Participant Document
Privacy Notice
Website visitors, adult participants, tutoring, events, subscriptions, recordings, testimonials, vendors, and international data.
PreambleLegal entity and public brand
Approval and re-review
Approved by Inner Circle Faith leadership for operational use under the approved teaching-only scope. Re-review is required if applicable law, jurisdictions, services, pricing, platforms, data practices, insurance, or source permissions materially change.
Brand statement
“Inner Circle Faith” is the public-facing trade name of Inner Circle Assets LLC. Use the full legal-provider statement in agreements, formal legal notices, receipts, insurance records, and other contexts where the contracting entity must be clear.
The legal service provider is Inner Circle Assets LLC, a Delaware limited liability company doing business as Inner Circle Faith. “Inner Circle Faith” is the public-facing trade name. Agreements, formal notices, payment records, insurance, and tax or processor records should identify the legal entity and trade name as appropriate. Services are limited to Christian religious teaching and general education; the Company does not provide legal, tax, accounting, investment, insurance, medical, mental-health, clinical, crisis, emergency, or other regulated professional services.
Effective August 7, 2026. This Privacy Notice describes how Inner Circle Assets LLC, a Delaware limited liability company doing business as Inner Circle Faith, collects, uses, shares, retains, and protects personal information. It also explains privacy choices and rights. Current privacy and business contact methods are maintained on the official Inner Circle Faith website and on purchase or account confirmations.
PreambleSensitive information
Religious beliefs, prayer-related information, and health-related information may be sensitive. Inner Circle Faith will collect only what is reasonably needed, obtain appropriate consent when required, restrict access, and avoid detailed histories when a general description will serve the educational purpose.
Section 1Scope
This Notice applies to the website, enrollment forms, courses, workshops, Focus Sessions, events, paid newsletter, digital and printed products, email, customer support, surveys, testimonials, recordings, contractor interactions, and related systems. A separate notice may apply when an event host or platform independently controls information.
Section 2Information we may collect
| Category | Examples |
|---|---|
| Identity and contact | Name, preferred name, adult-status confirmation, email, telephone, mailing address, country, state, time zone. |
| Account and enrollment | Username, program, attendance, completion, access history, accommodation requests, support records, consent versions. |
| Payment and transaction | Plan, amount, dates, tax location, refunds, chargebacks, processor token or limited payment details; full card data is ordinarily handled by processors. |
| Learning and tutoring | Learning objective, prior coursework, general questions, Scripture or curriculum reviewed, materials provided, assignments, brief operational notes. |
| Religious and sensitive | Religious interests, prayer-related topics, optional statements about health or family circumstances, only when voluntarily provided and reasonably needed. |
| Event and media | Registration, venue attendance, photograph, voice, video, transcript, chat, questions, and consent choices. |
| Testimonials | Statement, name choice, title, organization, photograph, audio/video, approval, material connection, release and withdrawal request. |
| Technical and usage | IP address, browser, device, logs, cookie identifiers, pages, clicks, email interaction, access times, security events. |
| Communications | Emails, calls, survey responses, complaints, correction requests, privacy requests, marketing preferences. |
| Safety and legal | Incident report, referral action, emergency contact when provided, fraud or security evidence, legal process, records hold. |
Section 3Information we ask you not to provide
- Social Security numbers, bank credentials, passwords, full payment-card data, or government identifiers unless specifically and lawfully required.
- Detailed trauma histories, medical records, diagnoses, or therapy records.
- Detailed accusations, criminal evidence, or private information about another person.
- Confidential employer, church, counseling, legal, or ministry records without authority.
- Images, recordings, or contact information of another person without lawful permission.
Section 4Sources
We collect information directly from you; from an authorized church or event host; from payment, email, CRM, scheduling, video, course, analytics, shipping, support, and security providers; from public professional sources when verifying a contractor or speaker; and from lawful referrals. We do not treat a prayer impression or spiritual statement as verified factual data about another person.
Section 5Purposes and legal bases
| Purpose | Why / legal basis where applicable |
|---|---|
| Provide services | Perform the agreement; enroll, schedule, teach, deliver, assess completion, support, and communicate. |
| Process transactions | Complete payment, tax, refund, fraud prevention, accounting, and recordkeeping. |
| Sensitive information | Explicit or other valid consent where required; participant-requested religious education; safety or legal obligations; no sale or behavioral-advertising use. |
| Improve and quality review | Legitimate operational interests or consent; use de-identified or aggregated information when practical. |
| Marketing | Consent or another lawful basis; honor opt-outs and suppression records. |
| Safety, integrity, and law | Protect people and systems, investigate misuse, respond to emergencies, comply with law, establish or defend rights. |
| Accessibility | Respond to accommodation requests and improve accessible delivery. |
| Recordings and testimonials | Specific, separate consent and the defined license or release; not bundled with enrollment. |
| International administration | Determine availability, tax, currency, consumer terms, and data-transfer safeguards. |
Section 6How we disclose information
- Service providers that host the website, course platform, video meetings, email, CRM, scheduling, payments, accounting, storage, analytics, security, captions, shipping, forms, signatures, or support, under appropriate contracts.
- Instructors, administrators, contractors, and reviewers who need access for an approved purpose and are subject to confidentiality and scope controls.
- Event hosts or sponsors only as disclosed and necessary for the event; each may separately control information it collects.
- Professional advisers, insurers, auditors, and legal authorities when reasonably necessary.
- Emergency responders, safeguarding authorities, law enforcement, or other recipients when authorized, legally required, or reasonably necessary to address serious safety.
- A successor in a lawful merger, reorganization, or sale, subject to notice and continued protection where required.
No sale of sensitive information
Inner Circle Faith does not sell religious-belief, tutoring, prayer-related, health-related, recording, or testimonial information. It does not use such information for targeted advertising across unrelated websites. Any future change would require advance notice, a lawful basis, and applicable rights.
Section 7Cookies, analytics, and advertising
The website may use necessary cookies for login, security, preferences, and purchases; analytics to understand use; and marketing technologies only after the required notice or consent. A cookie tool should identify vendors, purposes, durations, and choices. Browser signals will be handled as required by applicable law. Declining optional technologies should not prevent basic access, though some features may be affected.
Section 8Retention
| Record | Approved baseline period / rule |
|---|---|
| Routine tutoring notes | 24 months after final session, then secure deletion unless a hold applies. |
| Agreements, consents, order and completion records | 7 years after the relationship or longer if counsel directs. |
| Payment, tax, refund, and accounting | 7 years or the period required by tax and accounting law. |
| Recordings | Only for the purpose and period in the Recording Consent; delete when no longer needed. |
| Testimonials and releases | While used plus a reasonable evidence period; stop future use after an effective withdrawal when required or agreed. |
| Marketing consent / opt-out | Evidence of consent and a suppression record for as long as needed to honor the choice. |
| Complaints, safety, security, and legal matters | 7 years or longer under counsel-directed hold and limitation periods. |
| Website logs and analytics | Shortest practical period configured by purpose and vendor; document actual settings. |
| Source permissions and approvals | Life of use plus 7 years or license-required period. |
Section 9Security
- Role-based access and least privilege.
- Multifactor authentication for administrative accounts.
- Approved password manager and unique credentials.
- Encryption in transit and at rest where supported.
- Vendor diligence and data-processing terms.
- Secure backups, patching, logging, and incident response.
- Separation of payment-card processing from ordinary records.
- Training on phishing, sensitive religious information, and safe referral.
No security program eliminates risk. If a breach occurs, Inner Circle Faith will contain, investigate, document, and provide legally required notices.
Section 10Your choices and rights
- Access or receive information about personal data, subject to verification and legal exceptions.
- Correct inaccurate information.
- Request deletion when retention is not required.
- Obtain a portable copy where applicable.
- Withdraw consent for future processing where consent is the basis, without affecting prior lawful processing.
- Opt out of marketing email and certain targeted advertising, sale, or profiling where applicable.
- Appeal a denied Colorado privacy request when the law applies.
- Complain to an applicable regulator or data-protection authority.
- Request an alternative format or accessibility assistance.
Submit a request to the Privacy Contact listed on the official Inner Circle Faith website or purchase confirmation. We will verify identity proportionately, respond within applicable deadlines, and explain significant denials. Authorized-agent requests may require proof of authority.
Section 11Children and minors
Services are intended only for adults age 18 or older. Inner Circle Faith does not knowingly enroll minors. If it learns that a minor’s information was collected without an approved legal and safeguarding basis, it will delete or appropriately restrict it.
Section 12International transfers
Information may be processed in the United States and other countries where approved providers operate. Where required, Inner Circle Faith will use contractual safeguards, adequacy mechanisms, consent, or other lawful transfer tools. International availability may be limited until the necessary privacy, tax, and consumer systems are implemented.
Section 13Third-party services and links
Payment processors, event hosts, course platforms, social networks, and linked websites may have their own privacy practices. This Notice applies only when Inner Circle Faith controls the processing. Review third-party notices before use.
Section 14Changes
The effective date will be updated when this Notice changes. Material changes will be communicated as required and will not be applied retroactively in a way that unlawfully reduces rights. Prior versions will be archived.
Section 15Contact and complaints
| Purpose | Contact |
|---|---|
| Privacy requests | Use the Privacy Contact listed on the official Inner Circle Faith website or purchase/account confirmation. |
| General support | Use the Support Contact listed on the official Inner Circle Faith website or purchase/account confirmation. |
| Postal notices | 2093 Vineyard Dr, Windsor, CO 80550 |
| Telephone | +1 970-536-5948 |
| Website | Official Inner Circle Faith website. |
| Colorado appeal / complaint process | If the Colorado Privacy Act applies and a verified request is denied, appeal by replying to the denial or using the Privacy Contact. We will respond within the period required by law and, when required, explain how to contact the Colorado Attorney General. |
| EU/UK representative, if required | The International Addendum or jurisdiction-specific privacy notice will identify a representative if one is legally required before offering services in that jurisdiction. |
ReferencesAuthority references and annual legal review
These primary sources informed this final business-approved version. Laws, regulations, and agency guidance can change; re-check applicability at least annually and before any material change in service scope, jurisdiction, platform, pricing, data practice, or marketing method.
- Colorado Privacy Act: https://coag.gov/resources/colorado-privacy-act/
- FTC Data Security: https://www.ftc.gov/business-guidance/resources/start-security-guide-business
- EU GDPR Special Categories: https://eur-lex.europa.eu/eli/reg/2016/679/oj
- UK ICO Special Category: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/special-category-data/what-is-special-category-data/
UK data-protection update: the UK GDPR and Data Protection Act 2018 operate as amended by the Data (Use and Access) Act 2026; ICO special-category guidance remains the operational reference and is under continuing update.