1. Introduction

This Privacy Policy describes how Larisa Miller and Phoenix Global Group Holdings (collectively, “we,” “us,” or “our”) collect, use, share, and protect personal information when you visit larisamiller.com (the “Site”) or interact with us through the Site. We respect your privacy and are committed to handling your personal information in accordance with applicable data protection laws, including the European Union General Data Protection Regulation (GDPR), the United Kingdom GDPR, the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Brazil’s Lei Geral de Protecao de Dados (LGPD), China’s Personal Information Protection Law (PIPL), and Australia’s Privacy Act and Australian Privacy Principles (APP).

2. Information We Collect

2.1 Information You Provide Directly

We collect information you provide directly to us when you: (a) subscribe to our newsletter, Book Club, book waitlist, or press list; (b) pre-order a book or other product; (c) submit an inquiry through any contact form, including press, speaking, or advisory inquiries; (d) participate in events such as Book Club Zoom sessions; or (e) communicate with us by email or other means. The information we collect directly may include: your name, email address, postal address (for book fulfillment), phone number (when provided), organization, professional title, payment information (handled by our payment processor), inquiry content, and any other information you choose to provide.

2.2 Information Collected Automatically

When you visit the Site, we automatically collect certain information about your device and your interaction with the Site. This information is collected through Google Analytics, which is the only third-party analytics service used on the Site as of the effective date of this Policy. Information collected automatically may include: IP address (anonymized where required by law), browser type and version, operating system, referring website, pages visited and time spent on each page, approximate geographic location (derived from IP address), and device information.

2.3 Cookies and Similar Technologies

The Site uses cookies and similar tracking technologies. As of the effective date, the only cookies used by the Site are those set by Google Analytics for traffic measurement. We do not use advertising cookies, behavioral tracking cookies, or third-party marketing pixels. You can control cookies through your browser settings and through the cookie consent banner that appears on your first visit to the Site. EU, UK, and California visitors have specific rights regarding cookie consent, described in Section 7 below.

3. How We Use Your Information

We use the information we collect for the following purposes: (a) to provide and operate the Site, including delivering content you have requested; (b) to fulfill book orders and process payments; (c) to send you newsletter content, book launch updates, and other communications related to the lists you have subscribed to; (d) to respond to inquiries from press, speakers’ bureaus, advisory prospects, and other contacts; (e) to schedule and host Book Club Zoom sessions and Founders Circle events; (f) to analyze Site usage and improve the Site’s content and functionality; (g) to comply with legal obligations and protect our rights and the rights of others. We do not use your information for automated decision-making that produces legal or similarly significant effects.

4. Legal Basis for Processing (EU/UK Visitors)

For visitors located in the European Union, the United Kingdom, or other GDPR-regulated jurisdictions, our legal bases for processing personal information are: (a) your consent, when you subscribe to a newsletter or other list; (b) the performance of a contract, when you place a pre-order or purchase; (c) our legitimate interests in operating, securing, and improving the Site, when balanced against your interests and rights; and (d) compliance with legal obligations. You may withdraw consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

5. How We Share Your Information

We share your information only as described in this Policy. We share information with: (a) service providers who help us operate the Site, including Kit (formerly ConvertKit) for email management, Google for Google Analytics, the payment processor identified at checkout, and Zoom for Book Club and Founders Circle sessions. These service providers are contractually obligated to handle information in accordance with applicable law and only for the purposes for which we provide it to them. (b) Legal authorities when required by applicable law, court order, or governmental request. (c) Successors in interest if we sell or transfer all or part of our business. We do not sell your personal information, and we do not share it with third parties for their own marketing purposes.

6. International Data Transfers

The Site is operated from the United States. If you are located outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States. Some of our service providers may also process your information in other jurisdictions. We rely on appropriate safeguards for international transfers, including standard contractual clauses or equivalent mechanisms recognized under applicable law.

7. Your Rights

7.1 Rights Available to All Users

Regardless of your location, you may: (a) request access to the personal information we hold about you; (b) request correction of inaccurate information; (c) request deletion of your personal information, subject to certain legal exceptions; (d) unsubscribe from email communications at any time using the link in any email or by contacting us; (e) request that we limit the way we use your information.

7.2 GDPR Rights (EU and UK Visitors)

In addition to the rights above, EU and UK visitors have the right to: (a) data portability (receive your information in a structured, commonly used format); (b) restrict processing in certain circumstances; (c) object to processing based on legitimate interests; (d) lodge a complaint with a supervisory authority, including the Information Commissioner’s Office in the UK or the relevant Data Protection Authority in your EU member state.

7.3 CCPA/CPRA Rights (California Residents)

California residents have the right to: (a) know what personal information is collected, used, shared, or sold; (b) delete personal information held by us; (c) opt out of the sale or sharing of personal information (we do not sell personal information); (d) correct inaccurate personal information; (e) limit the use of sensitive personal information; (f) non-discrimination for exercising privacy rights.

7.4 LGPD Rights (Brazilian Visitors)

Brazilian visitors have rights under LGPD substantially equivalent to GDPR rights, including the right to confirmation of processing, access, correction, anonymization, deletion, portability, and information about sharing.

7.5 PIPL Rights (Chinese Visitors)

Visitors from China have rights under PIPL including access, correction, deletion, restriction, portability, and withdrawal of consent.

7.6 PIPEDA and APP Rights (Canadian and Australian Visitors)

Canadian and Australian visitors have rights under PIPEDA and APP including access, correction, and the ability to file complaints with the Office of the Privacy Commissioner of Canada or the Office of the Australian Information Commissioner, respectively.

7.7 How to Exercise Your Rights

To exercise any of these rights, please contact us at Larisa@LarisaMiller.com. We will respond within the timeframes required by applicable law, typically within thirty days for most requests. We may need to verify your identity before fulfilling certain requests.

8. Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected or as required by applicable law. Email subscribers’ information is retained for as long as the subscription is active, plus a reasonable archival period after unsubscription. Order information is retained for as long as required by applicable tax, accounting, and consumer-protection law. Inquiry information is retained for a reasonable period after the inquiry has been resolved.

9. Security

We implement reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encrypted transmission of payment information through our payment processor, encrypted storage of email subscriber information through Kit, and access controls on the systems where personal information is stored. However, no system is completely secure, and we cannot guarantee absolute security of your information.

10. Children’s Privacy

The Site is not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without verifiable parental consent, we will take steps to delete that information. If you believe we have collected information from a child under 16, please contact us at Larisa@LarisaMiller.com.

11. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top indicates the most recent revision. Material changes will be communicated through a notice on the Site or by email to subscribers. Your continued use of the Site after changes take effect constitutes acceptance of the revised Policy.

13. Data Controller and Contact Information

The data controller for personal information collected through this Site is Larisa Miller / Phoenix Global Group Holdings. For privacy-related questions, requests to exercise your rights, or any other privacy matters, please contact:

Larisa Miller

Email: Larisa@LarisaMiller.com

Phone: +1.910.391.5215

Website: www.LarisaMiller.com