Privacy Policy

1. Privacy, Security and Transparency

Thank you for visiting the websites and using the software published by Honor and Fire LLC. This Privacy Policy tells you what personal information we collect, how we use it, who we share it with and why, and what we do to protect it. We go into those matters in a fair amount of detail in the sections that follow, and we encourage you to read them carefully. In the meantime, here is a quick overview.

What do we collect?

We obtain two kinds of information:

• information that is collected automatically from every visitor, such as your device, your browser, and the pages you view, much of it through cookies and advertising pixels; and
• personal information that you choose to give us, such as your name, email address and phone number when you register for a webinar, book a call, apply, buy something, or create a Profit Academy account.

More details are in Sections 3, 4 and 5.

Why do we use it?

We use automatically collected information to run our websites and software, keep them secure, make them better, understand which of our campaigns work, and show you our advertising on other platforms.

We use the personal information you give us to respond to you, deliver what you signed up for or bought, bill you, support you, and send you information about our programs. We do not sell or rent your personal information to data brokers or marketing companies for money. As you might expect, we disclose information when the law requires it.

More details are in Section 6.

When do we share it?

We share personal information with the service providers who run parts of our business for us, with advertising platforms such as Meta and Google, with the affiliates and chapter leaders involved in your relationship with us, and when the law requires it. Our use of advertising pixels counts as “sharing” or a “sale” of personal information under some state laws, even though no money changes hands, and you can opt out.

More details are in Sections 10 and 11.

Your privacy choices and rights

You do not have to give us personal information to read our websites. You can unsubscribe from our emails, reply STOP to our text messages, ask us to stop calling you, and opt out of advertising sharing. Depending on where you live, you may also have the right to see, correct, or delete the information we hold about you.

More details are in Sections 11, 14, 15 and 16.

Contacting us

Questions about this overview or about the full policy can be sent to Honor and Fire LLC, 5101 East University Drive, Denton, Texas 76208, or to [email protected].

The English language version of this Privacy Policy is the controlling version, regardless of any translation.

2. About This Policy

Honor and Fire LLC (“Honor and Fire,” “we,” “us,” or “our”) is a Michigan limited liability company with its principal place of business at 5101 East University Drive, Denton, Texas 76208. We are the business that offers FRAP certification, FRAP chapter licensing, and the Profit Academy membership and software. We are the controller of the personal information described in this policy.

We use the words “you” and “your” to mean you, the reader, and anyone else who visits our websites or uses our services.

What this policy covers. This policy applies to personal information we collect through the following websites and software, and through the marketing, sales, enrollment, and support activities we run through them (together, the “Services”):

• warplan.com, including the pages and funnels served under it, and newprofit.warplan.com, where Profit Academy is also served and the Hidden Profit Assessment runs
• getfrap.com
• frapchapters.com
• honorandfire.com
• profitacademy.app and its subdomains, including revenue.profitacademy.app
• getprofitacademy.com
• any other website or page of ours that links to this policy

It also applies to personal information we collect offline or through other channels in connection with those activities, including telephone calls, video calls, text messages, email, webinars, events, and social media messaging.

This policy is our notice at collection. It identifies the categories of personal information we collect (Sections 4 and 5), why we collect each one (Section 6), whether each one is sold or shared (Section 14), and how long we keep each one (Section 8). A link to this policy is presented at or before the point where we collect personal information from you.

This policy describes what we do. It does not collect your consent. Where the law requires your consent, for example for marketing calls and text messages or for recording a call, we ask for it separately at the point the activity begins, under the disclosure presented to you there. This policy tells you what happens to the information either way.

Your other agreements with us. If you accept a separate agreement with us, including the FRAP License Agreement, the FRAP Chapter Agreement, or the Affiliate Program Agreement, and that agreement contains privacy or data terms that conflict with this policy, the agreement controls for the subject matter it covers.

3. Who We Collect Personal Information From

We may collect personal information from the following groups of people:

• Visitors to our websites.
• People who opt in, meaning anyone who gives us their contact details to register for a webinar, download something, take an assessment, book a call, or hear from us by email, text message, or phone.
• Applicants for FRAP certification and our other programs.
• Customers, meaning anyone who buys FRAP certification, a FRAP license or chapter, a Profit Academy membership, a webinar upgrade, or any other product from us.
• Profit Academy members, meaning anyone with an account in the Profit Academy software, including members given a seat by a chapter leader.
• Affiliates, chapter leaders, and referral partners.
• Business contacts, meaning owners and staff of businesses whose publicly available or commercially available business contact details we use for business-to-business outreach.
• Members of our workforce, and people who apply for jobs with us.
• Vendors and business partners.

Personal information generally means information that identifies you or can reasonably be linked to you, such as your name, address, telephone number, or email address. Some privacy laws, including the California Consumer Privacy Act and other U.S. state privacy laws and the European General Data Protection Regulation, define personal information in their own ways. Where those laws apply to us, “personal information” in this policy includes what they include.

The information we collect from each group, and the ways we use it, differ. The same person can fall into more than one group. Most of this policy addresses the first seven groups.

Workforce and job applicants. We collect the kinds of professional and employment information you would expect an employer to hold about its current and former workforce and about job applicants. We describe how we use that information in the notices we give to applicants and staff at the time we collect it. Where a third-party hiring platform collects your application and passes it to us, that platform’s own notice may also apply.

Vendors and business partners. Like any business, we buy goods and services and work with partners. We collect the business contact information we need from those people to manage and perform our contracts with them, and we describe that use in the contracts themselves.

4. What We Collect

There are two kinds of information we obtain from you and then store and use: (i) information collected automatically from every visitor, and (ii) personal information you choose to give us or that is collected in the course of your relationship with us.

If you do not want us to collect a particular kind of personal information, please do not provide it. That may mean you cannot take part in the activities that need it, such as booking a call or buying a program. It will not affect your ability to read the publicly available pages of our websites.

4.1 Information you give us

Here are the ways you give us personal information, and what we do with it.

Emails, forms, and opt-ins. When you fill out a form on one of our pages, such as to register for a webinar, download something, book a call, or contact us, we keep your name, email address, phone number, business name, and anything else you put in the form. We use it to respond to you, to deliver what you asked for, and to send you information about our programs that we think will interest you. Depending on what you gave us and what you agreed to, that may come by email, telephone call, or text message.

Text messages. When you give us your mobile number and opt in to text messages, you agree to receive recurring marketing, promotional, and informational text messages from us at that number, including messages sent using automated technology. The consent is collected at the point you give us your number, under the disclosure shown there, and is not a condition of any purchase. Message frequency varies. Message and data rates may apply. Reply HELP for help or STOP to cancel at any time. After you reply STOP you will receive one final message confirming that you have been unsubscribed. To start receiving messages again, reply START or opt in again through one of our forms. Carriers are not liable for delayed or undelivered messages. We keep the number you gave us, the record of your consent, and the record of the messages. Our text messages are sent through our customer relationship management platform, GoHighLevel. We do not sell your mobile number or your text-messaging consent, and we do not share them with third parties for their own marketing. Separately, when you buy from us or start a trial, we send hashed contact identifiers, which can include your phone number, to advertising platforms to measure our advertising, as described in Sections 7 and 10. That is not sharing of your text-messaging consent. Our text messages are sent under the registered brand name Honor and Fire LLC.

Telephone calls. Where you have agreed to be contacted, we and people acting for us call you about the programs you expressed interest in. We keep the number, the record of your consent, and a record of the calls. To stop marketing calls, tell the caller or contact us using Section 18.

Recorded and transcribed calls. We record and transcribe sales calls, discovery calls, onboarding calls, coaching calls, and support calls, so that we have accurate notes, can train our team, can check quality, and can improve our programs. We also record telephone calls placed or received through our customer relationship management platform, GoHighLevel. Video meeting recording and transcription are performed by a third-party provider, Fathom, acting for us, and recordings and transcripts may be processed by automated and artificial intelligence tools to produce summaries and action items. When a video meeting is recorded, an automated announcement at the start of the meeting tells you so. Telephone calls with us may be recorded. By continuing a call with us you consent to it being recorded. During a discovery call, a member of our sales team may also enter details about your business into our sales tool to prepare a report about your market for you.

Applications and assessments. When you apply for FRAP certification or another program, we collect your answers, which may include information about your business, your industry, your revenue range, your team, your goals, and how you plan to invest in your business. When you take the Hidden Profit Assessment, you enter your name and answer questions about your business, and the assessment calculates scores and estimates for you. We save your answers, your scores, and the contact details you give, and link them to your contact record, so that we can show you your results and follow up with you about them and about our programs.

Registering for webinars and events. When you register for a webinar or event we host, you give us your contact details, and if the event has a fee or an upgrade, your payment information. We use it to register you, send you reminders and replays, and follow up afterwards.

Buying from us. When you buy something, we collect your name, billing address, the product you bought, the amount, and your transaction history. Card numbers and bank details are collected and processed directly by our payment processors, Stripe and PayPal. We do not receive or store your full card number. We receive confirmation of payment, the card brand, the last four digits, and information about any refund, dispute, or chargeback.

Accepting an agreement. When you accept the FRAP License Agreement, the FRAP Chapter Agreement, or another agreement by checking a box, we keep a record of your acceptance, including the date, time, and version you accepted, together with the identifying details you gave at acceptance, such as your legal name, whether you are accepting as an individual or a business, your state, your mailing address, and your email address.

Creating a Profit Academy account. When you create an account, we collect your name, email address, telephone number, and sign-in details, and we use them to create and secure your account and to communicate with you about it. Inside the product you may also enter your business name and details, the leads and pipeline records you manage, your chapter and membership information, content you upload, and support messages. We use that information to provide the features you use.

Connecting other accounts to Profit Academy. Some Profit Academy features work only if you connect another account, such as a bank or credit account (Section 5), a marketing platform, or a social media account. If you connect one, we receive the information that feature needs.

Artificial intelligence features in Profit Academy. When you use an artificial intelligence feature, the prompts, documents, and content you submit are sent to our artificial intelligence provider to produce your output, and are stored so you can come back to your work. Bank and financial account information is not sent to artificial intelligence providers.

Affiliates and chapter leaders. If you join our affiliate program or become a chapter leader, we collect the information we need to run that relationship, including your contact details, the referrals and sales credited to you, your commission and payout records, and, for chapter leaders, your territory, your seats, and your members. We also collect a W-9 tax form, which includes your taxpayer identification number, from affiliates and chapter leaders we pay. Payouts are made through PayPal, so we do not hold your bank details.

Testimonials and content you send us. If you send us a testimonial, review, story, photograph, or video, we keep it and may use it as described in the release you sign or accept when we collect it.

Support and correspondence. We keep the messages you send us and our replies.

Please do not send us sensitive information we have not asked for, such as government identification numbers, bank login details, health information, or other sensitive information. If you send it anyway, we may delete it.

4.2 Information collected automatically

When you visit our websites or use our software, basic information is collected through your browser, using cookies, pixels, and similar technologies (Section 7). This includes:

• Device and connection information. IP address, browser type and version, operating system, device identifiers, screen size, language, and the page that referred you.
• Usage information. Pages viewed, time on page, scroll depth, links and buttons clicked, forms started and completed, and your path through the site.
• Campaign and attribution information. UTM parameters and similar campaign codes. On some of our websites these are stored in your browser’s local storage, so that a later form submission or purchase can be credited to the campaign that brought you to us.
• Video engagement information. Where a page contains a hosted video, our video provider records whether you played it, how much you watched, and which parts you replayed.
• Approximate location. A general location, such as city or region, derived from your IP address. We do not collect the precise location of your device.
• Profit Academy activity. Sign-in events, features used, and application error reports.

We use this information to run and improve the Services, to understand how people find and use them, to keep them secure, and to deliver and measure our advertising.

4.3 Information we receive from other sources

• Advertising and analytics platforms. Campaign performance, audience, and conversion information from platforms including Meta and Google.
• Business data sources. We obtain business names, addresses, telephone numbers, email addresses, and similar business contact details from public sources, such as business directories and chamber of commerce listings, and from commercial data vendors, and we use them for business-to-business outreach. If you received an email or call from us and never gave us your details, this is the likely source. You can opt out at any time using Section 11.
• Payment processors. Payment confirmations and card, refund, and dispute details, as described in Section 4.1.
• Plaid, if and when bank connection is offered and you connect a bank or credit account (Section 5).
• Affiliates and chapter leaders, where one of them refers you to us or gives you a Profit Academy seat.
• Social media platforms and messaging tools, where you message us through a social media platform, including through automated messaging tools we use on Instagram and Facebook.

5. Bank and Credit Account Information in Profit Academy

Bank connection is not yet available in Profit Academy. This section describes how it works if and when we offer it and you choose to connect a bank or credit account. Connecting an account will always be optional, and the rest of Profit Academy works without it.

We never see your bank login. When you connect an account you are handed to Plaid Inc., our service provider for this feature. You enter your credentials with Plaid, not with us. Your bank username and password are never sent to us and never stored on our systems. Your use of Plaid is also governed by Plaid’s own end user privacy policy, which is shown to you before you connect.

What we receive from Plaid: account names, types, and balances; transaction history, including dates, amounts, descriptions, and merchant information; and, for credit accounts, statement balances, due dates, minimum payments, and credit limits.

What we do with it: we show it back to you inside Profit Academy so you can see your balances and cash-flow trends. That is the whole purpose.

What we cannot do with it: we request read-only access. We do not have, and have not turned on, the ability to move money, make a payment, or make a transfer from any account you connect.

We do not sell this information, we do not share it for advertising, we do not send it to artificial intelligence providers, and we do not use it to train artificial intelligence models.

You are in control. You can disconnect a connected account at any time from inside Profit Academy, without contacting anyone. When you disconnect, we tell Plaid to revoke our access immediately, and we delete the associated information within 30 days. The same happens automatically if your membership ends for any reason.

Before you can connect an account, we ask you to confirm a one-time code sent to your verified mobile number, to make sure the person connecting the bank account is you.

6. How We Use Personal Information

We use personal information for the following purposes:

• to run, maintain, secure, and improve our websites, our software, and our programs
• to respond to your questions and requests
• to register you for webinars and events, and to schedule and hold calls with you
• to review applications and decide eligibility for programs, certification, and licensing
• to process purchases, deliver what you bought, bill you, and keep the tax and accounting records the law requires
• to create and manage your Profit Academy account and provide its features, including showing you your own connected account information
• to run our affiliate and chapter programs, credit referrals, and pay commissions
• to send you marketing by email, text message, telephone, and postal mail, subject to the consents described in Section 4.1
• to record, transcribe, summarize, and review calls, as described in Section 4.1
• to deliver, target, and measure advertising, including advertising shown to you on other platforms (Sections 7 and 11)
• to understand how people use our websites and software and to improve our content, offers, and conversion
• to provide customer support
• to detect, investigate, and prevent fraud, abuse, and security incidents
• to keep records, resolve disputes, enforce our agreements, and comply with the law

Automated tools and artificial intelligence. We use automated tools, including artificial intelligence tools, to transcribe and summarize calls, to sort and route messages, to draft communications that a person reviews before they are sent, and to analyze how our campaigns and business are performing. We do not make decisions that have legal or similarly significant effects on you based solely on automated processing.

7. Cookies, Pixels, and Other Tracking Technologies

A cookie is a small text file placed on your device when you visit a website. It lets the site recognize your device and remember information about your visit. We also use pixels (also called web beacons), server-side event forwarding, and your browser’s local storage. We allow third parties to use these technologies on our websites to collect information about your browsing over time.

They fall into these groups:

• Strictly necessary. Needed to run the Services, keep them secure, and keep you signed in. These cannot be switched off through our controls.
• Analytics and performance. Used to understand traffic and usage. These include Google Analytics and Google Tag Manager. You can learn how Google uses this information at policies.google.com/technologies/partner-sites, and you can opt out of Google Analytics at tools.google.com/dlpage/gaoptout.
• Advertising and retargeting. Used to deliver and measure advertising. These include the Meta Pixel and the Meta Conversions API, which sends events to Meta from our servers as well as from your browser. When you buy from us or start a Profit Academy trial, the Conversions API event includes hashed identifiers (your email address, phone number, first and last name, city, state, ZIP code and country) along with your IP address and browser details, so that Meta can match the event to an account and measure our advertising. Hashing turns each identifier into a scrambled code before it is sent.
• Functional. Used to remember preferences and to store campaign codes in local storage, as described in Section 4.2.

Your choices. You can block or delete cookies through your browser settings, and, where we present one, through a cookie banner or preference center. Blocking strictly necessary cookies may stop parts of the Services from working.

Do Not Track and other browser signals. There is no common industry standard for responding to “Do Not Track” or similar browser signals, and our websites do not currently respond to them. To opt out of advertising sharing, use one of the methods in Section 11.

8. Data Retention

We keep personal information for as long as we need it for the purposes in this policy and as the law requires. The criteria we use are (i) how long we have an ongoing relationship with you, (ii) whether a law requires us to keep it, and (iii) whether keeping it is advisable to enforce our agreements, meet limitation periods, resolve disputes, or deal with litigation or regulatory inquiries. The periods below apply unless a longer period is required by law or a legal hold.

When we no longer need information we delete it or de-identify it. Information we delete may remain in routine backups until those backups expire on their own schedule, and we do not restore deleted information into use. Where we hold de-identified information, we keep it in that form and do not try to re-identify it.

9. External Sites, Apps, Links and Social Media

We maintain a presence on social media platforms such as Facebook, Instagram, YouTube, and LinkedIn, and some features of our websites connect with those platforms. Our websites and software also link to, and work with, websites, apps, and services run by other companies, including our payment processors and Plaid.

We are not responsible for the content or the privacy practices of social media platforms or of any third-party site, app, or service. They are not controlled by us, and they have their own privacy policies and terms. If you have questions about how they collect and use personal information, read their privacy policies and contact them directly.

10. When and With Whom We Share Personal Information

Service providers. We use other companies to run parts of our business. We share personal information with them so they can perform services for us, and we require them to use it only for that purpose. The categories, with the main providers we use today, are:

Advertising partners. We give identifiers and conversion events to advertising platforms so that we can measure our campaigns and reach people likely to be interested in our programs. For purchases and trial starts, this includes the hashed contact identifiers described in Section 7, which can include your phone number. Under some state privacy laws this counts as a “sale” or “sharing” of personal information, even though no money changes hands. See Sections 11 and 14.

Affiliates, chapter leaders, and referral partners. Where an affiliate or chapter leader refers you to us, we share what is reasonably needed to credit the referral and run that relationship. Where you ask to be connected with a chapter leader, we share what is needed to make the introduction. Where a chapter leader gives you a Profit Academy seat, or you join a chapter, the chapter leader may receive your name and contact details as part of their member list. An affiliate who referred you receives your name and email address.

Professional advisors. We share information with our lawyers, accountants, and auditors where they need it to advise us.

Legally required disclosures. We disclose personal information to government authorities, and to other parties when those authorities require it, including in response to court orders and subpoenas, or where otherwise required or permitted by law.

To prevent harm. We disclose personal information when we believe in good faith that it is needed to protect our rights or property, to enforce our agreements, to investigate suspected fraud, or to protect the safety of our customers, members, or anyone else.

Business transfer. If we, or substantially all of our assets, are acquired or merged, or in a financing, reorganization, or sale of all or part of our business, personal information may be disclosed to the other party and its advisors and transferred as part of that transaction.

At your direction. We share personal information with any other party when you direct us to or agree that we may.

Standards for the companies we share with. We try to bind our service providers by contract to use the personal information we give them only to perform services for us, and not to disclose it to anyone else without our instruction. We cannot guarantee that every provider will agree to our terms, or that every provider that agrees will always comply.

We do not sell personal information for money, and we do not give personal information to other companies for their own independent marketing, other than as described in this section.

11. Your Rights and Options

You can choose not to give us personal information, but some features and programs may then not be available to you. Wherever you live, you can do the following.

Stop marketing email. Use the unsubscribe link in any marketing email, or contact us using Section 18. We may still send you messages about a purchase, your account, or an appointment you booked.

Stop text messages. Reply STOP to any text message. Reply HELP for help. You will get one final message confirming you are unsubscribed. Opting out of text messages may affect our ability to send you some information, such as appointment reminders.

Stop marketing calls. Tell the person calling you, or contact us using Section 18.

When you opt out, we take reasonable steps to remove you from our lists. It can take a short time for the change to reach every system, so you may still receive a message for a short period after you opt out.

Opt out of advertising sharing. Our advertising pixels send identifiers and records of what you did on our websites to platforms such as Meta and Google, so that we can show you our advertising elsewhere and measure whether it works. To opt out, submit a request at getfrap.com/data-rights-request and choose “Opt out of ad sharing,” or email [email protected] with the subject line “Opt Out of Sharing.” We will stop sending your contact information to advertising platforms and exclude you from our advertising audiences. You can also limit this activity yourself through your browser’s cookie settings, your Meta ad preferences (facebook.com/adpreferences), and your Google ad settings (adssettings.google.com). Opting out does not stop you seeing advertising. It stops us sharing your identifiers to target advertising to you.

See, correct, or delete your information. You can ask us for a copy of the information we hold about you, ask us to correct it, or ask us to delete it, using Section 18. Profit Academy members can also edit their profile, delete content they entered, and disconnect a bank account from inside the product without making a request.

People in some places have additional rights. See Sections 14, 15 and 16.

12. Children’s Privacy

Our websites and programs are designed for adults who own or run a business, or want to. They are not directed to children. We do not knowingly collect personal information from anyone under 18, and we do not knowingly sell or share the personal information of anyone under 16. If we learn that someone under 18 has given us personal information, we will delete it and will not use it for any purpose. If you believe a child has given us personal information, contact us at [email protected].

13. How We Protect Personal Information

We maintain a security program that includes administrative, technical, and physical measures designed to protect personal information against loss, misuse, unauthorized access, disclosure, alteration, and destruction. These include encrypting information in transit, access controls, and limiting access to the people who need it.

These safeguards apply to Profit Academy as well as to our websites, including encrypted connections and limits on who can reach the systems that hold member information.

We have incident response procedures that we follow when we learn that personal information may have been compromised, and if an incident affects your information we will notify you as the law requires. We ask our service providers to tell us promptly if they believe an incident has affected personal information we gave them.

No method of sending information over the Internet and no method of storing it electronically is completely secure. We cannot guarantee that information will never be accessed, lost, misused, or altered without authorization. You are responsible for keeping your Profit Academy password confidential and for telling us promptly if you think your account has been compromised.

14. U.S. State Privacy Laws

This section applies to residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and any other state whose consumer privacy law applies to us (the “Designated States”), where those laws apply to our processing. These laws include the California Consumer Privacy Act as amended (“CCPA”) and the comparable laws of the other Designated States (together, “State Privacy Laws”). In this section, “personal information” has the meaning given in those laws.

14.1 What we collect, where it comes from, and who receives it

The table below describes our practices during the 12 months before the Effective Date. We will not collect new categories of personal information, or use what we collected for materially different purposes, without telling you and, where the law requires, asking your consent.

Recipient categories: (1) service providers and contractors; (2) advertising and analytics platforms; (3) affiliates, chapter leaders, and referral partners; (4) professional advisors. We may also disclose any category to government authorities where required by law, and to a buyer in a business transfer (Section 10).

Sale and sharing. We have not sold personal information for money in the past 12 months. We do disclose personal information in a way that may count as a “sale” or “sharing” under State Privacy Laws: the categories marked “Yes” above are disclosed to companies that run cookies, pixels, and other online tracking technologies on our websites, principally Meta and Google, for targeted advertising. We do not knowingly sell or share the personal information of anyone under 16.

Sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted by Section 7027(m) of the CCPA Regulations, such as providing the service you asked for, securing your account, and meeting our tax reporting obligations.

Retention. See Section 8.

14.2 Your rights

Depending on your state, and subject to exceptions in the law, you may have the right to:

• Know and access. Confirm whether we process your personal information and get a copy of it, including the categories collected, the sources, the purposes, and the categories of third parties we disclosed it to, sold it to, or shared it with.
• Correct inaccurate personal information.
• Delete personal information we collected about you.
• Portability. Get your information in a portable, readily usable format.
• Opt out of targeted advertising, sale, and sharing. See Section 11 for how.
• Opt out of profiling that produces legal or similarly significant effects. We do not engage in that kind of profiling.
• Limit the use of sensitive personal information. We use sensitive personal information only for purposes that do not give rise to this right.
• Get a list of third parties. Residents of states that provide this right, including Oregon, Delaware, Minnesota, and Maryland, may ask for a list of the specific third parties, or categories of third parties, to which we have disclosed personal information.
• Appeal a decision we make on your request.
• Non-discrimination. We will not treat you differently for exercising a right. We will not deny you goods or services, charge you a different price, or give you a different level of quality because you exercised a privacy right.

14.3 How to make a request

Submit the form at getfrap.com/data-rights-request, email [email protected] with “Privacy Request” in the subject line, contact us toll-free at 1-866-740-9538, or write to us at the address in Section 18. We may limit requests for a copy of your information to two in any 12-month period, where the law allows.

Verification. We can act on a request only if we can verify your identity or your authority to make it. We will ask for identifying information and match it to what we hold, typically by confirming that you control the email address or account connected to the information. For a Profit Academy member, we verify against the account. For a website visitor, the information we hold is usually tied to a browser or device rather than to a name, so we may ask for details that help us find the right records, such as the browser and approximate dates involved. We use verification information only to handle your request.

Authorized agents. Only you, or a person you authorize in writing, may make a request about your information. An agent must provide documentation signed by you showing their authority, and we may ask you to verify your identity directly.

Timing. We acknowledge requests within 10 business days and respond within 45 days. Where a request is complex we may extend by a further 45 days, and we will tell you before the first period ends. If we must keep some information, such as billing records under Section 8, we will tell you what we are keeping and why.

Appeals. If we decline your request, we will explain why and how to appeal. Send your appeal to the email or address above within a reasonable time after our response. We will decide an appeal within 45 days, or the period your state’s law requires. If your appeal is denied, you may contact your state attorney general.

California “Shine the Light.” California residents may ask for information about disclosures of personal information to third parties for those parties’ own direct marketing. As stated in Section 10, we do not make those disclosures.

Nevada. Nevada residents may ask us not to sell certain covered information. We do not sell covered information as Nevada law defines it.

15. The EU General Data Protection Regulation, UK GDPR and Swiss Law

This section applies where the General Data Protection Regulation, the UK GDPR, or the Swiss Federal Act on Data Protection applies to our processing of your personal information, for example because you are in the European Economic Area, the United Kingdom, or Switzerland (the “GDPR Jurisdictions”). In this section, “you” means people in those places.

What we collect and why. We collect the categories of personal information described in Sections 4 and 5, for the purposes in Section 6. Our legal bases are:

• Contract, to provide what you bought and to run your account, membership, license, or program.
• Consent, for non-essential cookies and tracking technologies, for marketing where consent is required, and for call recording where consent is the applicable basis. You may withdraw consent at any time, without affecting processing that took place before you withdrew it.
• Legitimate interests, to run and secure our business, to carry out business-to-business marketing, to measure and improve our Services, and to establish, exercise, or defend legal claims, where our interests are not overridden by your rights.
• Legal obligation, to meet tax, accounting, and other legal requirements.

We do not make decisions about you based solely on automated processing.

Your rights. You have the rights to access, correction, erasure, restriction of processing, data portability, and objection, including the right to object at any time to direct marketing. These rights are subject to the conditions and exemptions in Articles 12 through 23 of the GDPR and the equivalent provisions of UK and Swiss law. One of those conditions is our right to decline part or all of a request if we cannot reasonably satisfy ourselves about your identity. We respond without undue delay and within the time the law sets. To make a request, contact us using Section 18. If you are not satisfied with how we use your information or respond to your request, you have the right to complain to your data protection authority.

International transfers. We are established in the United States, and information we collect is processed in the United States and in other countries where our service providers operate. Those countries may not offer the same level of protection as your home country. Where we transfer personal information out of a GDPR Jurisdiction to a country that has not been found to provide adequate protection, we rely on safeguards the law permits, including the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, with supplementary measures where needed. You may ask for a copy of the safeguards we use.

16. Rights of People in Other Jurisdictions

In other places with similar privacy laws, we collect the categories of personal information already described, and we collect, use, and disclose it in compliance with the applicable local law. If you are in Canada, you may ask for access to and correction of your personal information, and you may withdraw your consent to our use of it, subject to legal and contractual restrictions and reasonable notice. As noted above, we do not sell personal information for money, and we do not make decisions about you based solely on automated processing.

17. Changes to This Policy

We may change this policy from time to time. When we do, we will update the Last Updated date at the top and change the version number. If a change is material, we will give additional notice before it takes effect, by posting a notice on our websites and, for customers and Profit Academy members, by email or inside the product. Information we hold is governed by the policy in place at the time, unless you agree otherwise. We keep prior versions available so you can see what was in force on a given date.

18. Contacting Us

If you have questions about this policy or our privacy practices, or want to make a request, contact us at:

Email: [email protected]
Mail: Honor and Fire LLC, 5101 East University Drive, Denton, Texas 76208
Requests: getfrap.com/data-rights-request

If you need this policy in an alternative accessible format, contact us and we will provide it at no charge.