Separia™

Privacy Policy

Effective Date: June 6, 2026 · Last Updated: June 6, 2026

Governing law: State of Florida · separia.com/privacy

Please read this Privacy Policy carefully. It describes how Separia™ ("Separia™," "we," "our," or "us") collects, uses, discloses, and protects personal information in connection with our website, membership platform, content, and related services. By visiting, accessing, or using any Separia™ services, you acknowledge that you have received and reviewed this Privacy Policy. Please also review our Terms of Service. If you have questions, contact us as set forth in Section 20 (How to Contact Us).

This Policy includes: a unified Your U.S. State Privacy Rights section (Section 18) covering residents of several states; details on cookies and tracking technologies, sensitive data, automated decision-making and AI, data portability, verification and appeals, vendor transparency, cross-border transfers, data retention, auto-renewal, communications (email and SMS), and more.

TABLE OF CONTENTS

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1. SCOPE AND SERVICES

This Privacy Policy applies to personal information collected or processed in connection with:

• our website located at separia.com, its subdomains, and any other websites that link to this Policy (the "Website");
• our private membership platform, including content, tools, courses, journal prompts, audio meditations, quizzes, community features, and live programs (the "Membership Platform"); and
• any related services, new features, or functionality provided by us (together with the Website and Membership Platform, the "Services").

"Personal information" means information that identifies or can reasonably be linked to a particular person or household. De-identified and aggregated information is not personal information.

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2. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Except for material changes, updates are effective when posted at separia.com/privacy. For material changes, we will provide reasonable advance notice, for example by email and/or a prominent notice on the Services, and state the effective date. If you do not agree to an update, you must stop using the Services. Continued use after the effective date constitutes acceptance of the updated Policy.

Unless otherwise stated, material changes apply prospectively. Where a material change would affect the use of previously collected information in a materially different way, we will describe the change and obtain consent where required by applicable law.

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3. INFORMATION WE COLLECT

A. Information You Provide

• Contact information (name, email address, and similar contact details)
• Login credentials (username, password)
• Member-submitted content (journal entries, responses to prompts, community posts, quiz responses, uploads)
• AI-assisted interactions (inputs and related content you submit in AI-powered features)
• Surveys, feedback, and support communications
• Limited payment transaction details collected via our payment processor (see Section 4)

B. Information Collected Automatically

• Log data (IP address, browser type and settings, timestamps, interaction data)
• Usage and analytics (content viewed, features used, referring URLs, time zone, country)
• Device information (device type, operating system, configuration, identifiers)
• Approximate location (city/state inferred from IP address; we do not collect precise geolocation)

C. Information from Third Parties

• Service providers supporting operations (e.g., hosting, analytics)
• Email platform data where you have opted in to communications
• Social media interactions (name, username, and publicly posted activity)

D. Aggregated and De-Identified Data

We may aggregate or de-identify personal information and will not attempt to re-identify it unless required by law. De-identified or aggregated data may be retained and used for platform improvement and research.

If you provide personal information about someone else, you must ensure you are entitled to share it and that we may process it as described in this Policy.

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4. PAYMENT PROCESSING

Payments are processed by Stripe, Inc., a PCI-compliant third-party payment processor. Separia™ does not directly collect or store full payment card information. The information accessible to us is limited to partial transaction confirmation data provided by Stripe. Please review Stripe's Privacy Policy at stripe.com/privacy before submitting payment information.

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5. CHILDREN'S PRIVACY AND AGE GATING

Separia™ is for adults only (18+). We do not target, market to, or knowingly collect personal information from individuals under 18. We use age-screening measures appropriate to our Services. If we learn that we collected information from a minor without appropriate consent, we will disable access and take steps to delete or make the information inaccessible. To report a concern, contact us at hello@separia.com.

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6. SENSITIVE DATA AND MEMBER-SUBMITTED CONTENT

A. Member-Submitted Content

• Private tools (journals, worksheets): Visible only to you. Not used for marketing, profiling, or advertising.
• Quizzes and self-assessments: Used to personalize your experience within the Membership Platform. See also Section 7 regarding AI-powered quiz features.
• Community posts: Visible to other Separia™ members. Do not post information you do not wish to share with other members.
• Live programs: Content may be visible to other participants. Recording and redistribution policies are set in program-specific terms.

B. Sensitive Personal Information

Separia™ does not require sensitive personal information to use the Services. To the extent any member-submitted content includes sensitive information under applicable laws, we:

• do not sell or share it for cross-context behavioral advertising;
• do not use it for purposes unrelated to providing the Services; and
• where required by applicable law, obtain opt-in consent or provide appropriate limitations before processing.

You may exercise choices regarding sensitive personal information via the methods described in Section 12. California residents may request to limit use of sensitive personal information as described in Section 18.

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7. AUTOMATED DECISION-MAKING AND AI FEATURES

A. AI-Powered Features

• Quizzes and self-assessments: Certain quizzes use AI to process your inputs and generate personalized, informational outputs such as stage assessments and content recommendations. These outputs are informational only; they are not legal advice, mental health diagnoses, or professional assessments of any kind.
• Conversational tools: We may offer AI-powered conversational features. Content you submit is processed by AI to generate responses. These interactions are not confidential attorney-client communications. Separia™ is not a law firm and the AI does not provide legal advice.

B. Data Used by AI

• Inputs you submit directly (quiz answers, conversational inputs)
• Your membership stage and relevant platform activity, to the extent needed to personalize your experience

C. Significant-Effects Policy

We do not use AI features to make decisions that produce legal or similarly significant effects about you without human involvement. AI-generated outputs are recommendations and informational in nature. If we ever implement automated decision-making that produces significant effects, we will update this Policy and provide you with rights to access information about the logic used, to opt out, and to request human review where required by applicable law.

D. Third-Party AI Providers

AI features may be powered by third-party providers acting as service providers under contract. They are contractually limited to using your personal information only to provide the applicable service to us. You may request identification of current AI providers by emailing hello@separia.com.

E. Retention of AI Interaction Data

AI interaction content is retained consistent with Section 13. It may be retained for a limited additional period to improve AI feature quality, then deleted or anonymized. See Appendix B for the retention schedule.

F. Your Rights Regarding Automated Processing

Certain state privacy laws grant rights with respect to automated decision-making. To submit an ADMT-related request, contact hello@separia.com with "ADMT Request" in the subject line. See also Section 18 for state-specific rights.

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8. HOW WE USE PERSONAL INFORMATION

We use personal information to:

• provide, operate, and secure the Services;
• create and manage accounts and subscriptions;
• process payments;
• provide support and respond to inquiries;
• operate AI-powered features including quizzes and conversational tools;
• maintain, debug, improve, and enhance the Services and develop new features;
• conduct analytics and personalize experiences and communications;
• detect and prevent fraud, abuse, and security incidents;
• send marketing communications where permitted and consistent with your preferences; and
• comply with legal obligations, respond to lawful requests, protect rights, and enforce agreements.

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9. HOW WE DISCLOSE PERSONAL INFORMATION

We do not sell your personal information. We do not share it for third-party advertising directed at you based on your activity on the Services.

A. Service Providers and Vendors

We disclose personal information to vendors that help operate, administer, and improve the Services. Categories include:

• Hosting and infrastructure (currently Supabase and Vercel)
• Payment processing (currently Stripe)
• Email and communications (currently Kit / ConvertKit)
• AI and machine learning providers (powering quiz and conversational features)
• Analytics providers
• Professional services (attorneys, accountants, auditors)

All vendors are contractually limited to using personal information only to provide services to us and consistent with applicable law. See Appendix C for the current subprocessor list. We will provide advance notice of material changes to subprocessors.

B. Business Transfers

We may disclose information in connection with a merger, acquisition, financing, or sale of assets. The new owner may use personal information consistent with this Policy. We will notify you of any material change in use before it takes effect.

C. Legal, Safety, and Security

We may disclose information to comply with applicable law or legal process. Where not prohibited by law, we will attempt to provide prior notice. We may also disclose information to:

• enforce our Terms of Service or other agreements;
• investigate fraud, intellectual property infringement, or unlawful activity; or
• address emergencies involving risk of death or serious physical injury.

D. With Your Consent

We may disclose information for purposes not listed here with your prior consent, which you may revoke prospectively by contacting hello@separia.com.

E. Cross-Brand Context

See Section 17 for cross-brand disclosures.

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10. COOKIES AND TRACKING TECHNOLOGIES

We and authorized third parties use cookies and similar technologies (e.g., pixel tags, web beacons, local storage, embedded scripts) to operate the Services, remember your preferences, and understand usage. We do not use third-party advertising cookies for targeted advertising to members.

A. Types of Cookies We Use

• Strictly Necessary: Required for core functionality, including keeping you logged in. Cannot be disabled without affecting your ability to use the Services.
• Analytics: Help us understand how members use the platform, such as pages visited and time spent. Used only to improve the Services.

B. Your Cookie Choices

• Browser controls: You can manage cookies in your browser settings at any time. Disabling certain cookies may affect platform functionality, including your ability to stay logged in.
• Do Not Track (DNT): We do not currently respond to DNT signals due to the absence of a uniform standard for their interpretation.
• Global Privacy Control (GPC): We honor GPC signals as an opt-out of the sale or sharing of personal information where required by applicable law. We do not sell personal information. If our practices change in ways that require GPC recognition, we will honor qualifying signals.
• Analytics opt-out: You may opt out of Google Analytics by downloading the opt-out browser add-on at tools.google.com/dlpage/gaoptout.

See Appendix A for our Cookie Table, which we update periodically. You may also contact us at hello@separia.com for current information.

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11. MARKETING AND COMMUNICATIONS (EMAIL AND SMS)

A. Email

If you opt in, or where permitted without opt-in, we may send you emails about programs, content, and updates. You may unsubscribe at any time using the unsubscribe link in any marketing email. Transactional communications (e.g., billing notices, security alerts, policy updates) are not marketing and cannot be opted out of while your account is active.

B. SMS and Telephony

With your express written consent, we may send recurring automated text messages about your account or marketing. The following terms apply to any SMS program:

• Consent is not a condition of purchase.
• Message and data rates may apply. Message frequency varies.
• Text STOP to cancel at any time. Text HELP for assistance.
• Carriers are not liable for delayed or undelivered messages.
• You can also manage SMS preferences via your account settings or by emailing hello@separia.com with "SMS Opt-Out" in the subject line.

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12. YOUR CHOICES AND HOW TO EXERCISE YOUR RIGHTS

You may submit privacy requests by:

• Email: hello@separia.com | Subject line: Privacy Request
• Mail: Separia™, Attn: Privacy Request, c/o Aliette Hernandez Carolan, 1172 S Dixie Hwy, Suite 408, Coral Gables, Florida 33146

Specific choices available:

• Access, update, or correct: Request access to or correction of your personal information.
• Deletion: Request deletion of your account and personal information (subject to lawful exceptions). We will process confirmed deletion requests within 30 days.
• AI and automated processing: Request information about automated processing and opt out of certain processing where applicable.
• Communications preferences: Manage via email unsubscribe links or SMS STOP command.
• State-specific rights: See Section 18 for rights by state.

We will verify your request as described in Section 19 and respond within the timelines applicable to your state under Section 18.

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13. DATA RETENTION

We retain personal information only as long as necessary for the purposes described in this Policy, to comply with legal obligations, and to establish, exercise, or defend legal claims. If you cancel your membership and request deletion, we will delete your personal information within 30 days, subject to lawful exceptions (legal obligations, disputes, transaction records, and security).

AI interaction data may be retained for a limited additional period to improve feature quality, then deleted or anonymized. We may retain de-identified or aggregated data indefinitely.

See Appendix B for our data retention schedule by category.

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14. SECURITY AND INCIDENT RESPONSE

We implement reasonable and appropriate administrative, technical, and physical safeguards, including encrypted connections (HTTPS), firewalls, and access controls restricted to personnel with a legitimate business need. No system is perfectly secure; by using the Services, you understand and assume inherent risks associated with online activity.

We maintain incident response procedures. If a security breach affects your rights or freedoms as required under applicable law, we will notify you as required. We cannot control actions of other members with whom you choose to share information.

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15. SUBSCRIPTIONS AND AUTO-RENEWAL

Separia™ memberships are offered on a recurring subscription basis. Key terms:

• Recurring charges: By purchasing a membership, you authorize Separia™ to charge your payment method through Stripe on a recurring basis at the disclosed price and billing frequency until you cancel.
• Pre-purchase disclosure: Before you purchase, we will present clear and conspicuous terms including the total charges, billing frequency, and cancellation policy. Your affirmative consent is required.
• Confirmation: Following purchase, we will send an acknowledgment (e.g., by email) that includes the subscription terms, cancellation methods, and how to manage your subscription.
• Price changes: We will provide advance notice of any material change to your subscription price before it takes effect. Continued use after the effective date of a price change constitutes acceptance.
• Cancellation: You may cancel at any time via your account settings or by contacting hello@separia.com. Cancellation takes effect at the end of the current billing period. Refunds are not provided for partial periods unless required by applicable law.
• Easy cancellation: Cancellation will always be at least as easy as sign-up.

Federal auto-renewal requirements under the Restore Online Shoppers’ Confidence Act (ROSCA) and applicable state automatic renewal laws may apply to your subscription.

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16. DATA MINIMIZATION

Separia™ collects only personal data that is adequate, relevant, and reasonably necessary for the stated purposes. We apply this principle to our collection, retention, and sharing practices, including data processed through AI-powered features.

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17. EXTERNAL WEBSITES AND CROSS-BRAND SHARING

A. External Links

The Services may link to third-party websites and resources. Their practices are governed by their own policies. Separia™ is not responsible for the content or data practices of external websites. Links do not constitute an endorsement.

B. Sister Brand Disclosure

Separia™, The Quick Divorce™ (thequickdivorce.com), and aliettehcarolan.com are sister brands operated by Aliette Hernandez Carolan. We do not automatically share your personal information across brands. Any cross-brand sharing occurs only with your consent or as otherwise permitted by applicable law. Each brand's privacy notice governs the data collected through that service. You may withdraw consent for cross-brand sharing at any time by contacting hello@separia.com.

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18. YOUR U.S. STATE PRIVACY RIGHTS

Depending on your state of residence, you may have the following rights, subject to exceptions and thresholds under applicable law:

• Access / Know: Request confirmation of and access to personal information we hold, including categories, sources, purposes, and disclosures.
• Correction: Request correction of inaccurate personal information.
• Deletion: Request deletion of personal information we collected from or about you.
• Portability: Request a copy of certain personal information in a portable, readily usable, machine-readable format (e.g., CSV or JSON), delivered via secure download link or encrypted email. We will transmit data to another entity where technically feasible upon a verified request. Portability is limited to information you provided directly and information we maintain about you, and will not include information that would adversely affect the rights or freedoms of others.
• Opt out of targeted advertising: Opt out of processing personal information for targeted advertising. We do not engage in targeted advertising to members.
• Opt out of sale or sharing: We do not sell personal information. We do not share personal information for cross-context behavioral advertising. If our practices change, we will update this Policy and honor applicable opt-out rights and signals.
• Opt out of profiling / ADMT: Opt out of automated decision-making producing legal or similarly significant effects, and request human review where applicable. See Section 7.
• Sensitive data: Exercise rights related to use and disclosure of sensitive personal information, including opt-in consent where required or the right to limit use to necessary purposes.
• Non-discrimination: We will not discriminate against you for exercising any privacy rights.

How to submit a request: Use the methods in Section 12. We will respond within the applicable timeline (e.g., 45 days where required), with a permissible extension of up to 45 additional days upon notice to you.

Appeals (CO, CT, VA, and other states with appeal rights)

If we deny your request, you may appeal by replying to our decision email or by emailing hello@separia.com with "Appeal" in the subject line within 45 days of our decision. We will review and respond within 45 days (or the applicable period under your state's law) and provide a written explanation of the reasons for our decision. If your appeal is denied, we will inform you of any further options available to you, which may include contacting your state attorney general or consumer protection authority.

Global Privacy Control

We recognize GPC and similar browser-based opt-out signals as an opt-out of the sale or sharing of personal information where required and applicable to our data practices.

California Residents (CCPA / CPRA)

California residents have the following rights: Right to Know, Right to Delete, Right to Correct, Right to Opt Out of Sale or Sharing (we do not sell or share for cross-context behavioral advertising), Right to Limit Use of Sensitive Personal Information, Right Regarding Automated Decision-Making Technology (ADMT), and Right to Non-Discrimination.

Submit a "California Privacy Request" via the methods in Section 12. We will respond within 45 days, with a possible 45-day extension where reasonably necessary and with notice to you. Authorized agents may submit requests with proper written authorization; see Section 19.

California categories of personal information collected in the preceding 12 months: Identifiers (name, email, IP address, username); Commercial information (subscription history, purchases); Internet or network activity (usage data, platform interactions); Approximate geolocation (city/state from IP); Member-submitted content (journals, quizzes, posts, AI interactions); Inferences (preferences derived from the above). We have not sold or shared any of these categories for cross-context behavioral advertising in the preceding 12 months.

Nevada Residents

We do not sell personal information as defined under Nevada law. For questions, contact hello@separia.com with your full name, email address, and confirmation that you are a Nevada resident.

Shine the Light (California Civil Code § 1798.83)

California residents may request, once per year, the details of any personal information shared with a third party for that third party's direct marketing purposes during the prior calendar year. Email hello@separia.com with "Your California Privacy Rights" in the subject line, along with your full name and mailing address.

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19. VERIFICATION STANDARDS AND AUTHORIZED AGENTS

A. Verification

We verify your identity to a reasonable or high degree (depending on request sensitivity) using information associated with your account, and/or by requesting additional data elements or a signed declaration. If you maintain an account, we may require authentication through that account. If we cannot verify your identity, we will deny the request and explain why.

B. Authorized Agents

You may authorize an agent to submit a privacy request on your behalf. We require: (a) a signed written authorization from you to the agent; (b) verification of your identity; and (c) verification of the agent's identity. California residents: a power of attorney compliant with California law may satisfy requirement (a).

C. Frequency Limits

We may limit the number or frequency of requests as permitted by applicable law.

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20. HOW TO CONTACT US

For questions about this Privacy Policy, to exercise your rights, or to submit a data request:

Email: hello@separia.com | Subject line: Privacy Request
Mail: Separia™, Attn: Privacy Request
            c/o Aliette Hernandez Carolan
            1172 S Dixie Hwy, Suite 408
            Coral Gables, Florida 33146
Website: separia.com

Cross-Border Transfers

Personal information we collect is stored and processed in the United States. We may use vendors and cloud providers that process personal information in other locations. We implement appropriate contractual and technical safeguards designed to protect your information consistent with this Policy.

Vendor / Subprocessor Transparency

We maintain a current list of subprocessors and vendors that process personal information on our behalf (Appendix C). We will provide reasonable advance notice of material changes to subprocessors. Contact hello@separia.com with any questions.

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APPENDIX A: COOKIE TABLE

We use the following categories of cookies. Specific cookies in use may change; we update this table periodically. Contact hello@separia.com for current information.

Name	Provider	Purpose	Type	Duration
[INSERT]	Separia™ / Supabase	Authentication: keeps you logged in	First-party / HTTP	Session
[INSERT]	Vercel	Performance and infrastructure	First-party / HTTP	[INSERT]
[INSERT]	Analytics provider	Platform usage analytics	First or third-party	12–24 months
[INSERT]	[INSERT AI provider]	AI feature functionality	Third-party	[INSERT]

Note: Cookie names should be confirmed from your browser developer tools after launch and inserted above before publication.

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APPENDIX B: DATA RETENTION SCHEDULE

Example periods; actual periods may vary based on legal, tax, security, and operational requirements. Where ranges are shown, the shortest period consistent with obligations is applied unless otherwise required.

Category	Example Retention Period	Notes
Account information (profile, credentials)	Life of account; 30 days after confirmed deletion request	Subject to legal hold or dispute exceptions
Billing and transaction records	7 years from transaction date	May be longer if required by tax or audit law
Customer support records	2 years from last interaction
Usage logs and analytics	12–24 months, then aggregated / de-identified
AI interactions (quiz / conversational content)	Life of active account; up to 90 additional days to improve features; then deleted or de-identified
Marketing preferences and email events	While subscribed, plus 24 months after last engagement; suppression list maintained as required
Security and fraud records	As needed for investigation, plus up to 5 years, or longer if legally required
Legal holds and disputes	Duration of hold or dispute plus applicable limitation period

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APPENDIX C: SUBPROCESSORS AND VENDORS

The following categories of vendors process personal information on our behalf. This list is subject to change; we update it upon material changes. Contact hello@separia.com for the current list.

Category	Current Vendor(s)	Data Processed
Hosting and infrastructure	Supabase; Vercel	Account data, member content, platform activity
Payment processing	Stripe, Inc.	Partial transaction confirmation only (no card data stored by Separia™)
Email and communications	Kit / ConvertKit	Email address, communication preferences, engagement data
AI and machine learning	[INSERT: confirm current AI provider(s)]	Quiz responses, conversational inputs, membership stage
Analytics	Google Analytics (Google LLC)	Usage data, approximate location, device information
Professional services	[INSERT: legal, accounting, audit]	As needed for compliance and business operations

This Privacy Policy should be reviewed by qualified legal counsel before publication. It does not constitute legal advice. Separia™ is not a law firm and does not provide legal advice.