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EMPOWERING THE CHILDLESS WOMAN

CONNECTICUT PRIVACY POLICY AND CONSUMER HEALTH DATA NOTICE

Effective Date: August 2026
Last Updated: August 2026

  1. INTRODUCTION

Empowering The Childless Woman (“Empowering The Childless Woman,” the “Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains what information we collect, how we collect and use it, when and why we disclose it, how we protect and retain it, and the privacy rights available to Connecticut residents.

This Privacy Policy applies to the Empowering The Childless Woman mobile application and any related websites, pages, features, programs, content, communications, community functions, and services that link to or reference this Privacy Policy (collectively, the “Services”).

This Privacy Policy is intended to address our obligations under applicable Connecticut privacy law, including the Connecticut Data Privacy Act (“CTDPA”), Connecticut General Statutes §§ 42-515 through 42-526, as amended.

Because Empowering The Childless Woman provides educational, coaching, personal-development, and community services relating to life without children, you may voluntarily provide information concerning highly personal subjects, including infertility, fertility treatment, pregnancy loss, reproductive experiences, relationships, grief, emotional well-being, physical health, mental health, and other sensitive life experiences.

Some of this information may constitute “sensitive data” or “consumer health data” under Connecticut law.

We recognize the particularly private nature of this information and seek to collect, use, disclose, and retain only information reasonably necessary and proportionate to provide our Services and accomplish the purposes explained in this Privacy Policy.

Please read this Privacy Policy carefully.

Where Connecticut law requires your consent before particular personal information may be processed, we will obtain that consent in accordance with applicable law.

  1. WHO THIS PRIVACY POLICY APPLIES TO

This Privacy Policy applies to information we collect when you:

  • access or use the Empowering The Childless Woman mobile application;
  • visit a website or webpage operated by us that links to this Privacy Policy;
  • create or maintain an account;
  • enroll in or participate in a program;
  • purchase a program, membership, subscription, or service;
  • complete a survey, questionnaire, assessment, intake form, reflection exercise, or other activity;
  • participate in community, messaging, or discussion features;
  • communicate with us;
  • contact customer support;
  • participate in an event, coaching program, or educational offering; or
  • otherwise interact with a Service that references this Privacy Policy.

This Privacy Policy is written primarily for Connecticut residents and to address applicable Connecticut privacy requirements.

III. THIRD-PARTY SERVICES

This Privacy Policy applies to personal information processed by Empowering The Childless Woman.

It does not govern information independently collected or controlled by third parties, including:

  • payment processors;
  • application stores;
  • social-media platforms;
  • video-conferencing platforms;
  • external websites;
  • email providers;
  • hosting providers;
  • analytics companies;
  • advertising providers; or
  • other independently operated applications or services.

Those third parties maintain their own privacy policies and practices.

We encourage you to review the privacy policies of third-party services before providing personal information directly to them.

  1. USERS MUST BE AT LEAST 18 YEARS OLD

The Services are intended only for individuals who are 18 years of age or older.

Individuals under 18 are not authorized to create an account or use the Services.

We do not knowingly collect personal information from individuals under 18 through Services intended for adults.

If you believe that an individual under 18 has provided personal information to Empowering The Childless Woman, please contact us at:

[email protected]

We will take reasonable steps to investigate the matter and, where appropriate or legally required, delete the information.

  1. INFORMATION WE COLLECT

The personal information we collect depends upon how you interact with the Services and the information you choose to provide.

We may collect the following categories of information.

  1. Identifiers and Contact Information

This may include:

  • name;
  • email address;
  • postal address;
  • telephone number;
  • username;
  • account identifier; and
  • other similar identifying or contact information.
  1. Account Information

If you establish an account, we may collect information necessary to create, maintain, authenticate, and secure your account, including:

  • username;
  • password or other authentication credentials;
  • account preferences;
  • membership information;
  • program enrollment information;
  • subscription status; and
  • account history.
  1. Information You Voluntarily Provide

You may voluntarily provide information through:

  • surveys;
  • assessments;
  • questionnaires;
  • program exercises;
  • worksheets;
  • journals or reflections;
  • profile information;
  • posts;
  • comments;
  • photographs;
  • messages;
  • chats;
  • coaching questions;
  • community discussions;
  • feedback;
  • testimonials; and
  • communications with us.

Because of the nature of Empowering The Childless Woman, some information you voluntarily provide may be highly personal or sensitive.

You should provide only information that you are comfortable sharing and that is reasonably necessary for the applicable Service or feature.

  1. Demographic and Preference Information

You may voluntarily provide information such as:

  • age;
  • date of birth;
  • gender;
  • occupation;
  • interests;
  • preferences;
  • personal goals; and
  • other demographic information.
  1. Financial and Transaction Information

When you purchase a program, membership, subscription, or other Service, we may collect:

  • purchase information;
  • transaction date;
  • amount paid;
  • subscription information;
  • billing information; and
  • payment history.

Payment-card information may be collected and processed directly by a third-party payment processor rather than stored by Empowering The Childless Woman.

  1. Device and Technical Information

When you access or use the Services, we or our service providers may automatically collect certain technical information, including:

  • IP address;
  • browser type;
  • operating system;
  • device type;
  • device identifiers;
  • application version;
  • referring URLs;
  • pages or features accessed;
  • crash information;
  • log information; and
  • similar technical information.
  1. Usage Information

We may collect information regarding your interaction with the Services, including:

  • features used;
  • pages viewed;
  • links selected;
  • dates and times of use;
  • duration of sessions;
  • interactions with communications; and
  • general usage patterns.
  1. Location Information

We may derive approximate location information, such as city, state, or region, from an IP address or similar technical information.

We do not intentionally collect precise geolocation information unless:

  • it is reasonably necessary to provide a particular feature;
  • the collection is clearly disclosed to you; and
  • any consent required by Connecticut law has been obtained.
  1. Communications

If you communicate with us by email, message, chat, telephone, or another method, we may retain the communication and associated information where reasonably necessary to respond, administer our Services, maintain appropriate records, or comply with applicable law.

  1. SENSITIVE DATA UNDER CONNECTICUT LAW

Connecticut law provides heightened protections for certain categories of personal information classified as sensitive data.

Depending upon the information you voluntarily provide, sensitive data may include information concerning:

  • racial or ethnic origin;
  • religious beliefs;
  • mental or physical health conditions or diagnoses;
  • reproductive or sexual health;
  • sexual activity or sexual orientation;
  • citizenship or immigration status;
  • disability;
  • genetic information;
  • biometric information used to uniquely identify a person;
  • precise geolocation information;
  • certain government-issued identification information;
  • certain financial-account information and credentials;
  • consumer health data; or
  • other information defined as sensitive data under applicable Connecticut law.

We seek to avoid collecting sensitive data unless it is reasonably necessary to provide a requested Service, feature, or program experience.

Where Connecticut law requires consent before processing sensitive data, we will obtain your consent before engaging in that processing.

Connecticut treats sensitive data as a protected subset of personal information and generally requires a consumer’s consent before a controller processes it.

VII. CONSUMER HEALTH DATA

Connecticut law provides special protections for consumer health data.

Consumer health data includes personal data used to identify a consumer's physical or mental health condition, diagnosis, or status and includes reproductive and sexual health information.

Because Empowering The Childless Woman addresses experiences surrounding life without children, you may voluntarily provide information concerning:

  • infertility;
  • fertility treatment;
  • pregnancy;
  • miscarriage;
  • stillbirth;
  • pregnancy loss;
  • reproductive history;
  • reproductive healthcare;
  • sexual health;
  • physical-health conditions;
  • mental-health conditions;
  • emotional well-being;
  • diagnoses;
  • treatment;
  • counseling experiences; or
  • other health-related matters.

Such information may qualify as consumer health data under Connecticut law.

Empowering The Childless Woman recognizes that this information may be particularly private and sensitive.

Connecticut applies specific protections to consumer-health-data controllers, and these protections may apply regardless of ordinary business-size or data-processing thresholds.

VIII. HOW WE USE CONSUMER HEALTH DATA

We process consumer health data only when reasonably necessary and proportionate to:

  • provide a Service or feature that you request;
  • administer an assessment, exercise, program, or community experience in which you choose to participate;
  • respond to a question or communication from you;
  • maintain appropriate records concerning Services you requested;
  • protect the security and integrity of the Services;
  • comply with applicable legal obligations; or
  • accomplish another purpose that has been clearly disclosed to you and is permitted by applicable law.

We do not collect consumer health data merely because it may be interesting or commercially useful.

Where Connecticut law requires your consent to process consumer health data, we will obtain the required consent.

  1. WE DO NOT SELL CONSUMER HEALTH DATA WITHOUT REQUIRED CONSENT

Empowering The Childless Woman does not sell or offer to sell consumer health data without first obtaining the consent required by Connecticut law.

We do not provide information regarding infertility, pregnancy loss, reproductive health, mental health, physical health, or similar consumer health matters to data brokers for monetary consideration.

We will not knowingly disclose consumer health data for a purpose that Connecticut law prohibits.

Connecticut specifically prohibits the sale or offer for sale of consumer health data without consumer consent.

  1. ACCESS TO CONSUMER HEALTH DATA

Access to consumer health data is limited to employees, contractors, processors, and service providers who reasonably need access to perform authorized functions.

Employees or contractors provided access to consumer health data will be subject to applicable contractual or statutory confidentiality obligations.

Where a processor receives consumer health data on our behalf, we will use written contractual safeguards required by Connecticut law.

Connecticut prohibits providing employees or contractors access to consumer health data unless they are subject to confidentiality obligations and prohibits giving processors access without the required contractual protections.

  1. REPRODUCTIVE AND SEXUAL HEALTH INFORMATION

We recognize that users may disclose sensitive information concerning reproductive experiences.

Such information may include:

  • infertility;
  • fertility treatment;
  • pregnancy;
  • miscarriage;
  • stillbirth;
  • pregnancy loss;
  • reproductive healthcare;
  • reproductive decisions;
  • sexual health; and
  • experiences associated with becoming or not becoming a parent.

We seek to treat this information with heightened care.

We will not sell or offer to sell reproductive or sexual health information without any consent required under Connecticut law.

XII. GEOFENCING

Empowering The Childless Woman does not use geofencing in a manner prohibited by Connecticut law in connection with consumer health data.

We do not establish prohibited virtual boundaries around mental-health, reproductive-health, or sexual-health facilities for purposes such as:

  • identifying consumers;
  • tracking consumers;
  • collecting consumer health data from consumers; or
  • sending health-related notifications to consumers.

Connecticut law specifically restricts this type of health-related geofencing.

XIII. CONSENT TO PROCESS SENSITIVE DATA

Where Connecticut law requires consent before sensitive data may be processed, we will obtain your consent before the processing occurs.

Consent will relate to the specific purpose described when it is requested.

Where affirmative consent is legally required, we will not treat your general use of the Services as sufficient consent.

XIV. WITHDRAWAL OF CONSENT

Where our processing of personal information depends upon your consent, you may withdraw or revoke that consent.

We will provide a method for withdrawing consent that is at least as easy as the method used to provide consent, as required by Connecticut law.

You may also contact us at:

Email: [email protected]
Subject: Withdraw Privacy Consent

After receiving a valid withdrawal request, we will discontinue the applicable consent-based processing as soon as practicable and within the period required by Connecticut law.

Withdrawal of consent does not affect processing that lawfully occurred before the withdrawal.

If the information is reasonably necessary to provide a particular feature or Service you requested, withdrawing consent may prevent us from continuing to provide that feature or Service.

  1. HOW WE COLLECT INFORMATION

We may collect information in the following ways.

Directly From You

We collect information when you:

  • create an account;
  • enroll in a program;
  • make a purchase;
  • complete a form;
  • answer a survey or questionnaire;
  • complete an assessment or exercise;
  • post or submit content;
  • participate in a community;
  • communicate with us;
  • contact customer support; or
  • otherwise voluntarily provide information.

Automatically

Certain information may be collected automatically when you use the Services through:

  • cookies;
  • software development kits (“SDKs”);
  • log files;
  • pixels;
  • local storage;
  • analytics technologies; and
  • similar technologies.

From Service Providers

We may receive information from service providers that assist us with functions such as:

  • payment processing;
  • hosting;
  • authentication;
  • communications;
  • email;
  • security;
  • analytics; and
  • technology support.

XVI. DATA MINIMIZATION

We seek to collect personal data that is adequate, relevant, and reasonably necessary and proportionate to the purposes for which it is processed.

We seek to avoid unnecessary collection of:

  • consumer health data;
  • reproductive-health information;
  • mental-health information;
  • precise geolocation information; and
  • other sensitive information.

If we intend to process personal information for a materially different purpose that is not reasonably necessary to or compatible with the purpose originally disclosed, we will provide additional notice or obtain consent where required under Connecticut law.

Connecticut law requires covered controllers to limit personal-data collection to what is adequate, relevant, and reasonably necessary for disclosed purposes.

XVII. HOW WE USE PERSONAL INFORMATION

We may use personal information to:

  • provide, operate, maintain, and improve the Services;
  • administer Empowering The Childless Woman programs;
  • create and maintain accounts;
  • authenticate users;
  • administer memberships and subscriptions;
  • process transactions and purchases;
  • provide educational materials;
  • facilitate community and communication features;
  • provide Services and content you request;
  • administer assessments, surveys, questionnaires, and exercises;
  • respond to questions and customer-service inquiries;
  • communicate with you regarding your account, purchases, programs, security, or changes to our Services;
  • personalize features where appropriate;
  • understand how users interact with the Services;
  • diagnose technical problems;
  • maintain and improve functionality;
  • prevent, detect, investigate, and respond to security incidents;
  • prevent fraud or unlawful conduct;
  • enforce our Terms of Use and other agreements;
  • comply with applicable Connecticut and federal law;
  • establish, exercise, or defend legal claims;
  • maintain appropriate business and transaction records;
  • send marketing communications where permitted by law; and
  • perform other purposes disclosed at the time information is collected.

XVIII. MARKETING COMMUNICATIONS

We may send promotional communications concerning Empowering The Childless Woman programs, products, services, events, or opportunities where permitted by law.

You may unsubscribe from marketing emails by using the unsubscribe mechanism contained in the applicable email.

Unsubscribing from promotional communications will not necessarily prevent us from sending non-promotional communications concerning:

  • your account;
  • an active program;
  • a purchase;
  • a transaction;
  • a security matter; or
  • another Service you requested.

XIX. SALE OF PERSONAL DATA

Empowering The Childless Woman is not in the business of selling personal information for monetary consideration.

However, Connecticut law defines “sale” according to statutory criteria that may be broader than an ordinary monetary sale.

Accordingly, certain disclosures of information to third parties could potentially constitute a statutory sale depending upon the nature of the arrangement.

If we engage in activity that constitutes a sale of personal data under Connecticut law, we will:

  • disclose the practice as required;
  • provide an appropriate method for Connecticut residents to opt out;
  • honor legally recognized universal opt-out signals where required;
  • maintain required contractual safeguards; and
  • obtain consent where Connecticut law requires consent.

We will not sell consumer health data without the consent required by Connecticut law.

  1. TARGETED ADVERTISING AND ANALYTICS

We may use analytics providers or advertising-related service providers to understand how our Services are used or to assist us in promoting Empowering The Childless Woman.

Depending upon the data disclosed and the provider's activities, certain processing may qualify as targeted advertising under Connecticut law.

If we process personal data for targeted advertising as defined by Connecticut law, Connecticut residents will be provided a means to opt out.

Where required by law, we will also recognize qualifying universal opt-out preference signals.

We do not intentionally use consumer health data, including reproductive-health or mental-health information, for targeted advertising without satisfying all requirements of applicable Connecticut law.

XXI. PROFILING AND AUTOMATED DECISION-MAKING

We do not currently use personal data to make solely automated decisions that produce legal or similarly significant effects concerning users.

If we introduce such processing in the future, we will provide any disclosures, opt-out rights, assessments, or other protections required by Connecticut law.

XXII. ARTIFICIAL INTELLIGENCE AND LARGE LANGUAGE MODELS

Empowering The Childless Woman does not intentionally use participants' sensitive data or consumer health data to train a general-purpose large language model.

We do not sell participants' sensitive or consumer health data for the purpose of training a general-purpose artificial-intelligence model.

If we use artificial-intelligence or machine-learning tools to provide features of the Services, information may be processed by an authorized technology provider only for permitted purposes and subject to applicable contractual and legal safeguards.

If our practices change so that personal information is collected, used, disclosed, or sold for purposes of training a large language model, we will update this Privacy Policy and provide any additional disclosure, consent, or privacy choices required under Connecticut law.

XXIII. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies and similar technologies to:

  • operate the Services;
  • authenticate users;
  • maintain security;
  • recognize returning users;
  • remember preferences;
  • understand Service usage;
  • improve functionality;
  • diagnose technical problems; and
  • measure performance.

Certain technologies may be placed or operated by service providers on our behalf.

You may be able to manage certain cookies through your browser, mobile-device, or application settings.

Certain cookies or technologies may be necessary for portions of the Services to function properly.

For additional information regarding cookies and similar technologies, please review our Cookie Policy, where available.

XXIV. DO NOT TRACK AND UNIVERSAL OPT-OUT PREFERENCE SIGNALS

Certain web browsers offer a “Do Not Track” or “DNT” setting.

Because there is no single universally accepted standard governing DNT signals, we may not respond to ordinary browser DNT settings.

A legally recognized universal opt-out preference signal is different from an ordinary DNT setting.

Where Connecticut law requires us to recognize a qualifying universal opt-out preference signal relating to sale or targeted advertising, we will process that signal in accordance with applicable Connecticut law.

Connecticut has required covered businesses to recognize qualifying universal opt-out signals since January 1, 2025.

XXV. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information as reasonably necessary for the purposes described in this Privacy Policy.

Service Providers and Processors

We may disclose information to third parties that perform services on our behalf, including providers of:

  • mobile-application or website hosting;
  • cloud storage;
  • payment processing;
  • email delivery;
  • customer support;
  • communications;
  • video conferencing;
  • analytics;
  • authentication;
  • cybersecurity; and
  • technical support.

These organizations are authorized to process personal information only as permitted under applicable contractual arrangements and law.

Professional Advisers

We may disclose information where reasonably necessary to professional advisers, including:

  • attorneys;
  • accountants;
  • auditors;
  • consultants;
  • insurance providers; and
  • cybersecurity professionals.

Business Transactions

If Empowering The Childless Woman is involved in an actual or proposed:

  • merger;
  • acquisition;
  • restructuring;
  • financing;
  • bankruptcy;
  • sale of assets; or
  • similar business transaction,

personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

Legal Requirements

We may disclose information where reasonably necessary or required to:

  • comply with Connecticut or federal law;
  • respond to a subpoena;
  • comply with a court order;
  • comply with lawful governmental or regulatory requests;
  • establish, exercise, or defend legal claims;
  • protect the safety or rights of individuals;
  • protect our property or Services;
  • prevent fraud or illegal activity; or
  • maintain the security and integrity of our Services.

At Your Direction or With Your Consent

We may disclose personal information when you ask us to do so or provide legally valid consent.

XXVI. CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL DATA MAY BE DISCLOSED

Depending upon the Services you use, categories of recipients may include:

  • payment processors;
  • application and website hosting providers;
  • cloud-storage providers;
  • email and communications providers;
  • video-conferencing providers;
  • analytics providers;
  • advertising or marketing providers;
  • technology vendors;
  • cybersecurity and fraud-prevention providers;
  • customer-support providers;
  • professional advisers;
  • business successors; and
  • governmental, regulatory, judicial, or law-enforcement authorities where disclosure is required or permitted by law.

We do not intentionally provide consumer health data to third parties for purposes prohibited by Connecticut law.

XXVII. DE-IDENTIFIED AND AGGREGATED INFORMATION

We may create, use, or disclose information that has been aggregated or de-identified so that it cannot reasonably be linked to an identified or identifiable individual.

Where information is maintained as de-identified information under Connecticut law, we will take reasonable measures to ensure that it cannot reasonably be associated with an individual.

We will not attempt to re-identify de-identified information except as permitted by applicable law.

XXVIII. DATA SECURITY

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against:

  • unauthorized access;
  • acquisition;
  • misuse;
  • disclosure;
  • alteration;
  • destruction; and
  • loss.

Safeguards may include, where appropriate:

  • access controls;
  • authentication measures;
  • confidentiality obligations;
  • contractual safeguards;
  • technical security measures;
  • vendor-security requirements;
  • monitoring; and
  • incident-response procedures.

No Internet transmission, mobile application, email system, or electronic-storage system can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your password and other account credentials and should notify us promptly if you believe your account has been compromised.

We will respond to qualifying security incidents and data breaches in accordance with applicable Connecticut and federal law.

XXIX. DATA RETENTION

We retain personal information only for as long as reasonably necessary and proportionate to the purposes for which it was collected or another legitimate and lawful purpose.

The retention period for particular information may depend upon:

  • the nature of the information;
  • its sensitivity;
  • the reason it was collected;
  • the Services you use;
  • whether your account remains active;
  • transaction and financial-record requirements;
  • contractual obligations;
  • legal requirements;
  • security needs;
  • fraud prevention;
  • dispute resolution; and
  • the establishment or defense of legal claims.

When personal information is no longer reasonably necessary, we may delete, destroy, or de-identify it where appropriate and required by law.

We do not intend to retain consumer health data or other sensitive data indefinitely simply because it might potentially be useful in the future.

XXX. CONNECTICUT PRIVACY RIGHTS

Subject to applicable statutory exceptions and limitations, Connecticut residents may have the following rights regarding their personal data.

  1. Right to Confirm and Access

You may request confirmation of whether we are processing your personal data and request access to qualifying personal data.

  1. Right to Correct

You may request correction of inaccuracies in personal data concerning you, taking into account the nature and purposes of processing.

  1. Right to Delete

You may request deletion of qualifying personal data concerning you, subject to applicable exceptions.

  1. Right to Data Portability

You may request a copy of qualifying personal data in a portable and, where technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.

  1. Right to Opt Out of Sale

You may opt out of the processing of personal data for purposes that constitute a sale under Connecticut law.

  1. Right to Opt Out of Targeted Advertising

You may opt out of processing of qualifying personal data for targeted advertising.

  1. Rights Concerning Profiling

You may exercise applicable rights concerning profiling in furtherance of automated decisions that produce legal or similarly significant effects.

  1. Right to Withdraw Consent

Where our processing depends upon your consent, you may withdraw that consent in accordance with applicable Connecticut law.

  1. Right to Appeal

If we decline to take action on a qualifying Connecticut privacy request, you may appeal our decision.

These rights are subject to applicable statutory exceptions, limitations, and authentication requirements.

The Connecticut Attorney General identifies access, correction, deletion, portability, and opt-out rights among the core rights available to Connecticut consumers under the CTDPA.

XXXI. HOW TO SUBMIT A CONNECTICUT PRIVACY REQUEST

To exercise a Connecticut privacy right, contact us at:

Email: [email protected]
Subject: Connecticut Privacy Rights Request

You may also contact us by mail using the address in Section XXXIX below.

Please:

  1. identify the privacy right you wish to exercise;
  2. provide sufficient information for us to locate the applicable records; and
  3. provide information reasonably necessary for us to authenticate your request.

We will use reasonable measures to verify that the request is made by, or on behalf of, the individual to whom the personal data relates.

You do not have to create a new account solely to exercise a Connecticut privacy right.

XXXII. RESPONSE TO PRIVACY REQUESTS

We will respond to an authenticated Connecticut consumer request without undue delay and generally within 45 days after receipt, as required by applicable law.

Where reasonably necessary due to the complexity or number of requests, applicable law may permit us to extend the response period.

If an extension is necessary, we will notify you within the initial response period and provide the reason for the extension.

XXXIII. APPEALS

If we decline to take action on a qualifying Connecticut privacy request, you may appeal our decision.

Send your appeal to:

Email: [email protected]
Subject: Connecticut Privacy Rights Appeal

Please identify:

  • the original request;
  • our response, if available; and
  • why you believe our decision should be reconsidered.

We will respond to your appeal within the period required by Connecticut law.

If we deny the appeal, we will provide information regarding any further rights or remedies required by law, including information regarding how to contact the Connecticut Office of the Attorney General where applicable.

XXXIV. AUTHORIZED AGENTS

Where permitted by Connecticut law, you may designate an authorized agent to exercise certain privacy rights on your behalf.

We may take reasonable steps to verify the authority of an authorized agent as permitted by law.

XXXV. NON-DISCRIMINATION

We will not unlawfully discriminate against a Connecticut resident for exercising a privacy right provided by applicable Connecticut law.

XXXVI. DATA PROTECTION ASSESSMENTS

Where required by Connecticut law, Empowering The Childless Woman will conduct and document appropriate data protection assessments for processing activities that present a heightened risk of harm to consumers.

Depending upon our activities, such assessments may include processing involving:

  • sensitive data;
  • consumer health data;
  • sale of personal data;
  • targeted advertising;
  • qualifying profiling or automated decision-making; or
  • other processing activities presenting heightened risk.

We will periodically review our data-processing activities as our Services, technology, vendors, and legal obligations change.

XXXVII. HIPAA AND HEALTH-RELATED INFORMATION

Empowering The Childless Woman provides educational, coaching, personal-development, and community Services.

The fact that you may voluntarily provide information concerning infertility, pregnancy loss, reproductive health, physical health, mental health, grief, counseling, or another health-related matter does not automatically mean that the information constitutes “protected health information” under the federal Health Insurance Portability and Accountability Act (“HIPAA”).

Unless you are specifically informed that a particular Service is being provided through a HIPAA-covered arrangement, you should not assume that information submitted through the Services is protected by HIPAA.

Certain information that is not protected by HIPAA may nevertheless qualify as sensitive data or consumer health data and receive protections under Connecticut law.

Connecticut law separately exempts certain information already governed by HIPAA while imposing consumer-health-data obligations on information falling within the CTDPA framework.

XXXVIII. THIRD-PARTY LINKS AND SOCIAL MEDIA

The Services may contain links to independently operated websites, social-media platforms, applications, or other third-party services.

This Privacy Policy does not govern those third parties' independent privacy practices.

Empowering The Childless Woman may also maintain accounts on platforms such as Facebook, Instagram, YouTube, LinkedIn, TikTok, or other social-media services.

When you interact with us through a social-media platform, the platform may independently collect information about you under its own privacy policy and terms.

Information you publicly post on social media may be visible to others.

Personal information that we receive directly through our social-media accounts will be handled under this Privacy Policy to the extent applicable.

XXXIX. CONTACT US

If you have questions regarding this Privacy Policy, our privacy practices, or your Connecticut privacy rights, please contact:

Empowering The Childless Woman
Attn: Privacy
Wendy Ackley
341 Quaddick Road
Thompson, CT 06277

Email: [email protected]

For Connecticut privacy requests:

Subject: Connecticut Privacy Rights Request

For appeals:

Subject: Connecticut Privacy Rights Appeal

For withdrawal of consent:

Subject: Withdraw Privacy Consent

We will make reasonable efforts to respond to privacy inquiries, authenticated requests, and appeals in accordance with applicable Connecticut law.

  1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in:

  • Connecticut law;
  • our Services;
  • application features;
  • technology;
  • vendors;
  • data-processing activities; or
  • our business practices.

When we update this Privacy Policy, we will revise the “Last Updated” month and year at the beginning of the Policy.

Where Connecticut law requires additional notice or consent for a material change, we will provide such notice or obtain consent as required.

If a proposed change materially alters the way we process information previously collected, we will provide any additional protections required under Connecticut law.

Your continued use of the Services does not waive any privacy rights provided by Connecticut law.

XLI. AVAILABILITY OF THIS PRIVACY POLICY

We will make this Privacy Policy reasonably accessible to consumers.

Where applicable, this Privacy Policy may be available through:

  • a conspicuous Privacy link on our website;
  • the Empowering The Childless Woman mobile application's download or application-store page;
  • a settings menu or another conspicuous location within the mobile application; and
  • other locations required by applicable Connecticut law.

We will also take reasonable steps to make this Privacy Policy accessible to individuals with disabilities and available in additional languages where required by applicable law.