Frey & Co Holdings LLC – Privacy Policy

Effective Date: November 21, 2025

This Privacy Policy explains how Frey & Co Holdings LLC (“Company”, “we”, “our”, “us”) collects, uses, and protects personal information when you access our websites, landing pages, products, services, and digital assets (“Services”).

By using our Services, you acknowledge and agree to the practices outlined below.

1. Information We Collect

We may collect the following types of information:

Personal identification data (e.g. name, email address, phone number)

Business-related information you voluntarily provide

Payment and billing information

Usage data and analytics from website interaction, marketing pixels, ads, and cookies

Communication responses (email opens, webinar attendance, support messages)

2. Revenue Data Collection (FTC Compliant)

We may collect self-reported monthly revenue or performance data from clients who voluntarily submit this information.

This optional data may be used for:

Tracking progress and internal performance analysis
Generating aggregate, anonymized data reports
Creating testimonials and case studies (only with explicit permission)
Improving our coaching strategy, marketing, and customer experience

Voluntary Submission Only
Submitting revenue data is not required. Clients who choose to share such data may perform above average. As a result, the data may reflect selection bias, meaning outcomes shared may not represent typical results.

Use & Protection

Individual revenue data will not be shared publicly or with third parties without your explicit written permission

Any use of revenue figures in marketing or testimonials must be reviewed and approved by you

You may request modification or removal at any time

3. How We Use Personal Information

We may process data to:

Provide, operate, and improve our Services

Process payments and send billing communications

Send updates, reminders, and marketing communications

Analyze user experience and optimize campaign performance

Generate educational content and client improvement strategies

Comply with legal, financial, and regulatory obligations

We do not sell personal data.

4. Communications

By providing contact information, you consent to receive relevant updates, transactional notifications, and educational or promotional messages via email, SMS, and digital platforms.
You may unsubscribe at any time using the provided opt-out instructions. Opt-outs do not affect essential transactional or account-related communications.

5. Cookies & Tracking Technologies

We use cookies, analytics tools, and advertising pixels (e.g. Meta, Google) to:

Measure website performance and user engagement

Serve relevant advertising and retargeting

Improve user experience and functionality

You may disable cookies via your browser settings, but some features may not function properly.

6. Legal Basis for Processing (FTC, GDPR, and Similar Standards)

Where legally applicable, we process personal data based on:

Legitimate business interests (e.g. providing services, performance optimization)

Contractual necessity (processing purchases or program access)

User consent (when required, e.g. marketing opt-in or testimonial approval)

Legal compliance

7. Data Protection

We use commercially reasonable technical and organizational measures to safeguard your data. However, no online transmission or digital system is 100% secure.
By using our Services, you acknowledge and accept such inherent risks.

8. Data Sharing

We may share data with carefully selected third-party service providers (e.g., payment processors, CRM platforms, email automation tools) solely to support operations.
We do not sell personal data to third parties.

9. Data Retention

We retain your information as long as necessary to deliver Services, comply with legal obligations, or maintain business records.
You may request deletion unless data is legally required to be retained.

10. Your Rights

Where legally applicable, you may request to:

Access, update, or correct your data

Delete your data (unless required for legal or business purposes)

Withdraw marketing or data consent

Object to or restrict processing

Request removal from case studies or testimonials

Submit all requests via hello@successschool.io

11. International Access

If accessing our Services from outside the United States, you consent to the transfer and processing of your information in jurisdictions where we and our service providers operate.

12. Updates to Privacy Policy

We may revise this policy periodically. Updates are effective upon posting. Continued use of the Services indicates acceptance of any changes.

13. Contact

For privacy-related questions or data requests, contact:
📩 hello@successschool.io