This Privacy Policy was last updated on and is effective as of July 18, 2025.
This Privacy Policy (the “Policy”) governs the collection and handling of information collected by Growth Colony, LLC d/b/a Soulgery (the “Company”, “we“, “us” or “our”) or provided by you (“you” or “your”) on or through the website and related mobile applications (collectively, the “Site”), including the Company’s SoCo app, operated by the Company.
This Policy describes:
This Policy applies only to information we collect on or through the Site. This Policy does not apply to information that we collect offline, or that you provide to or is collected by any third party (other than on our behalf), which may have their own privacy policies and that we encourage you to read before providing your information to such third parties (see “Third-Party Information Collection” below).
Please read this Policy carefully to understand our policies and practices regarding your information and how we will Process it. By using the Site, you agree to be bound by this Policy. If you do not accept the terms of this Policy, you may not access or use the Site and you should discontinue your use of it.
This Policy may change from time to time as outlined below in “Changes to Our Privacy Policy”.
We collect information from and about users of the Site in the following ways, each of which is addressed further below:
When you download, register with, access, or use the Site, we may ask you to provide information by which you may be personally identified (“personal information”), including but not limited to, your name, , postal address, email address, telephone number, payment or other financial information (including but not limited to your credit card information), identification number or other online identifier or location data.
Such information may be provided by you in the following ways:
If you provide information for publication or display (“Posted”) on areas of the Site that are accessible to other users and invite or allow you to share your thoughts, give feedback, upload images or other content or otherwise contribute to the Site, and which are marked as such, or websites you access through the Site (collectively “User Contributions”), then your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you or another Site user may choose to share your User Contributions. For these reasons, your User Contributions may be viewed by persons other than us, including persons that you have not authorized to do so.
When you download, register with, access, or use the Site, the Site may use technology to automatically collect:
For information about choices you may make with respect to the above matters, please see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below.
To help with the functioning of the Site and for other business purposes, we use information collection and tracking technologies, which may automatically track the following information:
For more information about our use of cookies and web beacons please see our Cookie Policy, which may be accessed here: https://soulgery.com/cookie-policy
Please also see “Our Use of Google Analytics” below for more information on our use of Google Analytics and its tracking functions.
Service Providers. When you use the Site, certain third parties acting as our service providers may collect information on our behalf to help us operate the Site and to accomplish other business purposes.
Payments Processing. We may use third-party services (e.g., payment processors) for payments processing for transactions done through the Site. The Company itself will not store or collect your payment card details. That information is provided directly by you to the third-party payment processors whose use of your personal information for such purposes is governed by their privacy policy. Payment processors are also required to comply with laws applicable to them in their capacity as payment processor, which include requirements about the secure handling of payment information.
Other websites. The Site may contain links to other websites and applications/apps that are not operated by us. If you click any such link, you will be directed to that third party’s site or app. We strongly advise you to review the applicable privacy policy of every site or app that you visit. We have no control over and no general responsibility for any content, privacy policies or practices of any third-party sites, apps or services that are linked from our Site.
We use a tool called “Google Analytics” to collect information about the use of the Site. Google Analytics collects information such as how often users visit or use the Site, what pages users visit when they do so, and what other sites user used prior to coming to the Site. For more information regarding how Google uses such information, please visit the following website: https://www.google.com/policies/privacy/partners/.
We use the information we get from Google Analytics to improve the Site. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is subject to and restricted by the Google Analytics Terms of Use (https://marketingplatform.google.com/about/analytics/terms/us/) and the Google Privacy Policy (https://policies.google.com/privacy). You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser. For more information on disabling cookies on your browser, please see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below or refer to our Cookie Policy.
We Process information that we collect about you or that you provide to us, including any personal information, to:
Depending on your user settings, the usage information we collect helps us to improve the Site and to deliver a better and more personalized experience by enabling us to:
We may disclose personal information that we collect or that you provide:
We may compile and disclose aggregated information and other information that does not identify any individual without restriction.
This section describes mechanisms that we provide for you to control certain (but not all) uses and disclosures of your information.
California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.
If the Site then allows such functionality, you can review and update your personal information by logging into your account on the Site. Otherwise, you may contact us to request updates to your personal information.
In some cases, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In this case, we will inform you accordingly within a reasonable time and state the reasons for our inability to change your personal information. You may appeal this decision to us by email to info@Soulgery.com, stating your reason(s) and providing any relevant documentation that you think would be helpful within thirty (30) days of our refusal to change your information.
If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Site users.
California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.
The Site is primarily intended for use by persons who are at least 18 years old and, by your use of this Site, you affirm that you are at least 18 years of age. If you are a parent or legal guardian of a child under the age of 18 and believe that your child has disclosed personal information to us without authorization, you may contact us as provided below so that we can address such matter.
California Minors
California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your California Privacy Rights” below for more information.
We may update this Policy from time to time. If we make material changes to how we Process our users’ personal information, we will post the most recent privacy policy on this page and prompt you to acknowledge that the Policy has changed or otherwise contact you to inform you about such changes. If any such change is material, we will provide a more prominent manner of notice (which may, but need not, include, by a more detailed explanatory posting on this Site or by email or other notification of the relevant changes).
The date that this Policy was last revised is identified at the top of the page.
U.S. state consumer privacy laws provide residents of certain states with additional rights regarding our use of their personal information. These rights include the following:
The meaning of “sensitive personal information” differs in each of the above states. Generally, however, sensitive personal information means information that reveals a user’s racial or ethnic background; national origin; religious beliefs; mental or physical condition or diagnosis; sexual orientation; status as transgender or nonbinary; status as a victim of crime; citizenship or immigration status; precise geolocation data; or genetic or biometric data. We do not collect any of the foregoing types of sensitive personal information without your consent.
In addition, residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia have the right to appeal any decision that we make with regard to your exercise of any of your above-noted rights.
To exercise any of the above-noted rights or to appeal any decision that we make regarding the exercise of such rights, please contact the Company by one of the methods noted in Section O “Contact Information” of this Policy.
The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of this Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). The Company adopts this California Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and their related regulations (collectively the “CCPA”) and other applicable California laws.
Overview of Consumer Rights Under the CCPA
Under the CCPA, California consumers have certain rights regarding their personal information, including:
The provisions below of this California Notice provide further details about these and other rights and certain details about the exercise of such rights.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (collectively, “personal information”). Personal information does not include:
We have collected the following categories of personal information from consumers within the last twelve (12) months:
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Category |
Examples |
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Identifiers |
An individual’s name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers |
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Personal information categories described in Cal. Civ. Code § 1798.80(e) |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information (Note: Certain of the above information may be considered to be sensitive personal information under the CCPA and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.) |
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Commercial information |
Records of personal property, Company Offerings purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
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Internet or other similar network activity |
Browsing history, search history, information on a California consumer’s interaction with our website, application, or advertisement and any social media sites from which user information is linked, connected or obtained |
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Geolocation data |
Date related to a user or device’s physical location or movements (Note: Certain precise geolocation data may be considered to be sensitive personal information under the CCPA and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.) |
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Inferences drawn from other personal information |
These include data concerning a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes, among other matters |
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Sensitive personal information |
Personal information that reveals a consumer’s Social Security, driver’s license, state identification card, or passport number; a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; a consumer’s precise geolocation; a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication; a consumer’s genetic data |
Sources of Personal Information
In addition to sources of personal information addressed elsewhere in this Policy, we obtain the categories of personal information listed above from the following categories of sources:
Uses of Personal Information
In addition to uses of personal information addressed elsewhere in this Policy, we may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
The categories of third parties to which we may disclose personal information collected by us include the following:
Sales of Personal Information
the Company does not sell personal information to third parties.
Exercising Your CCPA Rights and Choices
The sections below describe how you may exercise your rights under the CCPA.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights” below), we will disclose to you:
As allowed by the CCPA, we do not provide these access and data portability rights for business-to-business personal information.
Deletion and Correction Request Rights.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, Deletion and Correction Rights” below), we will delete (and direct our service providers to delete) your personal information from our (and service provider) records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
As allowed by the CCPA, we do not provide these deletion rights for business-to-business personal information.
In addition, if you provide us with a verifiable consumer request to correct inaccurate personal information that we maintain about you, we will use commercially reasonable efforts to correct such information in accordance with your instructions.
Exercising Access, Data Portability, Deletion and Correction Rights.
To exercise the access, data portability, deletion and correction rights described above, you should submit a verifiable consumer request to us by one of the methods outlined below in Section O “Contact Information”.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of a minor child for whom you are a parent or legal guardian.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information involved with the request relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we will consider requests made through a password-protected online account that you maintain with us to be sufficiently verified when the request relates to personal information associated with that online account, provided such online account functionality is then made available by us on the Site.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an online account with us, we may deliver our written response to that online account, provided that such online account functionality is then made available by us on the Site. If you do not have an online account with us, or such functionality is not available for your online account we will deliver our written response by mail or electronically, at your option.
If we’re unable to comply with your request, the response we provide will also explain the reasons we cannot comply with the request. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA or other applicable law, we will not as a result of you exercising any of your rights under the CCPA:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Retention of Personal Information
Our policy is to retain personal information only for as long as is necessary to fulfill the reason for which the personal information was collected and as necessary to process such personal information. In addition to the above, we will retain your personal information for the purposes of satisfying any professional, legal, accounting or reporting requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we collected and processed your personal information and whether we can reasonably achieve those purposes through other means, as well as any applicable legal and professional requirements.
Other California Privacy-Related Disclosures
Sharing Personal Information for Direct Marketing Purposes. Before sharing personal information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.
California Do-Not-Track Disclosure. At this time, the Site is not set up to honor web browser do-not-track settings. Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.
Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by one of the methods noted below in Section O “Contact Information”.
Content Removal Requests for Site Users Under 18 Years Old. If you are a Site user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the Site. You may send us any such requests by one of the methods outlined below in Section O “Contact Information”. We will review the request and respond promptly. You should be aware that a request to remove content or information posted by you on the Site does not ensure or require complete or comprehensive removal of such content or information from our databases.
Complaints
If you have any complaint about use of the Site, you may contact us by one of the methods outlined below in Section O “Contact Information”. In accordance with California Civil Code Section 1789.3, California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210.
Changes to Our California Notice
We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will post the updated California Notice on the Site and update the California Notice’s effective date. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.
Persons who are residents of any of the member countries of the European Union (“EU”), residents of the United Kingdom (the “UK”) or are other data subjects covered by either the EU’s General Data Protection Regulation, (EU) 2016/679 (the “EU GDPR”) or the United Kingdom GDPR (the “UK GDPR”, and collectively with the EU GDPR, the “GDPR”) have certain additional privacy rights under applicable law. The following provisions of this Privacy Policy provide an overview of these additional rights.
Legal Bases for Processing Personal Information
When processing your personal information, the Company may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:
Disclosures to Third Parties
Your personal information will not be disclosed to third parties except for where it is necessary for fulfillment of the Company’s obligations to you or where the Company is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement the Company may have with you), or where the Company makes disclosures that are otherwise consistent with the uses described in this Policy.
The Company may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.
The Company reserves the right to transfer any personal information the Company has about you in the event the Company sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, the Company will use reasonable efforts seeking to require that the transferee uses personal information you have provided to the Company in a manner that is consistent with this Policy.
We will not sell, resell or lease your personal information to any third parties but the Company may, if required for the purpose(s) for which your personal information was collected and processed, share it with the Company partners and/or service providers to enable them to provide their services to the Company or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.
Security of Personal Information of EU and UK Residents
The Company has policies and technical and organizational measures in place which are intended to help safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although the Company will use reasonable efforts to protect your personal information, the Company does not warrant the security of personal information transmitted to the Company or stored by the Company, and personal information that is transmitted to the Company by you electronically is done at your own risk.
Retention of Personal Information of EU and UK Residents
Our policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which the Company collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which the Company is subject. To determine the appropriate retention period for personal information, the Company considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which the Company collected and processed your personal information and whether the Company can achieve those purposes through other means, and any applicable legal and professional requirements.
International Data Transfers
See Section N “International Data Transfers and Use of Third Parties” below, of this Policy for information concerning international transfers of personal information.
Your Rights as an EU or UK Resident
Yas a resident of the EU or the UK you have a number of rights concerning your personal information that the Company holds and uses, including the following:
You may exercise any of the above requests in writing to us by one of the methods outlined below in Section O “Contact Information”. You are also free at any time to request that we stop using your personal information for marketing purposes by writing to by one of the methods outlined below in Section O “Contact Information”.
The following section (the “Canada Addendum”) applies solely to individuals who are located in Canada. If you are accessing the Site from Canada, you have rights under Canadian federal and provincial privacy laws including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Alberta Personal Information Protection Act, the British Columbia Personal Information Protection Act, and Quebec’s Act respecting the protection of personal information in the private sector.
This Canada Addendum supplements the information contained in the Policy for data collected, used, and disclosed about individuals located in Canada. The other provisions of the Policy continue to apply except as modified in this Canada Addendum.
Please review this Canada Addendum and the entire Policy and make sure you understand and agree with its terms. In case of conflict between this Canada Addendum and the Policy, this Canada Addendum governs.
If you are a Canadian resident, we will only collect, use, and disclose your personal information if we have your consent, or as otherwise permitted or required by law. By using the Site you are providing your consent for your information to be collected, used, and disclosed in accordance with this Policy.
Your Choices
Where you have consented to receive marketing or general informational communications from us, you can always unsubscribe by using the link in the email you receive from us. You also have choices with respect to cookies and other tracking technologies. Please refer to our Cookie Policy.
You may also remove your consent for any use, collection, or disclosure of personal information by contacting use by one of the methods outlined below in Section O “Contact Information”. However, removal of such consent may prevent us from delivering certain Company Offerings to you.
International Data Transfers
See Section N “International Data Transfers and Use of Third Parties” below, of this Policy for information concerning international transfers of personal information.
Your Rights: Access, Correction, and Challenging Compliance
Under Canadian law, you have the right to request access to your information and that information we hold about you is correct. You also have the right to challenge compliance with this policy. Should you have any questions or concerns, would like to access or update your information, or if you would like any additional information about our privacy practices, please contact us at info@Soulgery.com.
While we will strive to address any concerns you have, you may also contact or file a complaint with the Office of the Privacy Commissioner of Canada by calling toll free to 1-800-282-1376.
Your personal information that is being collected by us may be transferred for further processing, access and storage to the United Kingdom as well as in the United States. When processed in the UK, your data will be subject to the laws of the UK and afforded protection under UK data protection law. The UK’s data protection standards are deemed to offer “adequate” protection under EU data protection law. When processed in the United States, your data will be subject to US federal and state law, as well as potential access by local law enforcement.
As further detailed in the Policy, we may from time to time use third parties for some of our data processing activities. Whenever we use third parties to process personal information on our behalf, including with international data transfers to or from such third parties, we use contractual and other means to ensure that your personal information is protected in accordance with applicable legal requirements.
To contact us about any of the matters addressed in this Policy, including to exercise any of your rights, to ask questions or to provide comments about this Policy and our privacy practices, you may contact us as follows:
