PRIVACY POLICY

Last Updated: June 6, 2025

This Privacy Policy describes how Stracent LLC, doing business as Owllum ("Company," "we," "us," or "our"), collects, uses, maintains, and discloses information provided by users (“you” or “User”) of the www.owllum.com website (the “Website”). It applies to all personal information collected through our Website or in connection with our coaching, consulting, and educational services.

By accessing or using the Website, you agree to the terms of this Privacy Policy. If you do not agree with our practices, you must not use this Website.

1. Collection of Personal Information

We collect personal information that you voluntarily provide when interacting with the Website. This includes, but is not limited to, information provided through contact forms, consultation bookings, newsletter sign-ups, assessments, course registrations, surveys, or direct communications. Such information may include your full name, email address, telephone number, billing address, and any details submitted via intake forms or questionnaires.

We also collect information automatically when you visit the Website. This may include your IP address, browser type, device identifiers, geographic location, pages visited, and time spent on each page. These data are collected through cookies, log files, tracking pixels, and analytics tools to help us analyze usage and improve the Website’s performance.

We do not collect or process sensitive personal information (e.g., race, religion, health data) unless specifically required for a particular service and explicitly consented to by you.

2. Use of Collected Information

We use the information we collect for the legitimate and lawful operation of our business, including but not limited to the following purposes: (a) to provide coaching, consulting, educational content, or related services as requested by you; (b) to manage and maintain our client relationships, including processing transactions and communicating with you about your account or engagement; (c) to administer intake forms, assessments, and feedback tools used in the delivery of services; (d) to send newsletters, marketing emails, course updates, and other promotional materials to which you have subscribed or opted in; (e) to respond to inquiries or support requests; (f) to comply with legal obligations or enforce our Terms of Use; and (g) to improve the Website’s performance and user experience through analytics and aggregated usage data.

Your information will only be used for the purposes for which it was originally collected unless you have been notified of and consented to any other use, or such use is otherwise authorized or required by law.

3. Email Communications and Email Policy

When you provide your email address through the Website—whether to inquire about services, subscribe to the newsletter, complete an intake form, or purchase a program—you consent to receive communications from Owllum via email. These may include service-related messages (e.g., booking confirmations, intake instructions, assessment results), administrative notices, newsletters, course updates, and promotional or educational content.

You may withdraw your consent to receive promotional communications at any time by clicking the “unsubscribe” link found at the bottom of our marketing emails. Doing so will not prevent us from continuing to send service-related messages that are necessary to fulfill our contractual or legal obligations to you.

We are committed to complying with all applicable laws governing email communications, including the United States CAN-SPAM Act, the General Data Protection Regulation (GDPR) applicable to European Union residents, and Canada’s Anti-Spam Legislation (CASL). We do not send unsolicited promotional emails, and we do not share your email address with unaffiliated third parties for marketing purposes.

We utilize Squarespace Email Campaigns to manage and distribute our emails. Squarespace acts as a data processor on our behalf and is contractually obligated to handle your data in accordance with privacy and data protection standards. By engaging with our emails, certain interaction data (such as open rates or link clicks) may be collected for the purpose of optimizing communication and measuring engagement.

If you wish to update your preferences, exercise your data rights, or report a concern related to email communications, you may contact us at info@owllum.com.

4. Lawful Bases for Processing (Where Applicable)

If you are located in a jurisdiction that requires a lawful basis for processing (such as under the General Data Protection Regulation “GDPR”), we process your personal data based on one or more of the following grounds: (a) your consent, which may be withdrawn at any time; (b) the performance of a contract or the need to take steps at your request prior to entering into a contract; (c) compliance with a legal obligation; or (d) our legitimate interests in operating and developing our business, providing and improving our services, or preventing fraud or misuse of our Website.

5. Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purpose(s) for which it was collected, including satisfying any legal, regulatory, accounting, or contractual requirements. The duration of retention may vary depending on the type of data and the applicable law. You may request the deletion of your personal data at any time, subject to limitations imposed by legal or legitimate business considerations.

6. Disclosure of Information to Third Parties

We do not sell, lease, or trade your personal information to third parties for monetary consideration. However, we may disclose your information to trusted third-party service providers who assist us in operating our business and delivering services to you, such as website hosting, email delivery, scheduling software, marketing platforms, and payment processing providers. These third parties are bound by confidentiality agreements and are only authorized to access your data to the extent necessary to perform their designated functions.

In addition, we may disclose personal information if required to do so by law or in response to valid legal requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your information in connection with a business transaction such as a merger, acquisition, or sale of assets, in which case you will be notified of any change in ownership or use of your personal information.

7. Data Security

We adopt commercially reasonable physical, technical, and administrative safeguards to protect your personal information against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, while we strive to use best practices to protect your personal data, we cannot guarantee its absolute security. You acknowledge and accept this risk when submitting personal data through the Website.

8. Cookies and Tracking Technologies

Our Website uses cookies and other tracking technologies to improve functionality, enhance user experience, and analyze Website usage. A cookie is a small file placed on your device that enables features such as session management, login authentication, and traffic monitoring. By using this Website, you consent to our use of such technologies. You may adjust your browser settings to decline cookies; however, doing so may impair access to certain features or functionalities of the Website.

9. International Transfers

If you are accessing the Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other jurisdictions where we or our service providers are located. By using the Website and submitting your personal data, you consent to such transfer, storage, and processing, including to jurisdictions that may not offer the same level of data protection as your country of residence.

10. Your Rights and Choices

Subject to applicable law, you may have certain rights with respect to your personal information, including the right to access, correct, amend, delete, restrict, or object to the processing of your data. You may also have the right to receive a copy of your data in a structured, commonly used, and machine-readable format. If you wish to exercise any of these rights, please contact us at the email address listed in Section 13.

You may also unsubscribe from marketing communications at any time by clicking the “unsubscribe” link contained in any promotional emails you receive. Please note that unsubscribing from marketing emails does not affect our ability to communicate with you regarding service-related matters or transactions.

11. Third-Party Links

The Website may contain links to third-party websites or content not controlled by the Company. We are not responsible for the privacy practices, data collection policies, or content of such third-party websites. Users are encouraged to read the privacy policies of any third-party site they visit before submitting personal information to that site.

12. Children’s Privacy

The Website and its services are not directed to individuals under the age of 13 (or the equivalent minimum age in relevant jurisdictions). We do not knowingly collect or solicit personal information from children. If we learn that we have inadvertently collected personal information from a minor, we will take prompt steps to delete such data from our records.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact us using the following contact information:

info@owllum.com

(929) 428-9657

Stracent LLC dba Owllum

418 Broadway #4417

Albany, NY 12207, USA

We take your privacy seriously, and we are committed to addressing any concerns or inquiries you may have promptly and responsibly.