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Privacy Policy

[LEGAL ENTITY NAME], LLC d/b/a Hartwell ("Hartwell," "we," "us," or "our"), an Ohio limited liability company.

Websites: myhartwell.com · hartwell.care · joinhartwell.com · go.myhartwell.com

Effective date: January 1, 2026 · Last updated: May 27, 2026

1. General Information

This Privacy Policy describes how [LEGAL ENTITY NAME], LLC d/b/a Hartwell ("Hartwell," "we," "our," or "the Company") collects, uses, shares, and protects the personal information of users ("you" or "your") of our websites, myhartwell.com, hartwell.care, joinhartwell.com, and go.myhartwell.com, our applications, programs, and related services (collectively, the "Services"). By using the Services, you accept the practices described here.

2. Information We Collect

2.1 Information you provide directly

  • Full name, email address, phone number, and mailing address;
  • Account login and profile information;
  • Payment information (processed by our secure third-party payment processor; we do not store full card numbers);
  • Information you submit through qualifier forms, applications, intake questionnaires, and onboarding (which may include business goals, intended state of operation, and self-reported access to capital);
  • Identity and verification information where required for a program;
  • Communications you send us, including support requests and survey responses.

2.2 Information collected automatically

  • IP address and approximate geographic location;
  • Device type, operating system, and browser information;
  • Pages visited, referral source, and time spent;
  • Cookies, pixels, and similar technologies (including advertising pixels such as the Meta/Facebook pixel and analytics tags);
  • Activity and interaction logs within our platforms and educational content.

2.3 Information from third parties

  • Advertising and lead-generation platforms (for example, Meta/Facebook lead ads and similar ad platforms);
  • Social media information, if you choose to connect or interact via social accounts;
  • Our payment processor and scheduling/booking tools;
  • Analytics and marketing service providers.

2.4 Call, video & recorded interactions

Our sales process and onboarding may include video sales presentations and scheduled calls. With notice and where permitted by law, calls, webinars, and video sessions may be recorded for quality, training, compliance, and dispute-resolution purposes. By participating, you consent to such recording where your consent is required.

3. How We Use Your Information

  • Service delivery: to provide programs, DFY assistance, platform access, onboarding, scheduling, and support; to process enrollments and payments;
  • Communications: to respond to inquiries, deliver program updates, send service and onboarding messages, and, with your consent where required, send marketing communications;
  • Advertising & measurement: to deliver, target, and measure advertising (including on Meta/Facebook and other platforms), to build lookalike/custom audiences, and to improve campaign performance, using cookies and pixels as described below;
  • Improvement: to analyze usage, develop new offerings, conduct research, and optimize the user experience;
  • Legal & security: to comply with legal obligations, enforce our Terms, prevent fraud and abuse, and protect rights and safety.

4. Legal Basis for Processing

Where applicable, we process personal information based on your consent, the performance of our contract with you, our legitimate interests (such as improving and marketing the Services), and compliance with legal obligations.

5. How We Share Information

5.1 No sale of personal information

We do not sell your personal information for money. Note that certain uses of advertising cookies and pixels may be considered "sharing" or "sale" for cross-context behavioral advertising under some state privacy laws; see Section 8 for your opt-out rights.

5.2 Authorized sharing

  • Service providers: payment processors, scheduling/booking tools, hosting and cloud providers, email/SMS providers, analytics, and marketing platforms that process data on our behalf;
  • Advertising platforms: ad networks such as Meta/Facebook for campaign delivery and measurement;
  • Professional and program partners: instructors, coaches, or partners directly involved in delivering a program you purchase;
  • Legal authorities: when required by law, subpoena, or legal process, or to protect our rights, users, or the public;
  • Business transfers: in connection with a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction.

Each third party operates under its own privacy practices. We are not responsible for the independent practices of third parties once data is transmitted to them; we encourage you to review their policies (for example, those of our payment processor, scheduling tool, and advertising platforms).

6. Data Security

We implement reasonable technical and organizational measures, including encryption in transit and at rest, access controls, monitoring, staff training, and periodic reviews. However, no system is completely secure, and we cannot guarantee absolute security against unauthorized access, loss, or alteration.

7. Data Retention

  • We retain personal information for the duration of your account, membership, or program relationship;
  • for periods required by law (including tax and financial record-keeping requirements);
  • for a reasonable period thereafter for legitimate business, dispute-resolution, and compliance purposes;
  • after which it is securely deleted or de-identified. Specific retention periods may vary by data type and legal requirement.

8. Your Privacy Rights

Depending on your jurisdiction (including under the California Consumer Privacy Act/CPRA and other U.S. state privacy laws), you may have the right to:

  • Access a copy of the personal information we hold about you;
  • Correct inaccurate or incomplete information;
  • Request deletion of your information;
  • Obtain your information in a portable format;
  • Restrict or object to certain processing;
  • Withdraw consent and opt out of marketing communications;
  • Opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising, and limit certain ad targeting.

To exercise these rights, contact us at support@myhartwell.com. We will not discriminate against you for exercising your rights. You may also control cookies through your browser settings and through ad-platform opt-out mechanisms.

9. Cookies & Similar Technologies

We use cookies, pixels, and similar technologies for essential site functionality, performance and analytics, content personalization, and marketing/advertising (including conversion tracking and audience building on platforms such as Meta/Facebook). You can manage cookies through your browser settings, any on-site preference tool we provide, and third-party opt-out mechanisms.

10. Minors

The Services are intended for individuals 18 years of age and older. We do not knowingly collect information from minors. If we learn we have collected information from a minor, we will promptly delete it.

11. International Users & Transfers

The Services are operated in the United States. If you access them from outside the U.S., your information will be transferred to and processed in the U.S., where data-protection laws may differ from those in your country. We apply appropriate safeguards for such transfers.

12. Third-Party Links & Services

Our Services may link to or integrate with third-party websites and tools (such as payment, scheduling, hosting, and advertising providers). We are not responsible for the privacy practices or content of those third parties, each of which maintains its own policies.

13. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated through a notice on our websites, by email to registered users, or via in-app notification, and the "Last updated" date will be revised. Continued use of the Services after changes take effect constitutes acceptance of the updated policy.

14. Regulatory Compliance

This Policy is intended to align with applicable laws, including the California Consumer Privacy Act (CCPA/CPRA), other applicable U.S. state privacy laws, Ohio law, and applicable federal regulations.

15. Contact

For questions about this Privacy Policy or your privacy rights:

[LEGAL ENTITY NAME], LLC d/b/a Hartwell

Attn: Privacy Officer

Email: support@myhartwell.com

This Privacy Policy is an integral part of, and incorporated into, our Terms & Conditions. We recommend reviewing both documents together.

Read the Terms & Conditions →