Effective date: May 07, 2019

Kalakay Fitness Systems LLC ("us", "we", or "our") operates the

http://trulifenutritioncoaching.com website (hereinafter referred to as the

"Service").

This page informs you of our policies regarding the collection, use and

disclosure of personal data when you use our Service and the choices you have

associated with that data.

We use your data to provide and improve the Service. By using the Service, you

agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, the terms used in this

Privacy Policy have the same meanings as in our Terms and Conditions,

accessible from http://trulifenutritioncoaching.com

Definitions

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* Service

Service is the http://trulifenutritioncoaching.com website operated by

Kalakay Fitness Systems LLC

* Personal Data

Personal Data means data about a living individual who can be identified

from those data (or from those and other information either in our

possession or likely to come into our possession).

* Usage Data

Usage Data is data collected automatically either generated by the use of

the Service or from the Service infrastructure itself (for example, the

duration of a page visit).

* Cookies

Cookies are small files stored on your device (computer or mobile

device).

* Data Controller

Data Controller means the natural or legal person who (either alone or

jointly or in common with other persons) determines the purposes for

which and the manner in which any personal information are, or are to be,

processed.

For the purpose of this Privacy Policy, we are a Data Controller of your

Personal Data.

* Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person

who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process

your data more effectively.

* Data Subject (or User)

Data Subject is any living individual who is using our Service and is the

subject of Personal Data.

Information Collection and Use

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We collect several different types of information for various purposes to

provide and improve our Service to you.

Types of Data Collected

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Personal Data

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While using our Service, we may ask you to provide us with certain personally

identifiable information that can be used to contact or identify you

("Personal Data"). Personally identifiable information may include, but is not

limited to:

* Email address

* First name and last name

* Phone number

* Address, State, Province, ZIP/Postal code, City

* Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or

promotional materials and other information that may be of interest to you.

You may opt out of receiving any, or all, of these communications from us by

following the unsubscribe link or the instructions provided in any email we

send.

Usage Data

**********

We may also collect information on how the Service is accessed and used

("Usage Data"). This Usage Data may include information such as your

computer's Internet Protocol address (e.g. IP address), browser type, browser

version, the pages of our Service that you visit, the time and date of your

visit, the time spent on those pages, unique device identifiers and other

diagnostic data.

Tracking & Cookies Data

************

We use cookies and similar tracking technologies to track the activity on our

Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous

unique identifier. Cookies are sent to your browser from a website and stored

on your device. Other tracking technologies are also used such as beacons,

tags and scripts to collect and track information and to improve and analyze

our Service.

You can instruct your browser to refuse all cookies or to indicate when a

cookie is being sent. However, if you do not accept cookies, you may not be

able to use some portions of our Service.

Examples of Cookies we use:

* Session Cookies. We use Session Cookies to operate our Service.

* Preference Cookies. We use Preference Cookies to remember your preferences

and various settings.

* Security Cookies. We use Security Cookies for security purposes.

Use of Data

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Kalakay Fitness Systems LLC uses the collected data for various purposes:

* To provide and maintain our Service

* To notify you about changes to our Service

* To allow you to participate in interactive features of our Service when

you choose to do so

* To provide customer support

* To gather analysis or valuable information so that we can improve our

Service

* To monitor the usage of our Service

* To detect, prevent and address technical issues

* To provide you with news, special offers and general information about

other goods, services and events which we offer that are similar to those

that you have already purchased or enquired about unless you have opted

not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection

Regulation (GDPR)

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If you are from the European Economic Area (EEA), Kalakay Fitness Systems LLC

legal basis for collecting and using the personal information described in

this Privacy Policy depends on the Personal Data we collect and the specific

context in which we collect it.

Kalakay Fitness Systems LLC may process your Personal Data because:

* We need to perform a contract with you

* You have given us permission to do so

* The processing is in our legitimate interests and it is not overridden by

your rights

* For payment processing purposes

* To comply with the law

Retention of Data

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Kalakay Fitness Systems LLC will retain your Personal Data only for as long as

is necessary for the purposes set out in this Privacy Policy. We will retain

and use your Personal Data to the extent necessary to comply with our legal

obligations (for example, if we are required to retain your data to comply

with applicable laws), resolve disputes and enforce our legal agreements and

policies.

Kalakay Fitness Systems LLC will also retain Usage Data for internal analysis

purposes. Usage Data is generally retained for a shorter period of time,

except when this data is used to strengthen the security or to improve the

functionality of our Service, or we are legally obligated to retain this data

for longer periods.

Transfer of Data

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Your information, including Personal Data, may be transferred to — and

maintained on — computers located outside of your state, province, country or

other governmental jurisdiction where the data protection laws may differ from

those of your jurisdiction.

If you are located outside United States and choose to provide information to

us, please note that we transfer the data, including Personal Data, to United

States and process it there.

Your consent to this Privacy Policy followed by your submission of such

information represents your agreement to that transfer.

Kalakay Fitness Systems LLC will take all the steps reasonably necessary to

ensure that your data is treated securely and in accordance with this Privacy

Policy and no transfer of your Personal Data will take place to an

organization or a country unless there are adequate controls in place

including the security of your data and other personal information.

Disclosure of Data

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Business Transaction

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If Kalakay Fitness Systems LLC is involved in a merger, acquisition or asset

sale, your Personal Data may be transferred. We will provide notice before

your Personal Data is transferred and becomes subject to a different Privacy

Policy.

Legal Requirements

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Kalakay Fitness Systems LLC may disclose your Personal Data in the good faith

belief that such action is necessary to:

* To comply with a legal obligation

* To protect and defend the rights or property of TruLife Nutrition Coaching

* To prevent or investigate possible wrongdoing in connection with the

Service

* To protect the personal safety of users of the Service or the public

* To protect against legal liability

Security of Data

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The security of your data is important to us but remember that no method of

transmission over the Internet or method of electronic storage is 100% secure.

While we strive to use commercially acceptable means to protect your Personal

Data, we cannot guarantee its absolute security.

Our Policy on "Do Not Track" Signals under the California Online Protection

Act (CalOPPA)

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We do not support Do Not Track ("DNT"). Do Not Track is a preference you can

set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings

page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation

(GDPR)

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If you are a resident of the European Economic Area (EEA), you have certain

data protection rights. Kalakay Fitness Systems LLC aims to take reasonable

steps to allow you to correct, amend, delete or limit the use of your Personal

Data.

If you wish to be informed about what Personal Data we hold about you and if

you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

* The right to access, update or delete the information we have on you.

Whenever made possible, you can access, update or request deletion of your

Personal Data directly within your account settings section. If you are

unable to perform these actions yourself, please contact us to assist you.

* The right of rectification. You have the right to have your information

rectified if that information is inaccurate or incomplete.

* The right to object. You have the right to object to our processing of

your Personal Data.

* The right of restriction. You have the right to request that we restrict

the processing of your personal information.

* The right to data portability. You have the right to be provided with a

copy of the information we have on you in a structured, machine-readable

and commonly used format.

* The right to withdraw consent. You also have the right to withdraw your

consent at any time where Kalakay Fitness Systems LLC relied on your

consent to process your personal information.

Please note that we may ask you to verify your identity before responding to

such requests.

You have the right to complain to a Data Protection Authority about our

collection and use of your Personal Data. For more information, please contact

your local data protection authority in the European Economic Area (EEA).

Service Providers

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We may employ third party companies and individuals to facilitate our Service

("Service Providers"), provide the Service on our behalf, perform Service-

related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these

tasks on our behalf and are obligated not to disclose or use it for any other

purpose.

Behavioral Remarketing

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Kalakay Fitness Systems LLC uses remarketing services to advertise on third

party websites to you after you visited our Service. We and our third-party

vendors use cookies to inform, optimize and serve ads based on your past

visits to our Service.

* Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by

visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions

from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural

Advertising established by the Digital Advertising Alliance. You can also

opt-out from Facebook and other participating companies through the

Digital Advertising Alliance in the USA, the Digital Advertising Alliance of

Canada in Canada or the European Interactive

Digital Advertising Alliance in Europe,

or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit

Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

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We may provide paid products and/or services within the Service. In that case,

we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is

provided directly to our third-party payment processors whose use of your

personal information is governed by their Privacy Policy. These payment

processors adhere to the standards set by PCI-DSS as managed by the PCI

Security Standards Council, which is a joint effort of brands like Visa,

MasterCard, American Express and Discover. PCI-DSS requirements help ensure

the secure handling of payment information.

The payment processors we work with are:

* Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Links to Other Sites

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Our Service may contain links to other sites that are not operated by us. If

you click a third party link, you will be directed to that third party's site.

We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.

Children's Privacy

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Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone

under the age of 18. If you are a parent or guardian and you are aware that

your Child has provided us with Personal Data, please contact us. If we become

aware that we have collected Personal Data from children without verification

of parental consent, we take steps to remove that information from our

servers.

Changes to This Privacy Policy

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We may update our Privacy Policy from time to time. We will notify you of any

changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior

to the change becoming effective and update the "effective date" at the top of

this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

Contact Us

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If you have any questions about this Privacy Policy, please contact us:

* By email: support@trulifenutritioncoaching.com