Privacy Policy

Victero Consulting Services LLC

Last Updated: February 24th, 2025

Website: https://victeroconsulting.com/

1. INTRODUCTION

This Privacy Policy ("Policy") describes how Victero Consulting Services LLC ("Victero Consulting," "Company," "we," "us," or "our"), a limited liability company registered in the State of Texas, USA, collects, uses, stores, shares, and protects your personal information when you visit our website at https://victeroconsulting.com/, use our member portal, or access any of our digital products, services, courses, memberships, coaching programs, communities, or content (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the collection and use of your information as described in this Privacy Policy. This Policy should be read in conjunction with our Terms and Conditions, available at https://portal.victeroconsulting.com/terms-conditions.

If you do not agree to this Privacy Policy, please do not access or use our Services.

2. INFORMATION WE COLLECT

We collect information in several ways depending on how you interact with our Services.

2.1 Information You Provide Directly

When you create an account, make a purchase, enroll in a program, join a membership, subscribe to our newsletter, participate in our community, contact us, or otherwise interact with our Services, we may collect the following personal information:

• Name (first and last)

• Email address

• Company name

• Designation, title, or professional role

• Payment and billing information (processed securely through our third-party payment processors; we do not directly store full credit card numbers)

• Any other information you voluntarily provide through forms, surveys, community posts, coaching sessions, or correspondence with us

2.2 Information Collected Automatically

When you visit our website or use our Services, we may automatically collect certain technical and usage information, including:

• Device information: Device type, operating system, browser type and version, screen resolution, and device identifiers

• Log data: IP address, access dates and times, pages viewed, time spent on pages, clickstream data, referring and exit URLs

• Usage data: Features used, content accessed, courses viewed, downloads, and interactions within the member portal and community

• Location data: General geographic location based on IP address (we do not collect precise geolocation)

2.3 Information Collected Through Cookies and Tracking Technologies

We use cookies, pixels, and similar tracking technologies to collect information about your browsing activity and to improve your experience. These include:

• Essential cookies: Required for the basic functionality of our website and Services (e.g., session management, authentication)

• Analytics cookies: Used to understand how visitors interact with our website, including through Google Analytics and Google Tags

• Advertising and retargeting cookies/pixels: Used to deliver relevant advertising and measure campaign effectiveness, including:

◦ Meta (Facebook) Pixel

◦ LinkedIn Insight Tag (Pixel)

◦ Google Analytics and Google Tags

For more information about cookies and how to manage your preferences, see Section 8 of this Policy.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 Service Delivery and Account Management

• To create and manage your account

• To provide access to purchased courses, memberships, content, and Services

• To process transactions and send related information, including purchase confirmations and invoices

• To deliver coaching sessions, masterclasses, and other Services

• To facilitate community participation and forum discussions

3.2 Communication

• To send you important Service-related communications, including account notifications, technical updates, security alerts, and support messages

• To send marketing emails and newsletters, including Apinder Bedi's Strategic Execution Newsletter, program announcements, and exclusive member opportunities

• To respond to your inquiries, requests, and customer support communications

3.3 Improvement and Personalization

• To analyze usage patterns and improve our website, Services, content, and user experience

• To personalize your experience and deliver content relevant to your interests and professional role

• To develop new products, services, features, and content

3.4 Marketing and Advertising

• To deliver targeted advertisements through third-party platforms such as Meta (Facebook/Instagram), LinkedIn, and Google

• To measure the effectiveness of our marketing campaigns

• To create custom and lookalike audiences on advertising platforms (using hashed or anonymized data)

• To retarget visitors who have interacted with our website or Services

3.5 Legal and Compliance

• To comply with applicable laws, regulations, and legal obligations

• To enforce our Terms and Conditions and other agreements

• To protect our rights, property, and safety, and that of our users and the public

• To detect, prevent, and address fraud, security issues, and technical problems

4. LEGAL BASIS FOR PROCESSING

Depending on your location and applicable law, we process your personal information based on one or more of the following legal bases:

• Consent: You have given your consent for us to process your personal information for specific purposes (e.g., subscribing to our newsletter, accepting cookies)

• Contract performance: Processing is necessary to fulfill our contractual obligations to you (e.g., providing access to purchased courses, delivering Services)

• Legitimate interests: Processing is necessary for our legitimate business interests, such as improving our Services, marketing, fraud prevention, and security, provided these interests are not overridden by your rights

• Legal obligation: Processing is necessary to comply with applicable laws and regulations

5. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, trade, or otherwise share your personal information with third parties for their own marketing purposes.

We may share your information only in the following limited circumstances:

5.1 Third-Party Service Providers

We use trusted third-party service providers to operate and deliver our Services. These providers have access to your information only to the extent necessary to perform their functions and are contractually obligated to protect your information. Our current service providers include:

• Kajabi: Course hosting, membership portal, community platform, email marketing, and Kajabi Payments — https://kajabi.com/policies/privacy

• Stripe: Payment processing — https://stripe.com/privacy

• Google (Analytics and Tags): Website analytics and advertising — https://policies.google.com/privacy

• Meta (Facebook/Instagram): Advertising and retargeting via Meta Pixel — https://www.facebook.com/privacy/policy/

• LinkedIn: Advertising and retargeting via LinkedIn Insight Tag — https://www.linkedin.com/legal/privacy-policy

5.2 Legal Requirements

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a legal request.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our website of any such change in ownership or control of your personal information.

5.4 With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

6. DATA RETENTION

6.1 Retention Period. We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to provide our Services, maintain your account, comply with our legal obligations, resolve disputes, and enforce our agreements.

6.2 General Retention Guidelines.

• Active account data: Retained for the duration of your account's existence and active use of our Services

• Purchase and transaction records: Retained for a minimum of seven (7) years to comply with tax and accounting requirements

• Marketing and communication preferences: Retained until you opt out or request deletion

• Analytics and usage data: Retained in aggregated or anonymized form for as long as useful for analytical purposes

• Community content: Posts, comments, and forum contributions may remain visible even after account deletion, though your personal identifiers will be removed or anonymized where feasible

6.3 Post-Termination. Following termination or deletion of your account, we may retain certain information as required by law or for legitimate business purposes, including backup and archival copies. We will delete or anonymize your personal information when it is no longer needed.

7. DATA SECURITY

7.1 Security Measures. We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, use, alteration, disclosure, or destruction. These measures include encryption of data in transit (SSL/TLS), secure authentication protocols, access controls, and regular monitoring of our systems.

7.2 Third-Party Security. Our third-party service providers, including Kajabi and Stripe, maintain their own security programs and are required to protect data in accordance with applicable standards and regulations. Stripe, for example, is PCI-DSS Level 1 certified.

7.3 No Absolute Guarantee. While we take reasonable precautions to protect your information, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your personal information. You acknowledge and accept this inherent risk when providing personal information online.

7.4 Your Responsibility. You are responsible for maintaining the security of your account credentials and for any activity that occurs under your account. Please notify us immediately at admin@victeroconsulting.com if you suspect any unauthorized access to your account.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 What Are Cookies? Cookies are small text files stored on your device when you visit a website. They help us recognize your browser, remember your preferences, and understand how you use our website.

8.2 Types of Cookies We Use.

• Strictly Necessary Cookies: Essential for our website to function properly. These cookies enable core features such as security, account authentication, and network management. They cannot be disabled.

• Analytics and Performance Cookies: Help us understand how visitors interact with our website by collecting and reporting information about usage patterns. We use Google Analytics and Google Tags for this purpose.

• Advertising and Targeting Cookies: Used to deliver advertisements relevant to you and to measure the effectiveness of our advertising campaigns. These include the Meta (Facebook) Pixel, LinkedIn Insight Tag, and Google advertising cookies.

8.3 Third-Party Cookies. Some cookies are placed by third-party services that appear on our pages. We do not control these third-party cookies. Please refer to the respective privacy policies of these providers for more information:

• Google: https://policies.google.com/technologies/cookies

• Meta: https://www.facebook.com/policies/cookies/

• LinkedIn: https://www.linkedin.com/legal/cookie-policy

8.4 Managing Cookies. You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, if you disable certain cookies, some features of our website may not function properly. You may also opt out of targeted advertising through the following resources:

• Digital Advertising Alliance (DAA): https://optout.aboutads.info/

• Network Advertising Initiative (NAI): https://optout.networkadvertising.org/

• European Interactive Digital Advertising Alliance (EDAA): https://www.youronlinechoices.eu/

8.5 Do Not Track Signals. Our website does not currently respond to "Do Not Track" (DNT) browser signals. However, you may manage tracking through the cookie management options described above.

9. YOUR RIGHTS AND CHOICES

Depending on your location and applicable law, you may have certain rights regarding your personal information:

9.1 Right to Access. You have the right to request a copy of the personal information we hold about you.

9.2 Right to Correction. You have the right to request that we correct any inaccurate or incomplete personal information.

9.3 Right to Deletion. You have the right to request that we delete your personal information, subject to certain exceptions (e.g., where retention is required by law or for legitimate business purposes).

9.4 Right to Opt Out of Marketing. You have the right to opt out of receiving marketing emails at any time by clicking the "unsubscribe" link in any marketing email or by contacting us at admin@victeroconsulting.com. Please note that even if you opt out of marketing communications, we may still send you Service-related transactional communications (e.g., account updates, purchase confirmations, security alerts).

9.5 Right to Data Portability. Where technically feasible and required by applicable law, you have the right to receive your personal information in a structured, commonly used, and machine-readable format.

9.6 Right to Restrict Processing. You may have the right to request that we restrict the processing of your personal information under certain circumstances.

9.7 Right to Object. You may have the right to object to the processing of your personal information for certain purposes, including direct marketing and processing based on legitimate interests.

9.8 Right to Withdraw Consent. Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

9.9 Exercising Your Rights. To exercise any of these rights, please contact us at:

Email: admin@victeroconsulting.com

We will respond to your request within thirty (30) days, or as required by applicable law. We may need to verify your identity before processing your request.

10. CALIFORNIA PRIVACY RIGHTS

10.1 California Residents. If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• The right to know what personal information we collect, use, disclose, and sell

• The right to request deletion of your personal information

• The right to opt out of the sale or sharing of your personal information

• The right to non-discrimination for exercising your privacy rights

• The right to correct inaccurate personal information

• The right to limit the use and disclosure of sensitive personal information

10.2 No Sale of Personal Information. We do not sell your personal information as defined under the CCPA/CPRA. We do not share your personal information for cross-context behavioral advertising purposes.

10.3 Exercising California Rights. California residents may exercise their rights by contacting us at admin@victeroconsulting.com. We will verify your identity before processing your request and will respond within forty-five (45) days as required by law.

11. INTERNATIONAL USERS

11.1 Data Processing Location. Our Services are operated from the United States. If you access our Services from outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your country of residence.

11.2 European Economic Area (EEA), United Kingdom, and Switzerland. If you are located in the EEA, UK, or Switzerland, we process your personal data in accordance with the legal bases described in Section 4. You may have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR, including the right to lodge a complaint with your local supervisory authority.

11.3 Consent to Transfer. By using our Services and providing your personal information, you consent to the transfer of your information to the United States and the processing of that information as described in this Privacy Policy.

12. CHILDREN'S PRIVACY

12.1 Age Restriction. Our Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18.

12.2 Parental Notification. If we become aware that we have inadvertently collected personal information from a child under 18 without verifiable parental consent, we will take immediate steps to delete that information from our systems.

12.3 Parental Rights. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at admin@victeroconsulting.com so that we can take appropriate action.

13. MARKETING AND EMAIL COMMUNICATIONS

13.1 Marketing Emails. By providing your email address and joining our membership, subscribing to our newsletter, or purchasing our Services, you consent to receive marketing and promotional emails from Victero Consulting, including the Strategic Execution Newsletter, program announcements, masterclass notifications, and exclusive member offers.

13.2 Frequency. We strive to send relevant and valuable communications. The frequency of marketing emails may vary depending on program launches, events, and content schedules.

13.3 Opt Out. You may unsubscribe from marketing emails at any time by clicking the "unsubscribe" link included at the bottom of each email or by contacting us at admin@victeroconsulting.com. Please allow up to ten (10) business days for your request to be fully processed. Opting out of marketing emails will not affect transactional or Service-related communications.

14. COMMUNITY AND USER-GENERATED CONTENT

14.1 Public Posts. If you participate in our community forums, discussions, or other interactive features within the Kajabi Community or member portal, please be aware that any information you share in these areas may be visible to other members of the community.

14.2 Personal Responsibility. You are solely responsible for the information you choose to share in community spaces. We encourage you to exercise caution and not disclose sensitive personal information (e.g., financial details, passwords, confidential business information) in public community forums.

14.3 No Guarantee of Confidentiality. While we enforce Community Guidelines (as described in our Terms and Conditions), we cannot guarantee the confidentiality of information shared in community spaces.

14.4 Content Retention. Community posts and contributions may remain visible within the platform even after your account is terminated or deleted. We will make reasonable efforts to remove or anonymize your personal identifiers upon request, subject to technical feasibility.

15. THIRD-PARTY LINKS AND SERVICES

15.1 External Links. Our website and Services may contain links to third-party websites, services, or resources. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices or content of any third-party website.

15.2 Due Diligence. We encourage you to review the privacy policies of any third-party website you visit through links on our website before providing any personal information.

16. CHANGES TO THIS PRIVACY POLICY

16.1 Right to Update. We reserve the right to update, modify, or revise this Privacy Policy at any time at our sole discretion to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

16.2 Notification of Changes. When material changes are made to this Policy, we will notify you via email to the address associated with your account. The "Last Updated" date at the top of this Policy will also be revised accordingly.

16.3 Continued Use. Your continued use of our Services following notification of changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should discontinue use of the Services and contact us to request deletion of your personal information.

17. DATA BREACH NOTIFICATION

17.1 Notification. In the event of a data breach that compromises the security, confidentiality, or integrity of your personal information, we will notify affected individuals and relevant authorities as required by applicable law. Notification will be provided via email and/or prominent notice on our website.

17.2 Response. We maintain incident response procedures to promptly investigate, contain, and remediate any data breach. We will take reasonable steps to mitigate the impact of any breach on affected individuals.

18. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal information, or our data practices, please contact us at:

Victero Consulting Services LLC

17350 State Hwy 249 Ste 220 #26346

Texas, USA

Email: admin@victeroconsulting.com

Data Requests: To submit a request to access, correct, delete, or otherwise exercise your rights regarding your personal data, please email admin@victeroconsulting.com with the subject line "Privacy Request."

19. ACKNOWLEDGMENT