PRIVACY POLICY

Effective Date: October 19, 2025

Sacler Solutions, LLC, doing business as CLM Unlocked (“Company,” “we,” “us,” or “our”), respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit clmunlocked.com, enroll in our programs, or participate in our community (collectively, the “Services”). By using our Services, you agree to this Privacy Policy. If you do not agree, please discontinue use of our website and programs.

  1. Information We Collect

We collect personal information that you voluntarily provide when you register, purchase, or participate in our programs, including:
• Name and contact information (email address, phone number, mailing address)
• Billing and payment information (processed securely via Stripe)
• LinkedIn profile URL, company name, and job title
• Account login credentials (for Kajabi and community platforms)
• Information provided during coaching sessions or community participation
• Technical data such as IP address, browser type, and usage analytics (via Google Analytics or similar tools)
We may also collect information automatically through cookies and similar technologies.

  1. How We Collect Information

We collect information through:
• Checkout and registration forms on Kajabi or successor platforms
• Payment processors (Stripe, credit card providers)
• Scheduling and communication tools (Calendly, Zoom, Microsoft Office 365)
• Analytics and tracking tools (Google Analytics, Kajabi analytics)
• Optional community or forum participation (Kajabi or Mighty Networks)
• Email communications and support inquiries

  1. How We Use Information

We use your information to:
• Process payments and deliver purchased content
• Manage accounts and provide customer support
• Communicate about your enrollment, updates, and related products or services
• Provide access to live sessions, coaching, and community spaces
• Improve our content, user experience, and offerings
• Comply with legal, tax, and regulatory obligations
• Send marketing communications (you may opt out at any time)

  1. Legal Bases for Processing (for International Users)

For users located in the European Economic Area or other regions with similar regulations, we process your data under the following legal bases:
• Performance of a contract (to provide purchased programs)
• Compliance with legal obligations
• Legitimate business interests (to operate and improve our Services)
• Your consent (for marketing communications and optional cookies)

  1. How We Share Information

We do not sell your personal data. We share information only as necessary with trusted third-party processors who support our operations, including:
• Kajabi (website, checkout, and course hosting)
• Stripe (payment processing)
• Zoom and Calendly (meeting and scheduling tools)
• Microsoft Office (email and document management)
• Google Analytics (site performance and traffic analysis)
• Mighty Networks (potential future community hosting)
Each processor is bound by confidentiality and data protection obligations consistent with this Policy.

  1. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to improve performance and analyze usage. You can choose to disable cookies in your browser settings, but some features may not function properly. Where required by law, you will be notified of cookie use and asked for consent.

  1. Email and Marketing Communications

We may send you administrative or transactional emails related to your purchase, as well as optional newsletters or promotional materials. You can unsubscribe from promotional emails at any time by clicking “unsubscribe” in the email or contacting us at [email protected].

  1. Community and Forum Use

If you post content in community forums or group discussions, other participants may view your information. Please use discretion when sharing personal details. We are not responsible for how other users use information you voluntarily share.

  1. Testimonials and Media Use

If you provide a testimonial, comment, image, or other submission to CLM Unlocked, you grant us permission to use that material, including your name, likeness, or statements, for promotional or educational purposes in accordance with our Terms of Purchase and Website Terms and Conditions. We will use your information responsibly and honor any reasonable request to remove identifying details.

  1. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, including maintaining your account, complying with legal obligations, resolving disputes, and enforcing our agreements. You may request deletion of your data as described in Section 13 below.

  1. Data Storage and Security

Your data is stored primarily in the United States and protected using reasonable administrative, technical, and physical safeguards. While we take steps to protect your information, no system can guarantee absolute security. Payments are processed securely by Stripe using encryption and tokenization.

  1. International Data Transfers

If you access our Services from outside the United States, your information may be transferred to and processed in the U.S. or other jurisdictions. We implement appropriate safeguards to ensure that international data transfers comply with applicable laws, including standard contractual clauses where required.

  1. Your Rights and Choices

Depending on your location, you may have rights to:
• Access and receive a copy of your personal data
• Request correction or deletion of your data
• Withdraw consent for marketing communications
• Object to or restrict processing of your data
• Request data portability
To exercise your rights, contact [email protected]. We will respond within 30 days where legally required.

  1. California Privacy Rights (CCPA)

If you are a California resident, you have the right to request information about the personal data we collect, use, and disclose, and to request deletion of your data. We do not sell personal information. You can exercise your rights by contacting us at [email protected].

  1. Children's Privacy

Our Services are intended for adults aged 18 and older. We do not knowingly collect information from children. If you believe a child has provided us with personal data, please contact us so we can delete it.

  1. Links to Other Websites

Our website may contain links to third-party sites. We are not responsible for the content or privacy practices of those sites. Please review the privacy policies of any linked websites before providing personal information.

  1. Social Media and Third-Party Analytics

Our website and Services may use analytics and tracking tools provided by third parties, including Meta (Facebook and Instagram) and LinkedIn. These tools help us understand engagement and the effectiveness of our communications and advertisements. These third parties may use cookies, pixels, or similar technologies to collect information about your activity across websites. For more information about how these platforms process your data, please review their respective privacy policies.

  1. Changes to This Policy

We may update this Privacy Policy periodically. The “Effective Date” above reflects the latest revision. We encourage you to review this page regularly. Continued use of our Services after an update constitutes acceptance of the revised Policy.

  1. Contact Information

For questions or requests regarding this Privacy Policy, please contact:

Sacler Solutions, LLC d/b/a CLM Unlocked
Email: [email protected]
Website: clmunlocked.com