

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication systems
• Regular security assessments and updates
• Employee training on data protection practices
• Incident response procedures

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Account Information: Retained while your account is active and for 7 years after closure
• Transaction Records: Retained for 7 years for accounting and tax purposes
• Communication Records: Retained for 3 years unless longer retention is necessary
• Marketing Data: Retained until you withdraw consent or for 2 years of inactivity

10. Your Rights Under APPI

You have the following rights regarding your personal information:

10.1 Right of Disclosure

You may request disclosure of:

• Purposes of use of your personal information
• Categories of personal information we hold
• Recipients or categories of recipients of your data

10.2 Right of Access

You may request access to your personal information we hold about you.

10.3 Right of Correction

You may request correction of inaccurate or incomplete personal information.

10.4 Right of Deletion

You may request deletion of your personal information in certain circumstances.

10.5 Right to Suspend Use

You may request suspension of use or provision of your personal information in certain situations.

10.6 Exercise of Rights

To exercise your rights, please contact us using the information provided in Section 2. We will respond to your request within 30 days and may require verification of your identity.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. You can control cookie settings through your browser preferences. For detailed information about our use of cookies, please refer to our Cookie Policy.

12. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it promptly.

13. Third-Party Links

Our website may contain links to third-party websites. This Privacy Policy does not apply to such third-party sites, and we are not responsible for their privacy practices.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date.

15. Complaints and Enforcement

If you have concerns about our privacy practices, please contact us first using the information in Section 2. If you are not satisfied with our response, you may file a complaint with:

Personal Information Protection Commission of Japan
Website: https://www.ppc.go.jp/
Phone: +81-3-6457-9849

16. Definitions

• Personal Information: Information relating to a living individual that can identify the specific individual by name, date of birth, or other description
• Sensitive Personal Data: Personal information requiring special care in handling, such as religious beliefs or health information
• Processing: Any operation performed on personal information, including collection, use, storage, and disclosure

Contact Us: If you have any questions about this Privacy Policy, please contact us at info@avodahdynamics.com or +1 518-864-3967.