PRIVACY POLICY

Last updated November 29, 2025

This Privacy Notice for Empower Counseling LLC (doing business as Empower Counseling LLC.) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at kely@empowercounselingllc.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by visiting kely@empowercounselingllc.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. WELLNESS INFORMATION DISCLOSURE
  14. DO WE MAKE UPDATES TO THIS NOTICE?
  15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Apple App Store and Google Play Store. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy.

All subscription payments for Compass are processed securely by Apple App Store (iOS) or Google Play Store (Android). We do not collect, process, or store any payment card information. Users should refer to Apple's or Google's privacy policies for information about how payment data is handled.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider.

Application Data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. The information we collect includes:

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (express consent) or in situations where your permission can be inferred (implied consent).

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf. The categories of third parties we may share personal information with are as follows:

We also may need to share your personal information in the following situations:

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details, like your Facebook or X logins. Where you choose to do this, we will receive certain profile information about you from the social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information, including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user's account.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, to request rectification or erasure, to restrict the processing of your personal information, and to data portability.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

If you have questions or comments about your privacy rights, you may email us at kely@empowercounselingllc.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific rights regarding your personal information.

Categories of Personal Information We Collect

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic dataNO
D. Commercial informationTransaction information, purchase history, financial details, and payment informationNO
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsYES
G. Geolocation dataDevice locationNO
H. Audio, electronic, sensory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNO
I. Professional or employment-related informationBusiness contact details in order to provide our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNO
J. Education InformationStudent records and directory informationNO
K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsNO
L. Sensitive personal InformationAccount login information, health data and religious or philosophical beliefsYES

Your Rights

You have rights under certain US state data protection laws, including:

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting kely@empowercounselingllc.com, by emailing us at kely@empowercounselingllc.com, or by visiting https://compassapp.courageously.com/.

13. WELLNESS INFORMATION DISCLOSURE

WELLNESS INFORMATION DISCLAIMER: Compass is a personal wellness and life management application designed to help users organize their time, track life satisfaction, and work toward personal goals. Compass is NOT a medical device, therapy service, or healthcare provider. The information and features provided in this app, including domain check-ins, mindfulness exercises, and wellness tracking, are for general informational and self-improvement purposes only. Compass does NOT provide: Medical advice or diagnosis; Mental health treatment or therapy; Crisis intervention services; Professional counseling. The content in this app is not intended to replace professional medical advice, diagnosis, or treatment. Always seek the advice of a qualified healthcare provider with any questions you may have regarding a medical or mental health condition. If you are experiencing a mental health emergency, please contact emergency services (911), the National Suicide Prevention Lifeline (988), or go to your nearest emergency room. By using Compass, you acknowledge that this app is a self-help tool and not a substitute for professional care.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at kely@empowercounselingllc.com or contact us by post at:

Empower Counseling LLC
#4 Office Park Circle
Suite 306
Mountain Brook, AL 35223
United States

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: kely@empowercounselingllc.com.