Avodah Dynamics California Consumer Privacy Act (CCPA) Privacy Policy

Effective Date: October 26, 2025

This California Consumer Privacy Act Privacy Policy ("CCPA Policy") applies to California residents and supplements the information contained in Avodah Dynamics' Privacy Policy. This CCPA Policy describes how we collect, use, disclose, and sell personal information of California consumers and the rights that California consumers have with respect to their personal information.

1. Personal Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").

Categories of Personal Information Collected:

A. Identifiers

• Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers

B. Personal Information Categories Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

• Name, signature, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other financial information

C. Protected Classification Characteristics Under California or Federal Law

• Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information

D. Commercial Information

• Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

E. Biometric Information

• Physiological, biological, or behavioral characteristics that can be used alone or in combination with each other to establish individual identity

F. Internet or Other Similar Network Activity

• Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement

G. Geolocation Data

• Physical location or movements

H. Sensory Data

• Audio, electronic, visual, thermal, olfactory, or similar information

I. Professional or Employment-Related Information

• Current or past job history or performance evaluations

J. Non-Public Education Information

• Education records directly related to a student maintained by an educational institution or party acting on its behalf

K. Inferences Drawn from Other Personal Information

• Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

2. Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you when you:
• • Register for coaching services or consultations
  • Purchase products or services from our website
  • Sign up for newsletters or community events
  • Complete surveys or feedback forms
  • Contact us through our website, email, or phone
• Indirectly from you through:
• • Your device when you visit our website or use our services
  • Cookies and similar tracking technologies
  • Social media platforms when you interact with our content
• Third parties including:
• • Business partners and service providers
  • Payment processors
  • Marketing and analytics providers
  • Social media platforms

3. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information
• To provide coaching, consulting, and personal development services
• To process transactions and manage customer accounts
• To provide customer support and respond to inquiries
• To personalize your experience and improve our services
• To send marketing communications and promotional materials
• To conduct research and analytics
• To detect security incidents and protect against fraudulent activity
• To debug and repair functionality issues
• To comply with legal obligations
• To evaluate or conduct a merger, divestiture, restructuring, or other transaction

4. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out. We do not sell personal information of consumers we know are under 16 years of age.

Categories of Third Parties With Whom We Share Personal Information:

• Service providers and vendors
• Payment processors
• Marketing and advertising partners
• Analytics providers
• Professional advisors (attorneys, accountants, consultants)
• Government agencies and law enforcement (when required by law)

5. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information:

Right to Know

You have the right to request that we disclose information about our collection and use of your personal information over the past 12 months, including:

• The categories of personal information we collected
• The categories of sources from which we collected personal information
• Our business or commercial purpose for collecting personal information
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we collected about you

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

Right to Opt-Out of Sale

You have the right to opt-out of the sale of your personal information. We do not sell personal information in the traditional sense but may share information with third parties for advertising purposes.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights, including by:

• Denying you goods or services
• Charging you different prices or rates for goods or services
• Providing you a different level or quality of goods or services
• Suggesting that you may receive a different price or rate or different level of quality

6. How to Exercise Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by either:

• Email: legal@avodahdynamics.com
• Phone: [Phone Number]
• Online Form: Available at https://avodahdynamics.com/privacy-request

Verification Process

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timeline

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Authorized Agents

You may designate an authorized agent to make a request on your behalf. We may require verification of both your identity and your agent's authority to act on your behalf.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Contact Information

If you have any questions or concerns about this CCPA Policy or our privacy practices, please contact us at:

Avodah Dynamics
Email: legal@avodahdynamics.com
Website: https://avodahdynamics.com

9. Changes to This CCPA Policy

We reserve the right to amend this CCPA Policy at our discretion and at any time. When we make changes, we will post the updated policy on our website and update the "Effective Date" at the top of this policy.

10. Additional Information

For more information about our privacy practices, please review our general Privacy Policy available at https://avodahdynamics.com/privacy-policy.

This CCPA Policy is designed to comply with the California Consumer Privacy Act and its implementing regulations. If you are not a California resident, this policy may not apply to you.