PRIVACY POLICY

Stay Firm Program

Effective Date: 4 April 2026

1. INTRODUCTION

This Privacy Policy explains how your personal information is collected, used, disclosed, and

protected when you visit:

https://www.stayfirmprogram.com (the “Website”)

or purchase or access the Stay Firm Programme (the “Programme”).

The Website and Programme are operated by:

Suzanne Noble

United Kingdom

Email: help@stayfirmprogram.com

(“we,” “us,” or “our”).

We are committed to protecting your privacy and complying with applicable laws, including:

• UK GDPR

• Data Protection Act 2018 (UK)

• U.S. state privacy laws (including California Consumer Privacy Act (CCPA) as

amended by CPRA, where applicable)

• U.S. Federal Trade Commission (FTC) consumer protection standards

2. INFORMATION WE COLLECT

We may collect the following categories of personal information:

A. Identifiers

• Full name

• Email address

• Billing address

• Country and state of residence

• IP address

B. Commercial Information

• Purchase history

• Payment transaction information

• Programme access records

Note: Payment card information is processed by secure third-party payment providers. We do

not store full card details.

C. Internet or Network Activity

• Browser type

• Device type

• Pages visited

• Time spent on pages

• Referring URLs

• Cookie data

D. Communications

• Emails you send to us

• Customer support messages

• Testimonials or feedback you voluntarily provide

E. Sensitive Information

The Programme relates to sexual health topics.

We do not require you to submit medical records. However, if you voluntarily share health-

related information in emails or communications, it will be handled confidentially and

securely.

3. HOW WE USE YOUR INFORMATION

We use personal information for the following purposes:

A. To Provide Services (Contractual Necessity)

• Process payments

• Deliver Programme access

• Provide customer support

• Send purchase confirmations

B. To Improve Our Services (Legitimate Interests)

• Analyse Website performance

• Improve user experience

• Prevent fraud or misuse

C. Marketing Communications (With Consent Where

Required)

• Send educational emails

• Provide Programme updates

• Share promotional offers

You may unsubscribe at any time using the link in our emails.

D. Legal Compliance

• Maintain accounting records

• Respond to lawful requests

• Protect legal rights

4. SHARING OF PERSONAL

INFORMATION

We may share personal information with trusted service providers, including:

• Payment processors

• Email marketing platforms

• Course hosting platforms

• Website hosting providers

• Analytics providers

These providers are contractually required to protect your information.

We do not sell personal information for monetary value.

We do not knowingly share personal data for behavioural advertising in a manner that

constitutes a “sale” under CCPA.

5. CALIFORNIA PRIVACY RIGHTS

(CCPA/CPRA)

If you are a California resident, you may have the right to:

• Know what personal information we collect

• Request access to your personal information

• Request deletion of your personal information

• Correct inaccurate personal information

• Opt out of the sale or sharing of personal information (if applicable)

• Limit the use of sensitive personal information (if applicable)

To exercise your rights, contact:

help@stayfirmprogram.com

We may need to verify your identity before fulfilling your request.

We will not discriminate against you for exercising your privacy rights.

6. OTHER U.S. STATE PRIVACY

RIGHTS

Residents of certain U.S. states (such as Virginia, Colorado, Connecticut, Utah, and others

with applicable laws) may have similar rights to:

• Access

• Delete

• Correct

• Opt out of certain data processing

To exercise these rights, email:

help@stayfirmprogram.com

7. INTERNATIONAL DATA TRANSFERS

Because we operate from the United Kingdom and sell to U.S. customers:

• Data may be processed in the UK, United States, or other countries.

• We implement appropriate safeguards for international data transfers, including

contractual protections and secure service providers.

8. DATA RETENTION

We retain personal information only as long as necessary for:

• Providing Programme access

• Legal and accounting requirements

• Resolving disputes

• Enforcing agreements

When no longer required, information is securely deleted or anonymised.

9. COOKIES & TRACKING

TECHNOLOGIES

We use cookies and similar technologies to:

• Enable Website functionality

• Analyse traffic

• Improve performance

• Support marketing efforts

You may control cookies through your browser settings.

If required by law, cookie consent mechanisms will be provided.

10. DATA SECURITY

We implement appropriate security measures, including:

• Secure hosting environments

• Encrypted payment processing

• Password-protected accounts

• Limited internal access to data

However, no internet transmission is completely secure.

11. CHILDREN’S PRIVACY

This Website and Programme are not intended for individuals under 18 years of age.

We do not knowingly collect personal information from minors.

If you believe a minor has provided personal information, contact us at

help@stayfirmprogram.com.

12. THIRD-PARTY LINKS

The Website may link to third-party websites.

We are not responsible for their privacy practices.

We encourage you to review their privacy policies.

13. YOUR UK GDPR RIGHTS

If you are located in the United Kingdom or European Economic Area, you have the right to:

• Access your personal data

• Correct inaccurate data

• Request erasure

• Restrict processing

• Object to processing

• Request data portability

• Withdraw consent

• Lodge a complaint with the Information Commissioner’s Office (ICO)

ICO website: https://ico.org.uk

14. DO NOT TRACK SIGNALS

Some browsers transmit “Do Not Track” signals.

At this time, we do not respond differently to such signals due to the lack of a consistent

industry standard.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically.

The updated version will be posted on the Website with a revised effective date.

Continued use of the Website after updates constitutes acceptance.

16. CONTACT INFORMATION

For questions about this Privacy Policy or to exercise your rights, contact:

Stay Firm Programme

Operated by Suzanne Noble

Email: help@stayfirmprogram.com

Website: https://www.stayfirmprogram.com