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PRIVACY POLICY

Effective Date: February 5, 2026
Last Updated: February 5, 2026

INTRODUCTION

Your privacy is important to us. Mood Pop, Inc. and its current and future shareholders (including, without limitation, Cynthia Occelli), affiliates, parent companies and subsidiaries (“we,” “us,” or “Mood Pop”) are strongly committed to protecting your privacy and providing a safe online experience for all of our users while offering the highest quality user experience.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you:

The Sites, App, and Services may hereinafter be collectively referred to as the “Sites and/or Services” or “Platforms.”

By using our Sites, App, and/or Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Sites, App, and/or Services.

What is Personal Information?

Personal information is any information about you that can be used to identify you. This includes information about you as a person (such as name, address, email address, phone number, and date of birth), your devices, payment details, and information about how you use our Sites, App, and/or Services.

Third-Party Sites and Services

Our Sites, App, and/or Services may contain links to third-party websites, services, and applications. Please be aware that we do not control these third parties and this Privacy Policy does not apply to them. Each third party has its own privacy policy, which you should read carefully before providing any personal information. We are not responsible for the privacy practices of third-party sites and services.

TABLE OF CONTENTS

  1. Information We Collect
  2. How We Collect Information
  3. How We Use Your Information
  4. How We Share Your Information
  5. Cookies and Tracking Technologies
  6. Your Privacy Rights and Choices
  7. Data Security
  8. Data Retention
  9. Children’s Privacy
  10. International Data Transfers
  11. State-Specific Privacy Rights
  12. Changes to This Privacy Policy
  13. Contact Us

1. INFORMATION WE COLLECT

We collect information that falls into two categories: “voluntarily provided” information and “automatically collected” information.

1.1 Information You Provide to Us (Voluntarily Provided)

“Voluntarily provided” information refers to any information you knowingly and actively provide to us when using or participating in our Sites, App, and/or Services. We may collect the following categories of personal information that you provide directly to us:

Identifiers and Contact Information:

  • Full name
  • Email address
  • Mailing address
  • Phone number and/or mobile number
  • Account username and password
  • Social media profile information (if you connect your account)

Commercial Information:

  • Products or services purchased, obtained, or considered
  • Purchasing or consuming histories or tendencies
  • Payment information (credit card number, billing address)

Account Information:

  • Registration details
  • Profile information
  • Account preferences and settings
  • Communication preferences

Communications and Inquiries:

  • Information you provide when you contact us for help, support, or customer service
  • Feedback, questions, comments, or suggestions you submit
  • Survey or questionnaire responses

User-Generated Content:

  • Reviews, testimonials, and ratings
  • Comments, forum posts, or messages
  • Photos, videos, or other content you submit
  • Stories or personal experiences you share

You can choose not to provide certain information, but this may limit your ability to use certain features or Services.

1.2 Information Collected Automatically

“Automatically collected” information refers to any information automatically sent by your devices when you access our Sites, App, and/or Services. We may automatically collect:

Log Data:

  • Internet Protocol (IP) address
  • Browser type and version (for websites)
  • Operating system
  • Pages you visit on our Sites or screens you view in our App
  • Time and date of your visit or app usage
  • Time spent on each page or in the App
  • Referring website addresses
  • Search terms used to find our Sites
  • Click-stream data
  • App activity and usage patterns

Device Data:

  • Device type (computer, smartphone, tablet)
  • Device identifier or unique device ID
  • Operating system and version
  • Mobile network information
  • Device settings
  • Device manufacturer and model

App-Specific Data (When You Use The Inside Passage App):

  • Your device’s in-built tools data (with your permission):
    • Device/app history
    • Identity information (as permitted)
  • App performance data
  • Crash reports and error logs
  • App feature usage
  • In-app activity and navigation patterns
  • App version and updates

Technical and Usage Data:

  • Information about how you interact with our Sites, App, and/or Services
  • Features you use and frequency of use
  • Error logs and diagnostic reports
  • Performance data

Location Information:

  • General geographic location based on IP address
  • Precise location (only if you grant permission on mobile devices or in the App)

Cookies and Similar Technologies:

  • Information collected through cookies, web beacons, pixels, and similar tracking technologies
  • For the App: cookies and similar data stored on your device
  • See Section 5 for detailed information about cookies

Please be aware that while some of this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify you.

1.3 Information from Third-Party Sources

We may receive information about you from third-party sources, including:

Service Providers:

  • Payment processors (transaction information)
  • Analytics providers (usage statistics)
  • Marketing platforms (campaign performance)

Social Media Platforms:

  • Information from your social media accounts if you connect them to our Services or App
  • Public profile information if you interact with us on social media
  • Social media profile data you consent to share

Data Brokers and Aggregators:

  • Demographic information
  • Interest categories
  • Marketing insights

Publicly Available Sources:

  • Public records
  • Information you make publicly available online

If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about someone else, you represent and warrant that you have that person’s consent to provide their information to us.

2. HOW WE COLLECT INFORMATION

We collect personal information when you:

On Our Websites:

  • Visit or navigate our Sites
  • Register for an account on any of our Sites
  • Sign up to receive updates via email, text, or social media
  • Subscribe to our Services or enroll in our programs
  • Make a purchase or payment
  • Post a comment, review, testimonial, or otherwise participate in our online community
  • Use a web browser to access our content
  • Contact us via email, social media, or contact forms
  • Participate in surveys, questionnaires, or research
  • Attend our events, webinars, or workshops
  • Interact with our advertisements
  • Mention us on social media
  • Use interactive features of our Sites (chat, forums, message boards)

Through Our App (The Inside Passage):

  • Download and install the App
  • Create an account in the App
  • Use the App’s features and services
  • Grant permissions for device access
  • Make in-app purchases
  • Submit content through the App
  • Contact us through the App
  • Interact with push notifications
  • Use the App to access our content

General:

  • Apply for a job or partnership opportunity
  • Otherwise communicate with us or provide information to us

3. HOW WE USE YOUR INFORMATION

3.1 Purposes for Using Your Information

We collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner incompatible with these purposes:

To Provide Our Services:

  • Deliver our Sites, App, and/or Services to you
  • Create and manage your account
  • Process your transactions and send related information (confirmations, receipts, invoices)
  • Provide customer service and respond to your requests
  • Enable you to access and use our features
  • Customize or personalize your experience of our Sites, App, and/or Services
  • Send you technical notices, updates, security alerts, and support messages
  • Deliver products and/or services to you

For Business Operations:

  • Conduct analytics, market research, and business development
  • Operate and improve our Sites, App, and/or Services
  • Develop new products, services, and features
  • Monitor and analyze usage patterns and trends
  • Conduct internal record keeping and administrative purposes
  • Perform accounting, auditing, and other internal functions
  • Comply with legal obligations and resolve disputes
  • Technical assessment to improve our App and associated applications

For Marketing and Communications:

  • Send you newsletters, promotional materials, and special offers
  • Deliver targeted advertising and marketing communications tailored to your interests
  • Conduct promotional activities, contests, and surveys
  • Provide you with information about products or services we believe may interest you
  • Provide you with information about third-party products and services that may interest you
  • Measure and analyze the effectiveness of our marketing campaigns
  • Serve advertising within the App

For Security and Legal Compliance:

  • Protect the security and integrity of our Sites, App, and/or Services
  • Detect, prevent, and address fraud, security issues, and illegal activities
  • Enforce our Terms of Service and other policies
  • Comply with applicable laws, regulations, and legal processes
  • Respond to lawful requests from public authorities
  • Protect our rights, property, or safety and that of our users and the public
  • Establish, exercise, or defend legal claims
  • Ensure Sites and App are safe, secure, and used in line with our terms of use

3.2 Legal Basis for Processing (For EU/EEA Residents)

If you are located in the European Union or European Economic Area, we process your personal information based on the following legal grounds:

  • Consent: Where you have given us explicit consent to process your information for specific purposes (including App permissions you grant)
  • Contract: Where processing is necessary to perform a contract with you or take steps at your request before entering into a contract
  • Legal Obligation: Where we need to comply with legal or regulatory obligations
  • Legitimate Interests: Where processing is necessary for our legitimate business interests or those of a third party, provided your interests and fundamental rights do not override those interests

3.3 Combining Information

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources, including:

  • Market research and analytics data
  • Demographic information from third-party sources
  • Data about how visitors use our Sites or App from analytics services
  • Information from social media platforms (if you consent to share your social media profiles)
  • Public records and publicly available information

This helps us improve our Sites, App, and/or Services and provide you with a better, more personalized experience.

4. HOW WE SHARE YOUR INFORMATION

4.1 Third Parties We Share With

We may disclose personal information to the following categories of third parties:

Service Providers and Business Partners: We share information with third-party service providers who perform services on our behalf, including:

  • IT service providers, data storage, web hosting, and server providers
  • Payment systems operators and payment processors, specifically:
    • PayPal
    • Stripe
    • Google Payments
    • Apple Pay
    • Authorize.net
  • Email service providers and marketing platforms, specifically:
    • Kit
    • Brevo
  • Customer relationship management (CRM) platforms
  • Analytics and data analysis providers
  • Error logging and diagnostic services
  • Maintenance and problem-solving providers
  • Security and fraud prevention services
  • Professional advisors (lawyers, accountants, auditors, consultants)
  • Debt collectors (if applicable)
  • App store providers (Apple App Store, Google Play Store)

Corporate Affiliates:

  • Parent companies, subsidiaries, and affiliated entities
  • Current and future shareholders

Business Transfer Recipients:

  • Potential buyers, investors, or other parties in connection with a business transaction such as a merger, acquisition, bankruptcy, dissolution, reorganization, sale of assets, or similar event
  • We may transfer your information if we or substantially all of our assets are acquired by a third party

Legal and Regulatory Authorities:

  • Courts, tribunals, and regulatory authorities as required by law
  • Law enforcement officers and agencies
  • Government entities
  • Credit reporting agencies (in the event of payment default)

Marketing and Advertising Partners:

  • Advertising networks and platforms
  • Social media companies for targeted advertising
  • Marketing agencies and service providers
  • Third parties who assist us in providing direct marketing to you

With Your Consent:

  • Other third parties when you have given us permission to share your information
  • Third parties to collect and process data (with your permission)

4.2 Purposes for Sharing

We share information for the following purposes:

  • To enable third parties to provide their services to us or on our behalf
  • To enable payment processing for purchases made on our Sites or in our App
  • To comply with legal obligations and respond to legal requests
  • To protect and defend our rights, property, or safety
  • To prevent fraud and enhance security
  • To facilitate business transactions
  • For marketing and advertising purposes
  • With your explicit consent

4.3 Data Sharing Limitations

All companies working for and with us must:

  • Comply with our privacy and security requirements
  • Use your information only as authorized by us and you
  • Implement appropriate security safeguards
  • Not sell your information to other third parties (except as authorized or required by law)

We do not sell your personal information for monetary consideration. However, we may share information with third parties for targeted advertising purposes, which may be considered a “sale” or “sharing” under certain state privacy laws (see Section 11).

4.4 Public Information

Please remember that any information you disclose in public areas of our Sites, App, and/or Services becomes public information:

  • Forum posts and comments
  • Community discussions
  • Reviews and testimonials
  • Social media interactions
  • Chat rooms and message boards
  • Public profiles in the App

You should exercise caution when deciding to disclose personally identifiable information in these areas. This information can be read, collected, or used by others with or without your knowledge or permission.

4.5 Information Shared for Legal Reasons

We reserve the right to use or disclose any information without notice or consent when necessary to:

  • Satisfy any law, regulation, legal process, or governmental request
  • Conduct investigations of consumer complaints or possible breaches of law
  • Enforce our Terms of Service, this Privacy Policy, or other agreements
  • Protect the integrity, security, and safety of our Sites, App, and/or Services
  • Protect our property, rights, and interests
  • Protect the safety and security of our users or the public
  • Respond to claims of third-party rights violations
  • Cooperate in any legal investigation or proceeding
  • Establish, exercise, or defend our legal rights

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 What Are Cookies?

Cookies are small text files that websites and apps place on your device to store information about your preferences and activities. We use cookies and similar tracking technologies to enhance your experience on our Sites, in our App, and when using our Services.

5.2 Types of Cookies and Tracking Technologies We Use

Essential Cookies:

  • Required for the Sites and App to function properly
  • Enable core features like security, network management, and accessibility
  • Allow the App servers to recognize your device when you use the App
  • Store information about your account, session, and/or device
  • Cannot be turned off without affecting functionality

Analytics and Performance Cookies:

  • Help us understand how visitors use our Sites and App
  • Collect information about page visits, screen views, traffic sources, and user behavior
  • Track App usage and performance on your device
  • Allow us to improve our Sites, App, and Services

Functionality Cookies:

  • Remember your preferences and settings
  • Provide enhanced, personalized features
  • Remember your login information
  • Store your language and regional preferences
  • Tailor your experience of our App based on your preferences

Marketing and Advertising Cookies:

  • Track your browsing activity across websites and apps
  • Enable us to deliver targeted advertisements
  • Serve advertising to your device both in the App and on other platforms
  • Measure the effectiveness of our advertising campaigns
  • Limit the number of times you see an advertisement

Third-Party Cookies:

  • Placed by third-party services we use (analytics, advertising, social media)
  • Subject to the third party’s privacy policy

5.3 Similar Technologies

Web Beacons (Pixels):

  • Small electronic images embedded in web pages and emails
  • Help us track whether you’ve opened an email or visited a page
  • Work in conjunction with cookies

Local Storage:

  • Allows websites and apps to store data locally on your device
  • Similar to cookies but can store larger amounts of data
  • Used in the App to improve performance and functionality

SDKs and APIs:

  • Software development tools that enable third-party functionality in the App
  • May collect information about your device and usage

Mobile Identifiers:

  • Device advertising identifiers (IDFA for iOS, AAID for Android)
  • Used for targeted advertising and analytics

5.4 Your Cookie Choices

For Websites – Browser Controls: You can control and manage cookies through your browser settings:

  • Accept All Cookies: Default setting for most browsers
  • Reject All Cookies: May limit functionality of our Sites
  • Delete Cookies: Remove existing cookies from your device
  • Block Third-Party Cookies: Prevent tracking by external parties

Most browsers allow you to:

  • See what cookies have been set
  • Delete cookies individually or all at once
  • Block cookies from being set
  • Set preferences for certain websites

Your ability to limit cookies is based on your browser’s capabilities. Please refer to your browser’s help documentation for specific instructions.

For Mobile App – Device Settings: Mobile devices offer controls for app tracking and cookies:

  • iOS: Settings > Privacy > Tracking (toggle off “Allow Apps to Request to Track”)
  • iOS Advertising: Settings > Privacy > Advertising > Limit Ad Tracking
  • Android: Settings > Google > Ads > Opt out of Ads Personalization
  • Android App Permissions: Settings > Apps > The Inside Passage > Permissions

Impact of Disabling Cookies: If you disable cookies:

  • You can still view our Sites and use our App, but some features may not work properly
  • Advanced and customized features will not be available
  • You may need to manually enter information each visit
  • Your user experience may be less personalized
  • Some App features may not function correctly

5.5 Cookie Policy

For more detailed information about our use of cookies, including a complete list of cookies we use, please refer to our Cookie Policy or contact us using the information in Section 13.

5.6 Do Not Track

“Do Not Track” (DNT) is a privacy preference you can set in your web browser that signals to websites that you do not want to be tracked.

Our Response to Do Not Track Signals: At this time, we do not respond to or alter our practices when we receive DNT signals from browsers. We adhere to the standards outlined in this Privacy Policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

We will continue to monitor developments around DNT browser technology and privacy regulations that may require us to respond to DNT signals.

6. YOUR PRIVACY RIGHTS AND CHOICES

6.1 General Rights

You have the following rights regarding your personal information:

Right to Access: You may request details of the personal information we hold about you, including:

  • Categories of information we collect
  • Sources from which we collected information
  • Purposes for collecting and using information
  • Categories of third parties with whom we share information

Right to Correction: If you believe any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, you may request that we correct it. We will take reasonable steps to correct information found to be inaccurate, incomplete, misleading, or out of date.

Right to Deletion: You may request that we delete your personal information, subject to certain exceptions required or permitted by law. This includes:

  • Data stored through our websites
  • Data stored in our App
  • Your account information

Right to Opt-Out: You may opt out of:

  • Marketing and promotional communications (email, SMS, push notifications)
  • Sale or sharing of your personal information (see state-specific rights)
  • Targeted advertising based on your information
  • App tracking (through device settings)

Right to Restrict Processing: You may request that we limit how we use your information in certain circumstances.

Right to Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format (where technically feasible).

Right to Object: You may object to our processing of your information for certain purposes, including direct marketing.

Right to Manage App Permissions: You can control the permissions you grant to our App at any time through your device settings, including:

  • Access to device data
  • Location services
  • Camera and photo library
  • Notifications
  • Background app refresh

Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, including by:

  • Denying you goods or services
  • Charging you different prices or rates for goods or services
  • Providing you with a different level or quality of goods or services
  • Suggesting that you will receive a different price, rate, level, or quality of goods or services

Exception: We may offer financial incentives permitted by law that can result in different prices, rates, or quality levels. Any such offer will reasonably relate to the value of your personal information and will include written terms. Participation requires your prior opt-in consent, which you may revoke at any time.

6.2 How to Exercise Your Rights

To exercise any of these rights, please contact us using the contact information in Section 13.

When Submitting a Request:

  • Clearly describe the right you wish to exercise
  • Provide sufficient information for us to verify your identity
  • Specify whether you want to receive information electronically or by mail
  • Include your contact information for our response
  • Specify whether your request relates to website data, App data, or both

Verification Process: To protect your privacy and security, we will verify your identity before fulfilling your request. We may:

  • Ask you to confirm personal information we have on file
  • Request additional documentation to verify your identity
  • Send a verification link to your email address on file
  • Ask you to log in to your account
  • Use other reasonable verification methods

Authorized Agents: You may designate an authorized agent to make requests on your behalf. The agent must:

  • Provide proof of authorization to act on your behalf
  • Verify their own identity
  • Provide any additional information we require

Response Time: We will respond to your request within the time period required by applicable law, typically:

  • 45 days for most requests
  • Up to 90 days for complex requests (with notice of the extension)

6.3 Communication Preferences

Email Communications: You may opt out of receiving marketing and promotional emails by:

  • Clicking the “unsubscribe” link in any marketing email
  • Adjusting your email preferences in your account settings (website or App)
  • Contacting us at the email address in Section 13

Text/SMS Messages: You may opt out of text message communications by:

  • Replying “STOP” to any SMS message we send
  • Contacting us at the information in Section 13

Push Notifications (App): You may control push notifications from our App by:

  • Adjusting notification settings within the App
  • Changing notification permissions in your device settings
  • iOS: Settings > Notifications > The Inside Passage
  • Android: Settings > Apps > The Inside Passage > Notifications

Phone Calls: You may opt out of marketing calls by informing us during the call or by contacting us using the information in Section 13.

Important Account Communications: Even if you opt out of marketing communications, we may still send you:

  • Transactional messages related to your account or purchases
  • Service announcements and administrative messages
  • Legal notices
  • Security alerts
  • Customer service responses
  • Other non-promotional communications
  • Essential App notifications

Processing Time: We will take commercially reasonable steps to implement your opt-out requests promptly. However, you may continue to receive:

  • Promotional mail for up to 60 days due to printing and mailing schedules
  • Emails for up to 10 business days
  • Push notifications until you adjust your device settings
  • Communications from third parties to whom your information was previously disclosed (you must opt out with them directly)

6.4 Account Closure

You may close your account at any time by contacting us or through account settings in the App. Upon account closure:

  • We will deactivate your account and restrict future access
  • You will no longer be able to access the App or website features requiring login
  • Some information may be retained as required by law or for legitimate business purposes
  • Certain information may remain in backups and archives
  • Information you posted publicly may remain visible to others

7. DATA SECURITY

7.1 Our Security Measures

We take the security of your personal information seriously. We maintain reasonable and appropriate physical, electronic, and procedural safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, and destruction.

Our security measures include:

Physical Safeguards:

  • Secure facilities with restricted access
  • Locked storage for physical documents
  • Visitor sign-in and escort protocols
  • Secure disposal of physical documents

Technical Safeguards:

  • Encryption of data in transit using SSL/TLS
  • Encryption of sensitive data at rest (including App data)
  • Secure communication between the App and our servers
  • Firewalls and intrusion detection systems
  • Regular security assessments and penetration testing
  • Multi-factor authentication for administrative access
  • Secure software development practices
  • Regular security updates and patches
  • Secure app development and testing protocols

Organizational Safeguards:

  • Access controls limiting who can view your information
  • Employee training on data security and privacy
  • Confidentiality agreements with employees and contractors
  • Vendor security requirements and oversight
  • Incident response and breach notification procedures
  • Regular review and update of security practices

7.2 Your Responsibilities

You are responsible for:

  • Maintaining the confidentiality of your account password
  • Selecting a strong, unique password for your account (website and App)
  • Not sharing your password with others
  • Logging out of your account when finished
  • Notifying us immediately of any unauthorized account access
  • Keeping your contact information current
  • Using secure internet connections when accessing your account
  • Keeping your mobile device secure and protected
  • Updating the App when new versions are available
  • Protecting your device from malware and unauthorized access

Password Security Tips:

  • Use a unique password not used for other accounts
  • Include a combination of uppercase and lowercase letters, numbers, and symbols
  • Avoid easily guessable information (birthdates, names, common words)
  • Change your password periodically
  • Use a password manager if needed
  • Enable biometric authentication (fingerprint, Face ID) if available in the App

7.3 Security Limitations

While we work hard to protect your information, please be aware:

  • No method of transmission or storage is 100% secure. Despite our efforts, we cannot guarantee absolute security.
  • Internet transmission risks. Information transmitted over the Internet can potentially be intercepted by third parties.
  • Mobile device risks. Your device may be lost, stolen, or compromised.
  • Unauthorized access. We cannot be responsible for actions of those who gain unauthorized access to your information through no fault of ours.
  • Third-party security. We are not responsible for the security practices of third-party websites, apps, or services.

We make no warranties, express, implied, or otherwise, as to the ultimate effectiveness of our safeguards.

7.4 Data Breach Notification

In the event of a data breach that affects your personal information, we will:

  • Investigate the incident promptly
  • Take steps to mitigate the breach
  • Notify affected individuals as required by applicable law
  • Notify relevant regulatory authorities as required
  • Provide information about steps you can take to protect yourself
  • Implement measures to prevent future incidents

You will typically be notified within the timeframe required by applicable law (often within 72 hours of discovery for serious breaches). Notification may be sent via email, App notification, or other appropriate means.

7.5 Reporting Security Issues

If you discover a security vulnerability or have concerns about our security practices, please contact us immediately at help@cynthiaoccelli.com with “Security Issue” in the subject line.

8. DATA RETENTION

8.1 How Long We Keep Your Information

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Factors we consider when determining retention periods:

  • The nature and sensitivity of the information
  • The purposes for which we collected the information
  • Legal, accounting, or reporting obligations
  • Whether we have a legitimate business need for the information
  • Contractual obligations
  • Consent duration (if based on consent)
  • Industry best practices

8.2 Retention Periods by Category

Account Information:

  • Retained for the duration of your account (website and/or App)
  • May be retained for up to 7 years after account closure for legal, tax, and accounting purposes
  • Deleted or anonymized after retention period expires (unless legal hold applies)

Transaction Records:

  • Retained for at least 7 years for tax and accounting compliance
  • May be retained longer if required by law or ongoing legal matters

Marketing Communications:

  • Retained until you opt out or withdraw consent
  • Metadata may be retained for analytics purposes

Customer Service Records:

  • Retained for 3-7 years to address potential disputes or claims
  • May be retained longer if related to ongoing matters

Usage and Analytics Data:

  • Typically retained for 1-3 years
  • May be aggregated or anonymized for longer-term analysis

App Usage Data:

  • In-app activity data retained for 1-3 years
  • Crash reports and error logs retained for up to 2 years
  • Analytics data may be anonymized and retained longer

Legal Hold: If information is subject to a legal hold, investigation, or litigation, we will retain it until the matter is resolved, even if it exceeds our standard retention periods.

8.3 Deletion and Anonymization

When we no longer need your personal information:

  • We will delete it from our active systems (including App servers)
  • We will make it anonymous by removing all details that identify you
  • Anonymized data may be retained indefinitely for research and analytics

However, please note:

  • Information may remain in backups and archives for a period of time
  • Some information may persist in third-party systems beyond our control
  • Legal requirements may mandate retention of certain data
  • Information you posted publicly may remain accessible to others
  • App data may remain in local device storage until you uninstall the App

8.4 Your Right to Request Deletion

You may request deletion of your personal information at any time (see Section 6). We will comply with your request unless:

  • We have a legal obligation to retain the information
  • The information is necessary to complete a transaction or provide a service you requested
  • The information is needed to detect security incidents or prevent fraud
  • The information is required to exercise our rights or defend against claims
  • Other legal exceptions apply

9. CHILDREN’S PRIVACY

9.1 Age Restrictions

We are committed to protecting the privacy of children. We do not knowingly collect, use, or disclose personal information from children under the age of 13 without verifiable parental consent.

Our Sites, App, and/or Services are not directed to children under 13 and we do not:

  • Aim any of our products or services directly at children under 13
  • Knowingly collect personal information from children under 13
  • Market to children or allow them to register for our Services or download our App with the intent to serve children

9.2 COPPA Compliance

We comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and its accompanying regulations. We have adopted techniques to ensure compliance with this Privacy Policy and COPPA.

9.3 Content Suitability

Our Sites, App, and/or Services may include content that we believe is unsuitable for children under 13 and is not necessarily monitored. Topics may include:

  • Personal development and life coaching
  • Relationships and intimacy
  • Adult themes and experiences
  • Other mature content

9.4 Parental Rights and Responsibilities

If you are a parent or guardian:

  • We encourage you to talk to your children about online safety
  • Monitor your children’s use of the Internet and mobile apps
  • Teach your children not to provide personal information online without permission
  • Use parental control tools, internet filters, and device restrictions
  • Monitor app downloads and in-app activities

If we learn we have collected information from a child under 13:

  • We will delete that information as quickly as possible
  • We may contact the parent to verify the child’s age
  • We will not use or disclose the information

If you believe we have collected information from your child under 13: Please contact us immediately using the information in Section 13 so we can delete the information.

9.5 Minimum Age for Certain Services

Some of our Services may have higher minimum age requirements:

  • Users must be 18 or older to make purchases
  • Users must be 18 or older to enter into contracts
  • Certain programs or Services may require users to be 18 or older
  • App store age ratings apply (check App Store or Google Play Store listing)

If you are under 18, you may use the Sites, App, and/or Services only with the involvement of a parent or legal guardian.

10. INTERNATIONAL DATA TRANSFERS

10.1 Location of Our Operations

Our Sites, App, and/or Services and the servers that make them available are located in the United States of America. Our Sites, App, and/or Services are controlled and operated by us from the United States.

10.2 Transfer of Your Information

If you access our Sites, use our App, or use our Services from outside the United States, please be aware that:

  • Your information will be transferred to, stored, and processed in the United States
  • The United States may have different data protection laws than your country
  • Your information may be subject to access by law enforcement and other authorities in the United States
  • By using our Sites, App, and/or Services, you consent to this transfer, storage, and processing

10.3 International Users

When you use our Sites, App, and/or Services from outside the United States:

  • You authorize the transfer of your information to the United States
  • You consent to processing under United States law
  • You acknowledge that United States privacy laws may be different from those in your country

The Sites, App, and/or Services are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States.

10.4 European Union and European Economic Area

For users in the EU/EEA:

While our primary operations are in the United States, we recognize your rights under the General Data Protection Regulation (GDPR). We process your personal information based on legal grounds described in Section 3.2.

Transfer Mechanisms: When we transfer your personal information from the EU/EEA to the United States, we rely on:

  • Your explicit consent
  • Necessity for performance of a contract
  • Standard contractual clauses (where applicable)
  • Other appropriate safeguards

Your EU/EEA Rights: In addition to rights described in Section 6, you have:

  • Right to lodge a complaint with your local data protection authority
  • Right to object to processing based on legitimate interests
  • Right to withdraw consent (where processing is based on consent)
  • Right to restrict processing in certain circumstances

10.5 Cross-Border Data Transfers

Where your information may be transferred: Your personal information may be stored and processed in any country where we have facilities or engage service providers. This may include countries that do not have data protection laws equivalent to those in your country.

Safeguards we use:

  • Contractual protections with service providers
  • Standard contractual clauses (SCCs) where appropriate
  • Adequacy determinations by relevant authorities
  • Other lawful transfer mechanisms

11. STATE-SPECIFIC PRIVACY RIGHTS

The following sections provide additional information for residents of specific U.S. states with comprehensive privacy laws.

11.1 CALIFORNIA RESIDENTS

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

11.1.1 Notice of Collection

In the past 12 months, we have collected the following categories of personal information as enumerated in the CCPA:

  • Identifiers: Name, email address, phone number, account name, IP address, device ID
  • Commercial Information: Products or services purchased, purchasing history
  • Internet/Network Activity: Browsing history, search history, interaction with websites/app
  • Geolocation Data: General location based on IP address, precise location (with permission)
  • Audio/Visual Information: Photos or videos you submit, call recordings (with notice)
  • Professional/Employment Information: Current employer, job title (if provided)
  • Inferences: Preferences, characteristics, behavior, attitudes

Sources: We collect this information directly from you, automatically through your use of our Sites/App/Services, and from third-party sources described in Section 1.3.

Purposes: We use this information for purposes described in Section 3, including providing Services, business operations, marketing, and legal compliance.

Disclosure: We disclose these categories to third parties described in Section 4.

11.1.2 Your California Rights

Right to Know: You have the right to request that we disclose:

  • The categories of personal information we collected about you
  • The categories of sources from which the personal information was collected
  • The business or commercial purpose for collecting or selling personal information
  • The categories of third parties with whom we share personal information
  • The specific pieces of personal information we collected about you

Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.

Right to Correct: You have the right to request correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing: You have the right to opt out of the “sale” or “sharing” of your personal information.

  • We do not sell personal information for monetary consideration
  • We may share information with third parties for targeted advertising, which may constitute “sharing” under CCPA
  • To opt out: Contact us using the information in Section 13

Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of your sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA.

Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Financial Incentives: We may offer financial incentives permitted by CCPA (such as discounts, loyalty programs, or special offers) that can result in different prices, rates, or quality levels. Any such incentive:

  • Will reasonably relate to the value of your personal information
  • Will be described in written terms
  • Requires your prior opt-in consent
  • May be revoked by you at any time

11.1.3 Shine the Light Law

Under California Civil Code Section 1798.83 (“Shine the Light” law), California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes.

To make a Shine the Light request:

  • Send a written request to the address in Section 13
  • Include “Request for California Privacy Information” or “Shine the Light Request” in the subject line
  • Include your name, street address, city, state, and ZIP code
  • You may make this request once per calendar year

We will provide:

  • A list of categories of personal information disclosed for direct marketing purposes in the preceding calendar year
  • Names and addresses of third parties who received such information

Not all information sharing is covered by Shine the Light law.

11.1.4 How to Exercise California Rights

Submitting Requests:

  • Email: help@cynthiaoccelli.com with “California Privacy Rights Request” in subject
  • Mail: Mood Pop, Inc., Attn: Privacy Rights, 2355 Westwood Blvd, #750, Los Angeles, CA 90064

Verification: We will verify your identity before responding to requests. We may request:

  • Information that matches our records (email, account details)
  • Declaration under penalty of perjury that you are the consumer
  • Additional documentation for high-value or sensitive requests

Response Time:

  • We will respond within 45 days of receipt
  • We may extend the response period by an additional 45 days if necessary (with notice)

Authorized Agents: You may designate an authorized agent to submit requests on your behalf. The agent must provide:

  • Written authorization from you
  • Proof of their identity
  • Your identity verification (you may need to confirm directly with us)

No Fee: We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine a fee is warranted, we will notify you and explain why.

11.2 VIRGINIA RESIDENTS

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act (VCDPA).

Your Virginia Rights:

  • Right to access your personal information
  • Right to correct inaccuracies in your personal information
  • Right to delete your personal information
  • Right to obtain a copy of your personal information (data portability)
  • Right to opt out of:
    • Targeted advertising
    • Sale of personal information
    • Profiling in furtherance of decisions that produce legal or similarly significant effects

How to Exercise Rights: Contact us using the information in Section 13 with “Virginia Privacy Rights Request” in the subject line.

Appeals: If we refuse to take action on your request, you may appeal by contacting us and specifying “Virginia Privacy Appeal” in your communication. We will respond within 60 days.

11.3 COLORADO RESIDENTS

If you are a Colorado resident, you have rights under the Colorado Privacy Act (CPA).

Your Colorado Rights:

  • Right to access your personal information
  • Right to correct inaccuracies in your personal information
  • Right to delete your personal information
  • Right to data portability
  • Right to opt out of:
    • Targeted advertising
    • Sale of personal information
    • Profiling for decisions with legal or similarly significant effects

How to Exercise Rights: Contact us using the information in Section 13 with “Colorado Privacy Rights Request” in the subject line.

Appeals: If we refuse your request, you may appeal by contacting us with “Colorado Privacy Appeal.” We will respond within 45 days.

11.4 CONNECTICUT RESIDENTS

If you are a Connecticut resident, you have rights under the Connecticut Data Privacy Act (CTDPA).

Your Connecticut Rights:

  • Right to access your personal information
  • Right to correct your personal information
  • Right to delete your personal information
  • Right to data portability
  • Right to opt out of:
    • Targeted advertising
    • Sale of personal information
    • Profiling

How to Exercise Rights: Contact us using the information in Section 13 with “Connecticut Privacy Rights Request” in the subject line.

11.5 UTAH RESIDENTS

If you are a Utah resident, you have rights under the Utah Consumer Privacy Act (UCPA).

Your Utah Rights:

  • Right to access your personal information
  • Right to delete your personal information
  • Right to data portability
  • Right to opt out of:
    • Targeted advertising
    • Sale of personal information

How to Exercise Rights: Contact us using the information in Section 13 with “Utah Privacy Rights Request” in the subject line.

11.6 DELAWARE RESIDENTS

If you are a Delaware resident, you have rights under Delaware’s privacy law.

Your Rights: Similar to other states, including access, deletion, correction, and opt-out rights.

How to Exercise Rights: Contact us using the information in Section 13 with “Delaware Privacy Rights Request” in the subject line.

11.7 FLORIDA RESIDENTS

If you are a Florida resident, you have rights under Florida’s privacy law.

Your Rights: Similar to other states, including access, deletion, correction, and opt-out rights.

How to Exercise Rights: Contact us using the information in Section 13 with “Florida Privacy Rights Request” in the subject line.

11.8 General Information for All State-Specific Rights

Verification: We will verify your identity before fulfilling your request using reasonable methods based on the sensitivity and nature of the request.

Response Time: We typically respond within 45 days. For complex requests, we may extend the response period (with notice to you).

No Discrimination: We will not discriminate against you for exercising your privacy rights.

No Fee: We generally do not charge a fee for processing requests unless they are excessive, repetitive, or manifestly unfounded.

12. CHANGES TO THIS PRIVACY POLICY

12.1 Updates to This Policy

We may update this Privacy Policy from time to time to:

  • Reflect changes in our practices
  • Comply with new legal or regulatory requirements
  • Address new privacy concerns or technologies
  • Improve clarity or transparency
  • Respond to user feedback
  • Reflect changes to our Sites, App, or Services

12.2 How We Notify You of Changes

For Material Changes: If we make material changes to how we collect, use, or disclose your personal information, we will:

  • Update the “Last Updated” date at the top of this Privacy Policy
  • Provide prominent notice on our Sites before the changes take effect
  • Display a notice in the App when you next open it
  • Send an email notification to registered users (if we have your email address)
  • Send a push notification through the App (if you have notifications enabled)
  • Obtain your consent if required by applicable law

What Constitutes a Material Change:

  • Significant new uses of personal information
  • Changes to your rights or choices
  • Changes in data retention practices
  • Changes to who we share information with
  • Reduced protections for personal information

For Non-Material Changes:

  • We will update the “Last Updated” date
  • Changes will be effective upon posting
  • We encourage you to review this Policy periodically

12.3 Your Acceptance of Changes

Continued use of our Sites, App, and/or Services after we post changes constitutes your acceptance of the updated Privacy Policy.

If you do not agree with the changes:

  • You should discontinue use of our Sites, App, and/or Services
  • You may uninstall the App from your device
  • You may request deletion of your account and information
  • For material changes requiring consent, we will not apply changes to previously collected information without your consent

12.4 Archive of Previous Versions

We maintain archives of previous versions of this Privacy Policy. If you would like to review a previous version, please contact us.

12.5 Effective Date

This Privacy Policy is effective as of the date indicated at the top of this document. Any changes will be effective as of the date specified in the updated Policy.

13. CONTACT US

13.1 Privacy Questions and Requests

If you have any questions about this Privacy Policy, our privacy practices, or if you wish to exercise your privacy rights, please contact us:

Email: help@cynthiaoccelli.com
Subject Line: Privacy Inquiry [or specify: California Privacy Rights Request, Delete My Information, etc.]

Mailing Address:
Mood Pop, Inc.
Attention: Privacy Officer
c/o Cynthia Occelli
2355 Westwood Blvd., #750
Los Angeles, CA 90064
United States

13.2 Specific Privacy Requests

For specific privacy rights requests, please use these subject lines:

  • California Residents: “California Privacy Rights Request”
  • Virginia Residents: “Virginia Privacy Rights Request”
  • Colorado Residents: “Colorado Privacy Rights Request”
  • Connecticut Residents: “Connecticut Privacy Rights Request”
  • Utah Residents: “Utah Privacy Rights Request”
  • Delaware Residents: “Delaware Privacy Rights Request”
  • Florida Residents: “Florida Privacy Rights Request”
  • Data Deletion: “Delete My Information”
  • Data Access: “Access My Information”
  • Opt-Out of Sale/Sharing: “Opt-Out of Sale/Sharing”
  • App Data Inquiry: “App Privacy Inquiry”
  • General Privacy: “Privacy Inquiry”

13.3 Response Time

We will respond to your inquiry or request within:

  • 45 days for most requests
  • 30 days for certain state-specific requests
  • As required by applicable law

If we need additional time, we will notify you and explain the reason for the delay.

13.4 Complaints and Regulatory Authorities

If you believe we have not adequately addressed your privacy concerns, you have the right to:

File a complaint with us:

  • Use the contact information above
  • Include details of your concern
  • We will investigate and respond to your complaint

Contact regulatory authorities:

  • California residents: California Attorney General’s Office
    • Website: oag.ca.gov/privacy
    • Phone: (916) 210-6276
  • Other U.S. residents: Your state Attorney General’s office
  • EU/EEA residents: Your local data protection authority
  • Federal Trade Commission (FTC):
    • Website: www.ftc.gov
    • Phone: 1-877-FTC-HELP (1-877-382-4357)

13.5 Business Inquiries

For partnership, affiliate, or other business inquiries related to privacy or data protection, please use the email address above with “Business Privacy Inquiry” in the subject line.

ADDITIONAL INFORMATION

Text Message Communications

When you contact us by text message (Short Message Service – SMS) or when we send you text messages, please be aware:

Information We Collect:

  • Your mobile phone number
  • The content of your text messages
  • Metadata associated with messages (time, date, carrier)

How We Use SMS Information:

  • To communicate with you regarding our Services
  • To respond to your inquiries
  • To provide customer support
  • To send confirmations and updates (if you opted in)
  • To send marketing messages (only with your consent)

Sharing of SMS Data: We do not share your mobile phone number, text messaging originator data, or text messaging consent data with third parties or affiliates, except:

  • Aggregators and providers of text messaging services (necessary for delivery)
  • As required by law
  • With your explicit consent

Your SMS Choices:

  • Reply “STOP” to any text to opt out of that messaging program
  • Reply “HELP” for assistance
  • Message and data rates may apply
  • Message frequency varies by program

TCPA Compliance: We comply with the Telephone Consumer Protection Act (TCPA) and will obtain your express consent before sending marketing text messages.

Marketing Consent

By providing your contact information and opting in to marketing communications:

  • You consent to receive marketing emails, texts, push notifications, or calls from us
  • You may opt out at any time using the methods described in Section 6.3
  • Your consent is not a condition of purchase (you can still use our Services if you opt out)
  • We will honor your preferences and opt-out requests promptly

User-Generated Content Considerations

When you submit User-Generated Content (reviews, testimonials, comments, photos, videos):

  • You grant us a license to use, display, and distribute your content (see Terms of Service)
  • Your content may be publicly visible (on websites or in the App)
  • You are responsible for ensuring you have rights to any content you submit
  • We may use your content for marketing and promotional purposes
  • You cannot fully delete content once it becomes public (though you may request removal)

California’s COPPA-Type Requirements

California has additional protections for minors (under 18) online:

  • Minors may request removal of content they posted
  • We will make reasonable efforts to remove or anonymize such content
  • Removal may not be complete if content was reposted by others
  • To request removal: Contact us with details of the content and proof of age

App Store Privacy Information

Our App is available through the Apple App Store and Google Play Store. These platforms have their own privacy policies and practices:

When you download our App, you are also subject to the app store’s terms and privacy policies.

Third-Party App Integrations

If you connect third-party services or apps to The Inside Passage:

  • Those services will have access to information you authorize
  • Review their privacy policies before connecting
  • You can revoke access at any time through app settings
  • We are not responsible for how third-party services use your information

ACKNOWLEDGMENT

By using our Sites, App, and/or Services, you acknowledge that:

  1. You have read and understood this Privacy Policy
  2. You agree to the collection, use, and disclosure of your information as described
  3. You consent to the transfer of your information to the United States
  4. You understand your privacy rights and how to exercise them
  5. You acknowledge that we may update this Privacy Policy and that continued use constitutes acceptance
  6. You understand the permissions you grant to our App and how we use that access

If you do not agree to this Privacy Policy, please do not use our Sites, download or use our App, or use our Services.

DOCUMENT INFORMATION

Policy Name: Privacy Policy
Version: 3.0
Effective Date: February 5, 2026
Last Updated: February 5, 2026
Last Reviewed: February 5, 2026
Next Scheduled Review: February 2027

Previous Versions:

  • Version 1.0 (Effective December 2, 2013) – Websites only
  • Version 2.0 (Effective June 2, 2025) – App added

Coverage: This policy covers all Mood Pop, Inc. websites, The Inside Passage mobile application, and all associated services.

© 2026 Mood Pop, Inc. All Rights Reserved.