Privacy Policy

Wisdom Into Practice ("we," "us," or "our") is operated by EntrepreNEW, Inc., a Florida S-Corporation, which operates the website wisdomintopractice.com and related services, including the courses and coaching of Damian Martinez, and is responsible for the personal information described in this policy. This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you use our website, free guides and quizzes, email communications, community membership, courses and other digital products, physical products, coaching and consulting services, custom projects, and related systems, including when you purchase or take part in coaching or sign a coaching agreement. This policy applies to visitors and customers worldwide, including those in the European Union, United Kingdom, Canada (including Quebec), Australia, Brazil, Japan, and South Korea.

By using our services, you consent to the data practices described in this Privacy Policy. If you do not agree with our policies and practices, do not use our services.

This Privacy Policy, our Terms of Service, and our Refund Policy are shared by the websites that EntrepreNEW, Inc. operates. A part of this policy that describes a particular product, service, or system applies only where that product, service, or system is used on the website you are visiting or for a purchase you make.

1. Information We Collect

Information You Provide

• Account and contact information: Full name, email address, phone number (if provided, for example when you book a session), mailing address (for physical product orders), and password (encrypted) where you create an account
• Email sign-up (free guides and quizzes): Name (optional), email address, signup source and entry point, and your quiz answers and result where you take a quiz
• Contact form: Name, email, message content
• Community membership (Skool): Name, email, payment information via Stripe
• Course and digital product purchases: Name, email, billing address, payment information via Stripe, transaction history and purchase records (courses, commentary edition bundles, paid PDF guides, audio commentary tracks, video masterclass content, and other digital products)
• Physical product orders: Name, email, shipping address, phone number where a carrier requires one, and the items ordered
• Personalized products: The photographs and wording you upload or enter, the preview you approve, and any low-resolution acknowledgment you give before purchase
• Coaching, consulting, and intensives: Name, email, billing information, scheduling preferences, session scheduling information (calendar events and video meeting links), and topics and questions submitted before a session
• Make Your Next Moves coaching: Name, email, phone number, billing information and Stripe Checkout session and payment references, intake questionnaire answers, booking details, materials you email us between sessions, notes or follow-up communications, audio and video recordings and written transcripts of every session, and your coaching agreement signing record (see Section 5A)
• 30-Day Cohort enrollment: Name, email, billing information
• Book purchases (Amazon KDP): Handled by Amazon. We receive order data but not payment details
• Communication data: Customer support inquiries, email correspondence, newsletter subscription preferences, and feedback and survey responses
• AI guide conversations: Where the website offers our AI guide, the messages you type to it (see Section 3)

Payment Information

Credit card or payment method details are processed securely by Stripe. We do not store full card numbers.

Information Collected Automatically

• IP address, browser type and version, device type (desktop, mobile, tablet), operating system, screen resolution, and language preferences
• Pages visited and navigation paths, time spent on pages, scroll depth, click patterns and interactions, referring website or source, exit pages, and date and time of visits
• Cookie and session identifiers
• Meta Pixel events (page views, form submissions, button clicks), loaded only when your consent state allows it
• Google Analytics 4 events (server-side and client-side), loaded only when your consent state allows it
• Server-side Conversions API data sent to Meta Platforms, subject to your cookie consent preferences

Analytics, advertising, and our own first-party usage measurement run only when your cookie choice allows it, as described in Section 6 and Section 21.

Information Generated Through Delivery and Access Systems

• Magic link authentication data: email verification against Stripe purchase records, single-use token generation, token activation timestamps and IP addresses, session cookie grant and expiration
• Download access logs: Cloudflare R2 presigned URL generation and first-use activation timestamps, IP addresses
• Streaming access logs: Bunny.net session data including stream start, duration, device information, and bandwidth
• Course account and access records
• Email delivery confirmations: delivery receipts from our email provider confirming successful message delivery
• Checkout acceptance records: the exact text and version of your checkout consent (including the text of the checkout box you checked and the version of each policy it names), the date and time recorded by our server, the IP address at which consent was provided, and device/browser information, kept with your order
• Coaching agreement signing records: your name and email, the date and time of signing, your browser's time zone, the agreement version, the order it relates to, cryptographic hashes of the signed document, non-reversible fingerprints of the IP address and browser used to sign, and the signed document itself

Information from Third Parties

• Payment processors: transaction confirmation from Stripe, payment status updates, and fraud detection alerts
• Advertising and analytics partners: Meta (Facebook/Instagram) Pixel data for ad performance measurement and Google Analytics data for website usage analysis
• Fulfillment partner and carriers: production, shipment, tracking, and delivery events for physical products

2. How We Use Your Information

To Provide Our Services

• Deliver free guides and quiz results by email (including a weekly Monday digest where offered, and immediate delivery for new signups)
• Process purchases of courses and digital products and deliver content and access through account access, email download links, and gated streaming pages
• Operate passwordless magic link authentication to verify access to purchased gated content
• Process community membership payments and manage access via Skool
• Make, ship, and deliver physical and personalized products, and handle replacements and refunds
• Schedule and deliver coaching, consulting, and intensive sessions by live video (such as Google Meet or Zoom)
• Deliver Make Your Next Moves coaching, including booking sessions, recording and transcribing every session, sending you a copy after each session, preparing for your next session, and keeping your coaching record (see Section 5A)
• Keep records of what you agreed to at checkout and of your signed coaching agreement, and use them to show what was agreed, including in a payment dispute
• Manage your account and order history and provide customer support
• Answer your questions through our AI guide, where offered

To Communicate With You

• Send transactional emails (order confirmations and receipts, delivery and access links, magic link authentication, shipping and tracking, membership updates)
• Send session reminders and follow-ups by email and, if you gave us a mobile number, by text message
• Send newsletter content and promotional offers (with your consent)
• Provide customer support responses

To Improve Our Services

• Analyze site usage and usage patterns to improve content and user experience
• Debug technical issues
• Develop new products and content
• Understand audience preferences and behavior

To Advertise and Measure Performance

• Operate targeted advertising campaigns on Meta platforms (Facebook, Instagram) and, where used on the website, other advertising platforms (with your consent where required)
• Measure advertising campaign effectiveness and track conversions from ads to purchases
• Create custom and lookalike audiences for ad targeting

To Protect Our Services

• Prevent fraud, spam, unauthorized access, misuse, and abuse
• Enforce our Terms of Service
• Maintain delivery and access evidence for payment dispute resolution and chargeback defense
• Comply with legal, tax, and accounting obligations

3. How We Share Information

We do not sell your personal information in the traditional sense, and we do NOT sell personal information as defined by the CCPA. However, our use of the Meta Pixel, the Meta Conversions API, and Google Analytics for advertising measurement may constitute "sharing" or "targeted advertising" under certain US state privacy laws (see Section 10).

Service Providers

We share data with these categories of service providers, solely for the purposes described:

• Stripe: Payment processing for all purchases (courses, community membership, digital products, physical products, coaching, Make Your Next Moves, consulting, intensives, cohort enrollment). Stripe acts as an independent controller for payment processing.
• Meta Platforms (Facebook/Instagram): Advertising pixel and Conversions API for campaign optimization and measurement, loaded only when your consent state allows it. Meta acts as an independent controller for advertising data.
• Google: Analytics (GA4), and Google Calendar, Google Meet, and Google Workspace (session booking and video sessions, business email and documents, and storage of coaching recordings and transcripts), and Google Fonts (web fonts). Analytics loads only when your consent state allows it.
• Video meeting and calendar providers (such as Google Meet, Google Calendar, or Zoom): Booking and hosting live coaching sessions. For Make Your Next Moves, sessions are recorded and transcribed using the platform's own recording and transcription features, and recordings and transcripts are stored securely in our business accounts.
• Cloudflare: CDN, DNS, security, approximate country lookup, and R2 object storage (guide PDF and digital product delivery via presigned URLs, website backups, and personalized product uploads where used).
• Bunny.net: Audio and video streaming hosting and delivery for gated content, course videos, and offer videos. Bunny.net logs streaming access events.
• Twilio: SMS notification delivery for coaching session booking confirmations, reminders, and operational alerts. Twilio acts as a data processor for SMS delivery only.
• YouTube: Free video hosting for show episodes.

Services Used on This Website

• Mailtrap: Email delivery for guides, transactional emails, magic link authentication, and order confirmation emails. Mailtrap acts as a data processor on our behalf.
• Google Tag Manager and reCAPTCHA: Tag management, and spam prevention on forms. reCAPTCHA is essential and loads for every visitor; tags managed through Google Tag Manager load only when your consent state allows it.
• Pinterest: Pinterest Tag and Conversions API for advertising measurement. The tag loads only after your consent state allows advertising technology, and server-side events follow the same consent choice.
• ElevenLabs: Audio content production (AI narration). ElevenLabs does not process personal customer data.
• Skool: Community platform hosting for paid membership, including affiliate commission tracking.
• Printify and its print partners: Production and shipping of physical products ordered in our shop. We share your name, shipping address, email address, phone number where a carrier requires one, and the items ordered, solely to make and deliver your order. For personalized products, we also share the print file made from the content you supplied.
• Shipping carriers and customs authorities: Postal services and couriers (for example USPS, UPS, FedEx, DHL, and national postal operators) receive your name, delivery address, and contact details to deliver your parcel. For orders shipped outside the United States, the carrier and the customs authority of the destination country receive the information required on customs declarations, including the recipient's name and address and a description and value of the contents.
• OpenAI: Generates replies for our AI guide (see AI Guide below).
• Amazon KDP: Book sales and fulfillment. Amazon handles all customer data for book purchases independently. Links to Amazon on our website may carry Amazon Attribution tags so we can measure which pages lead to book sales; we do not send your personal information to Amazon through these links.
• UpdraftPlus: Website backups.
• Vultr and SpinupWP: Server hosting and server management.
• Our own website database: Orders, Make Your Next Moves intake answers, checkout acceptance records, and signing records, our lead and email system, and our first-party analytics are stored in our own website database.

AI Guide

Where the website offers our AI guide, the messages you type and the page you are on are sent to our AI provider, OpenAI, to generate replies, and the conversation is stored in our Cloudflare database so the guide can continue it. Conversations and sessions that have been idle for more than 30 days are deleted automatically by a daily process. Please do not enter sensitive personal information in the AI guide.

Legal Requirements and Business Transfers

We may also disclose information: when required by law, subpoena, court order, or legal process; in response to lawful requests from public authorities; to protect our rights, property, or safety; to enforce our Terms and investigate potential violations of them; to prevent fraud or illegal activity; and in connection with a merger, acquisition, reorganization, or sale of assets (subject to confidentiality obligations). If our business is acquired, merged, or sells assets, your information may be transferred as part of that transaction, and you will be notified of any change in ownership or control.

What We DO Share

• Data with service providers to operate our business
• Data when legally required
• Analytics and conversion data with ad platforms when your consent state allows it (pseudonymized, for example a hashed email address)

What We DON'T Do

• Sell your personal data to data brokers
• Share data for unrelated third-party marketing
• Provide your info to spam lists
• Sell or rent your email address
• Use coaching recordings or transcripts in marketing without your written permission

4. Legal Bases for Processing (GDPR)

Where the General Data Protection Regulation (GDPR) or UK GDPR applies, we process personal data on the following legal bases:

Where we rely on legitimate interests (Art. 6(1)(f)), we have conducted a balancing assessment and determined that our interests do not override your rights and freedoms, taking into account the necessity and proportionality of the processing and the safeguards in place.

5. Data Retention

Data Deletion Requests

You may request deletion of your personal data by emailing support@mybiblekit.com. We will process deletion requests within 30 days (45 days for California residents), retain data required by law (tax records, transaction history), and confirm deletion in writing. We may also keep checkout acceptance records, signed coaching agreements, coaching records, active dispute records, and chargeback defense evidence where we need them to meet legal obligations, resolve disputes, or enforce our agreements, and we will tell you what we keep and why.

5A. Coaching Recordings, Transcripts, and Agreements

Session Recordings and Transcripts

Make Your Next Moves sessions are recorded (audio and video) and transcribed. This is a required part of the coaching, stated on the offer page before purchase and agreed in the signed coaching agreement. Sessions are held on a video meeting platform such as Google Meet or Zoom and are recorded and transcribed using that platform's recording and transcription features. Recordings and transcripts are stored securely in our business accounts. Transcripts are produced by automated speech-to-text. We use recordings and transcripts to deliver and support your coaching, for example to prepare for your next session, and to keep a record of our services.

• Your copy: we send you a copy of the recording and transcript after each session
• Who can access them: you, Damian Martinez, and EntrepreNEW, Inc. personnel and service providers only as needed to deliver and support your coaching
• How they are protected: they are stored securely in access-controlled business accounts and shared with you through private, access-controlled links. They are not posted on public pages and are not used for advertising or marketing analytics. The only exception is the marketing clips described below
• Other attendees: anyone else who attends a session must consent before being recorded. Their voice, image, and what they say will appear in the recording and transcript
• Marketing clips: Damian may use short clips of his own portion of a session in his marketing, showing only himself and nothing that identifies you or your business. Anything that shows or identifies you or your business, including quotes, images, or testimonials, is never used publicly without your separate written permission
• How long we keep them: recordings and transcripts are kept as part of your coaching record and are not automatically deleted after a set period. You can ask for access to them or ask us to delete them as described in Section 7. We may keep what we need to meet legal obligations, resolve disputes, or enforce our agreements

Coaching Agreement Signing Records

Before any session is held or recorded, each Make Your Next Moves client electronically signs our coaching agreement. We keep the signed agreement and a record of the signing (your name and email, the date and time of signing, your browser's time zone, the agreement version, the order it relates to, cryptographic hashes of the signed document, and non-reversible fingerprints (salted hashes) of the IP address and browser used to sign) as contract records. Signed agreements are stored privately, outside the public website. A copy of your signed agreement is sent to you by email, and you can view and download it from your private booking page. Access to these records is limited to people who need it to provide and administer the service.

Checkout Agreement Records

When you check the box "I agree to the Terms of Service, Privacy Policy, and Refund Policy." at checkout, our server records that you agreed, the exact text, the version of each document, and the date and time, together with your order, as described in Section 1 (Checkout acceptance records). Our checkout systems may also record your IP address with the order; where we record it for Make Your Next Moves, it is stored in a non-reversible (hashed) form. Agreeing at checkout is not consent to marketing email. Marketing email is a separate choice that you can withdraw at any time.

Separate From Your Cookie Choices

These records are needed to provide the service you bought and to keep contract and legal records. They are kept whether or not you accept analytics and advertising cookies. Choosing Essential Only in Cookie Settings, or sending a Global Privacy Control signal, does not delete them and does not stop us from processing your order, booking, or agreement.

5B. RUSS Links and Referrals

Wisdom Into Practice may link visitors to RUSS, an AI business guide sold and operated by EntrepreNEW, Inc. on damianmartinez.com. Those links may carry a referral label (for example "wip") so we know which website a visitor came from. Wisdom Into Practice does not store RUSS conversations, business profiles, credit balances, payment card details or PDFs. RUSS account, purchase, usage and PDF records are handled on damianmartinez.com as described in its Privacy Policy, Section 5B.

Contact, quiz and email records you give Wisdom Into Practice separately remain covered by this Privacy Policy. Visiting RUSS or buying it is not consent to marketing email. Signing up for or buying from Wisdom Into Practice does not sign you up for RUSS email.

5C. Bible Study Studio and MyBibleKit.com

Bible Study Studio runs on wisdomintopractice.com/study/ and MyBibleKit.com. Both are operated by EntrepreNEW, Inc. and use one shared customer system, so the information below is the same whichever website you use, and your account, studies and credits appear on both.

What we collect

• Account: your email address, and a record of the 6-digit sign-in codes we send (stored only in a scrambled form, used once, valid for 15 minutes) and of your signed-in sessions (a secure cookie on the website you signed in on).
• Orders and studies: what you chose to study, your study settings (who it is for, depth, meeting length, and any group name, leader name or meeting date you type), order status, and the files made for you.
• Membership and credits: membership status and billing dates from Stripe, and a permanent record of credits added, used, bought, returned, removed or expired.
• Payments: handled by Stripe. We receive the payment result and a customer reference; we do not receive or store your full card number.
• Which website you used: recorded on orders and memberships for support and reporting.

How we use and store it

We use this information to make and deliver your studies, run your membership and credits, sign you in, send order, sign-in and membership emails, prevent fraud and abuse, and provide support. Study files are stored privately (Cloudflare R2) and can be downloaded only by you, or through a Leader's Study Kit group link for that group's participant pages. MyBibleKit.com is served through Cloudflare, which passes requests to our systems without storing your account data. Emails are sent through our email delivery providers. Analytics and advertising tags on both websites follow your choices in our consent banner, as described in Sections 6 and 21.

The research and writing behind your study use AI services. We send them the Scripture, research and study settings needed to write your study, not your payment details. We keep order, membership and credit records for as long as your account exists and as required for tax, accounting and dispute purposes (Section 5). Your rights in Sections 7 to 14A apply; contact support@mybiblekit.com (or support@mybiblekit.com).

Studies can be made for children's groups, but accounts and purchases are for adults; we do not knowingly collect personal information from children (Section 15).

6. Cookies and Tracking Technologies

Meta (Facebook) Pixel

We use the Meta Pixel on our website to measure the effectiveness of our advertising, understand user actions on our site, and deliver targeted advertisements. The Meta Pixel collects data about your activity on our site and sends it to Meta. This may include pages viewed, products purchased, and actions taken. You can opt out of Meta's targeted advertising through your Facebook ad settings or by using the Digital Advertising Alliance's opt-out tool.

Google Analytics and the Google Tag

We use Google Analytics to analyze website traffic and usage patterns. Google Analytics uses cookies to collect anonymized information about how visitors use our site. You can opt out by installing the Google Analytics opt-out browser add-on. Google Analytics loads through the Google tag (gtag.js) or Google Tag Manager, which are served from Google's googletagmanager.com domain, and they load only when your consent state allows it.

Cookie Consent Banner

If you are browsing from a jurisdiction whose law requires your permission before non-essential cookies are used, you will see a banner offering "Allow All" and "Essential Only". Allow All allows analytics and advertising technology (Google Analytics, the Meta Pixel and other advertising tags, and our own first-party site analytics) to load, and allows attribution measurement. Essential Only turns off analytics and advertising cookies and keeps all of that technology switched off; only cookies strictly necessary to operate the site are used. Until you choose, none of that technology loads and no attribution is recorded. This complies with Article 5(3) of the ePrivacy Directive (2002/58/EC) and the UK Privacy and Electronic Communications Regulations 2003 (PECR). Strictly necessary cookies do not require consent and are always active.

If you are browsing from a jurisdiction that does not require prior consent, including the United States, analytics and advertising technology loads without a banner, except that advertising and sharing technology does not load if your browser sends a Global Privacy Control signal. You can still opt out at any time using the "Cookie Settings" link in the site footer. The jurisdictions that see the banner are listed in Section 21.

Changing Your Mind and Global Privacy Control

You can reopen your choice at any time using the "Cookie Settings" link in the site footer, which clears your stored choice, reopens the banner, and lets you change your decision in any region. We honor the Global Privacy Control (GPC) signal in every region as an opt-out of advertising and sharing, without requiring any action from you. When your browser or extension sends GPC, advertising and sharing technology is turned off: the Meta Pixel and Meta Conversions API, Google advertising signals, and any other advertising or conversion pixel do not run, and no advertising or conversion events are sent from our server to Meta or other advertising platforms. GPC does not change your analytics choice: Google Analytics, our first-party site analytics, and attribution measurement follow the choice you make in the banner (or, where no banner is required, run unless you choose Essential Only). When GPC is present, some measurement may also be skipped; for example, a purchase confirmed by our payment provider may not be reported to Google Analytics from our server, and our attribution beacon may not run. If you choose Essential Only after choosing Allow All, these technologies stop on the current page and do not run on later pages.

Managing Cookies and Opt-Out Options

You can control cookies through your browser settings. Disabling essential cookies may prevent you from using certain features of our website, including making purchases. You may also opt out of specific tracking via: Meta tracking at facebook.com/settings; Google Analytics at tools.google.com/dlpage/gaoptout; the Digital Advertising Alliance tool at optout.aboutads.info; or by enabling Global Privacy Control (GPC) in your browser.

Do Not Track

We do not currently respond to "Do Not Track" browser signals. However, you can opt out of analytics and advertising tracking using the tools described above, and we honor Global Privacy Control.

Server-Side Measurement

In addition to the technology running in your browser, we send certain conversion events directly from our server to Meta (via the Conversions API), to Google Analytics 4, and to other advertising platforms listed in Section 3 where used. These events may include the identifiers described in Section 21 and a SHA-256 hashed form of your email address where you have provided one; we do not transmit your email address in readable form. This is subject to the same consent choice described above. If no consent is recorded for you, for example when your purchase is confirmed by our payment provider and your browser choice is not known, no event is sent to Meta or Google.

First-Party Site Analytics

When your consent state allows it, our own measurement tool records how our pages are used: the pages you view and their titles, time on each page, scroll depth, clicks, the landing page and referring page, your device type, browser, and operating system, a random visitor identifier, and your account identifier if you are signed in. This data stays in our own website database and is deleted automatically as stated in Section 5.

Other Services That Load on Our Pages

Some services load for every visitor because they deliver parts of the page itself. Cloudflare handles every request to our site. Depending on the page, fonts may load from Google Fonts, video players from Bunny.net or YouTube, and other page features from the providers listed in Section 3. When these load, the provider receives your IP address and browser information, and some may set their own cookies. If you send a chat message through a live chat window, the chat provider processes it so that we can reply.

7. Your Rights (All Users)

Regardless of location, you have the right to:

• Access: Request a copy of your personal information
• Correct: Fix inaccurate or incomplete data
• Delete: Request deletion of your account and personal data (subject to legal and contractual retention exceptions, including tax records, active dispute records, and chargeback defense evidence; see Section 5)
• Opt out: Unsubscribe from marketing and guide emails via the link in any email. Opt out of SMS via STOP. Opt out of advertising tracking via Cookie Settings or GPC
• Withdraw consent: Revoke previously given consent at any time
• Portability: Get your data in a portable format

To exercise any right, contact us at support@mybiblekit.com. We respond within the timeframe required by applicable law, and process deletion requests within 30 days as described in Section 5.

8. EU/UK Data Subject Rights (GDPR)

If you are in the European Economic Area (EEA) or United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) / UK GDPR:

• Right of access (Art. 15): Obtain confirmation of whether we process your data and request a copy
• Right to rectification (Art. 16): Correct inaccurate or incomplete personal data
• Right to erasure / right to be forgotten (Art. 17): Request deletion of your data, subject to overrides for legal obligations (tax records), legitimate interests (dispute defense), and freedom of expression
• Right to restriction of processing (Art. 18): Request that we restrict processing in certain circumstances
• Right to data portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format and transmit it to another controller (applies to data processed by consent or contract and by automated means)
• Right to object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes. You have an absolute right to object to direct marketing at any time
• Right not to be subject to automated decision-making (Art. 22): Not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects (see Section 17)
• Right to withdraw consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal

To exercise any right, contact us at support@mybiblekit.com (you may use the subject line "GDPR Request"). We may ask you to verify your identity before fulfilling your request. We will respond within one month of receiving your request, extendable by two months for complex or numerous requests (Art. 12(3)).

Right to lodge a complaint: You have the right to lodge a complaint with your local supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk. In the EU, contact your national data protection authority.

9. International Data Transfers

We are based in the United States and use US-based service providers. If you access our services from outside the United States, your personal data will be transferred to, stored, and processed in the United States and other countries that may not provide the same level of data protection as your country of residence.

EU/UK transfers: We transfer personal data from the EEA and UK to the United States relying on the EU-US Data Privacy Framework and the UK Extension (UK-US Data Bridge) where our service providers are certified, and on the European Commission's Standard Contractual Clauses (SCCs) with supplementary measures where they are not certified, or on your explicit consent. For the UK, we also rely on the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs where applicable.

Other international transfers: For transfers from other jurisdictions (including Canada, Australia, Brazil, Japan, and South Korea), we rely on the transfer mechanisms recognized by the applicable data protection law of your jurisdiction, including your consent to the transfer as part of your use of our Services.

Shipping to your country: When you order a physical product for delivery outside the United States, the details needed to deliver it are necessarily transferred to carriers and customs authorities in and on the way to your country. This transfer is necessary to perform the contract you enter into when you place the order.

You may request a copy of the relevant transfer safeguards by contacting us at support@mybiblekit.com.

10. US State Privacy Rights

If you are a resident of a US state with applicable comprehensive consumer privacy legislation (including but not limited to California CCPA/CPRA, Virginia VCDPA, Colorado CPA, Connecticut CTDPA, Texas TDPSA, Oregon, Montana, Indiana, Tennessee, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Minnesota, Maryland, Kentucky, Rhode Island, and additional states as their laws take effect), you may have the right to:

• Know what personal data we collect and how it is used
• Request deletion of your personal data
• Correct inaccuracies in your personal data
• Request portability of your personal data in a usable format
• Opt out of the sale, sharing, or use of your personal data for targeted advertising
• Limit certain uses of sensitive personal data (where applicable)
• Not be discriminated against for exercising your privacy rights

California residents (CCPA/CPRA): California residents have the right to know what personal information is collected, the right to request deletion, and the right to opt out of the sale or sharing of personal information. We do NOT sell personal information as defined by the CCPA. To exercise California rights, email support@mybiblekit.com with the subject line "CCPA Request." We will respond within 45 days.

"Do Not Sell or Share": Our use of the Meta Pixel, the Meta Conversions API, Google Analytics, and other advertising tags for advertising measurement and optimization may constitute "sharing" of personal information or "targeted advertising" under applicable US state privacy laws (including the CCPA/CPRA definition of "sharing" for cross-context behavioral advertising). To opt out, choose Essential Only in our "Cookie Settings," click the "Do Not Sell or Share My Personal Information" link on our website, or enable Global Privacy Control (GPC) in your browser, which we treat as an opt-out of advertising and sharing (see Section 6). We honor recognized universal opt-out mechanisms including GPC.

To submit a privacy rights request, contact us at support@mybiblekit.com. We respond within the timeframe required by applicable law (45 days under CCPA/CPRA, 45 days under most other state laws). You may also designate an authorized agent to submit a request on your behalf, subject to identity verification.

11. Canadian Privacy Rights

If you are a resident of Canada, your personal information is protected under the Personal Information Protection and Electronic Documents Act (PIPEDA), and if you reside in Quebec, under the Act respecting the protection of personal information in the private sector (as amended by Law 25). You have the right to: access your personal information held by us; request correction of inaccurate information; withdraw consent for non-essential processing, with withdrawal taking effect going forward where we rely on consent; and file a complaint with the Office of the Privacy Commissioner of Canada (OPC) or, in Quebec, the Commission d'acces a l'information (CAI). If you are in Quebec, you may also request that we cease disseminating your information and may exercise rights of de-indexation. We comply with the Canadian Anti-Spam Legislation (CASL) for all commercial electronic messages sent to Canadian recipients.

12. Brazilian Privacy Rights (LGPD)

If you are a resident of Brazil, your personal data is protected under the Lei Geral de Protecao de Dados (LGPD, Lei 13.709/2018). You have the right to: confirm the existence of processing; access your data; correct incomplete, inaccurate, or outdated data; request anonymization, blocking, or deletion of unnecessary or excessive data; request data portability; request deletion of data processed with consent; obtain information about public and private entities with which we share data; be informed about the possibility of not providing consent and the consequences; and revoke consent. To exercise these rights, contact us at support@mybiblekit.com. You may also file a complaint with the Autoridade Nacional de Protecao de Dados (ANPD).

13. Japanese Privacy Rights (APPI)

If you are a resident of Japan, your personal information is protected under the Act on the Protection of Personal Information (APPI). We specify the purposes of use of your personal data, handle data securely, and provide mechanisms for disclosure of the personal information we hold, its correction or deletion, and cessation of its use or provision to third parties. We disclose cross-border data transfers to the United States and employ appropriate security measures for such transfers. To exercise your rights, contact us at support@mybiblekit.com. We will respond within a reasonable period.

14. South Korean Privacy Rights (PIPA)

If you are a resident of South Korea, your personal information is protected under the Personal Information Protection Act (PIPA). We collect and process your data only with appropriate consent, specify purposes of use, and implement security measures for cross-border data transfers. You have the right to access, correct, delete, and suspend processing of your personal data, and may withdraw consent at any time. To exercise your rights, contact us at support@mybiblekit.com. You may also file a complaint with the Personal Information Protection Commission (PIPC).

14A. Other Privacy Rights by Jurisdiction

Australia (Privacy Act 1988 and the Australian Privacy Principles): You may request access to and correction of your personal information, and may complain to the Office of the Australian Information Commissioner.

Switzerland (revised FADP): You have rights of access, rectification, deletion and objection substantially equivalent to those described in Section 8, and may complain to the Federal Data Protection and Information Commissioner.

India (DPDPA 2023): You may request access to a summary of the personal data we process, request correction or erasure, nominate another person to exercise your rights, and raise a grievance with us before approaching the Data Protection Board.

Other jurisdictions: Where you are in another jurisdiction listed in Section 21, including Argentina, Chile, Colombia, New Zealand, Thailand, Vietnam, the Philippines, Taiwan, Singapore, Malaysia, Indonesia, Israel, Turkey, the United Arab Emirates, Saudi Arabia, South Africa, Kenya and Nigeria, we will honor requests for access, correction, deletion and withdrawal of consent to the extent your local law provides them.

To exercise any of these rights, contact us at support@mybiblekit.com.

15. Children's Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from children under 18 (or under the applicable age of digital consent in your jurisdiction). If we become aware that we have collected personal information from a child, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, contact us at support@mybiblekit.com and we will delete the information promptly.

16. Data Security

We implement commercially reasonable, industry-standard technical and organizational security measures designed to protect your personal information, including:

• Encrypted transmission (SSL/TLS, HTTPS) across all pages and API endpoints
• Encrypted password storage
• Secure hosting infrastructure (Cloudflare CDN and SpinupWP-managed servers)
• Secure payment processing and storage of payment data by Stripe (PCI-DSS compliant; we do not store credit card numbers)
• Access controls and authentication mechanisms, with limited access to personal data on a need-to-know basis
• Rate limiting on forms and API endpoints, and honeypot spam protection on public forms
• Firewall and intrusion detection systems, regular security monitoring, and incident response procedures
• Coaching recordings, transcripts, and signed agreements kept in access-controlled accounts and storage, not published on public web pages

Security limitations: No method of transmission over the Internet or of storage is 100% secure, and we cannot guarantee absolute security of your data. If you believe your account has been compromised, contact support@mybiblekit.com immediately.

17. Automated Decision-Making

We do not use your personal data to make decisions based solely on automated processing (including profiling) that produce legal effects or similarly significant effects concerning you, as described in GDPR Article 22. Our use of analytics and advertising tracking (Meta Pixel, GA4) involves profiling for advertising purposes, which you can object to at any time (see Section 8, Right to Object). Stripe's fraud detection system (Radar) uses automated processing to assess transaction risk, but this does not produce legal effects on you; a declined transaction can be reattempted or resolved through alternative payment methods. Replies from our AI guide are generated automatically but do not make decisions about you.

18. Changes to This Privacy Policy

We may update this Privacy Policy at any time. When we make material changes, we will update the "Last updated" date at the top, notify you by email for significant changes, and may post a notice on our website. Continued use of our Services after notification constitutes acceptance of the updated policy. We will not retroactively apply material changes to data collected under a prior version without your consent where required by applicable law.

19. Contact

Wisdom Into Practice, operated by EntrepreNEW, Inc.
Email: support@mybiblekit.com
Website: wisdomintopractice.com/contact
Response Time: Within 48 hours.

Mailing Address: EntrepreNEW, Inc., PO Box 17463, West Palm Beach, FL 33416

20. SMS and Text Messaging

20.1 SMS Data We Collect

When you provide a mobile phone number for coaching booking confirmations and reminders or operational notifications, we collect and store the mobile phone number provided. This number is used exclusively for delivering transactional SMS notifications.

20.2 How We Use SMS Data

Mobile phone numbers are used exclusively to deliver transactional SMS notifications including coaching session reminders, booking confirmations, and operational alerts. We do not use mobile phone numbers for marketing, promotional messaging, or any purpose other than transactional notifications.

20.3 SMS Service Provider

SMS notifications are delivered through Twilio, Inc. Twilio processes the mobile phone number and message content on our behalf for the sole purpose of message delivery.

20.4 No Sharing of Mobile Information

No mobile information collected as part of the SMS notification program will be shared with or sold to third parties or affiliates for marketing or promotional purposes. Your mobile phone number is used solely for delivering transactional alerts as described in this policy and our Terms of Service.

20.5 SMS Opt-Out and Data Deletion

You may opt out of SMS notifications at any time by replying STOP to any message or contacting us at support@mybiblekit.com. Upon opt-out, your phone number will be removed from the SMS notification system. Message and data rates may apply. For help, reply HELP or contact support@mybiblekit.com.

21. Attribution & Tracking Technology

21.1 What attribution means here

When you arrive at wisdomintopractice.com, we record how you got here. This lets us understand which articles, guides, newsletters, emails, social posts and paid advertisements bring people to the site, so we can invest in what works. We call this "attribution". Attribution is measurement. We do not use it to build advertising profiles about you, sell your information, or make automated decisions that affect you.

21.2 How attribution is collected

Most pages on this site are served from a cache, which means the page you see was prepared in advance and our server does not run any code specific to you when you request it. Because of this, attribution is collected by a small piece of JavaScript that runs in your browser (an "attribution beacon"). The beacon reads information already present in your browser and in the address of the page you landed on, and sends it to our server.

The beacon runs only when there is something to record: either the web address you arrived on carries tracking information, or you arrived from an external website. In the second case it runs once per browsing session. It does not run if you choose Essential Only, and it may also be skipped when your browser sends GPC.

21.3 Marketing and click identifiers we read from the web address

Advertising and email platforms add identifiers to links so that clicks can be measured. When present in the address you arrive on, we read and store:

• Advertising click identifiers: fbclid (Meta: Facebook and Instagram), gclid (Google Ads), msclkid (Microsoft Advertising), ttclid (TikTok), twclid (X), epik (Pinterest), sclid (Snapchat), rdt_cid (Reddit), li_fat_id (LinkedIn), dclid (Google Display & Video 360)
• Campaign parameters: utm_source, utm_medium, utm_campaign, utm_term, utm_content
• Additional referral and email parameters, stored together as a single structured field: ref, source, via, si, igshid, mc_cid, mc_eid, mkt_tok, ck_subscriber_id, _ke, yclid, wbraid, gbraid, irclickid, cjevent, partner, aff, affiliate_id

21.4 Information the beacon reads from your browser

Where present, we read the _fbp and _fbc first-party cookies set by Meta's pixel, and the _ga Google Analytics cookie, from which we derive the client identifier only. If a Meta click identifier is present in the address but the _fbc cookie is not, we construct the equivalent value ourselves in Meta's documented format, combining a timestamp with the click identifier.

21.5 Information recorded alongside it

• A randomly generated visitor identifier, not derived from your name, email address or device fingerprint
• Your IP address
• Your browser's user-agent string, truncated to 500 characters
• The referring website address, if your browser supplied one
• The address of the page you landed on
• A classification of the traffic source (for example "meta_paid", "google_organic", "email")
• The date and time
• Your account identifier, if you are signed in

21.6 Cookies and browser storage used for attribution and consent

• wip_attribution: Stores your attribution visitor identifier and traffic source so a later purchase can be matched to the visit that led to it. Duration: 30 days. Flags: Secure, HttpOnly.
• wip_consent: Records your cookie choice ("all" or "necessary"). Duration: 365 days.
• wip_geo: Caches the country determined for you so we do not repeat the lookup on every page. Duration: 30 days.
• Browser session storage (cleared when you close the tab): wip_ab records that a first-visit referral has already been reported in this session; wip_ab_q temporarily holds an attribution record that has not been sent because you are in a region where we require consent first and you have not yet given it. If you decline, or simply leave, it is never sent.

21.7 How your country is determined, and why

To know whether we must ask for your consent before any tracking, we need to know which country you are browsing from. Our content delivery provider, Cloudflare, determines an approximate country from your IP address and supplies it to us as a two-letter country code. We do not receive a precise location. The result is stored in the wip_geo cookie so the lookup is not repeated on every page.

We currently treat 56 jurisdictions as requiring your affirmative consent before any analytics or advertising technology loads. These comprise the European Union and European Economic Area, the United Kingdom, Switzerland, and: Canada, Brazil, Argentina, Chile, Colombia, Australia, New Zealand, Japan, South Korea, India, Thailand, Vietnam, the Philippines, Taiwan, Singapore, Malaysia, Indonesia, Israel, Turkey, the United Arab Emirates, Saudi Arabia, South Africa, Kenya and Nigeria. If you are browsing from one of these jurisdictions, the attribution beacon sends nothing at all until you choose Allow All. If you choose Essential Only, nothing is sent.

21.8 Consent records

When you choose Allow All or Essential Only in our cookie banner, we record that decision so we can demonstrate we honored it. The record contains the decision itself, the approximate country, the version of the consent notice shown where recorded, your IP address, your user-agent string, and the date and time. It does not contain your name or email address.

21.9 Changing your mind

You can reopen your cookie choices at any time using the "Cookie Settings" link in the site footer. Doing so clears your stored choice and presents the banner again. We honor the Global Privacy Control (GPC) signal as described in Section 6: if your browser or extension sends GPC, we turn off advertising and sharing technology without requiring any action from you. Analytics follows your banner choice, and the attribution beacon may be skipped.

21.10 Abuse protection on the attribution endpoint

To prevent automated abuse, the endpoint that receives attribution records accepts at most 10 submissions per IP address per minute. Requests beyond that are refused. We keep a short-lived counter, tied to your IP address, for 60 seconds for this purpose only.

21.11 How long attribution records are kept

Attribution records are deleted automatically 180 days after they are created. A scheduled process runs weekly to remove them. Records linked to a completed purchase are retained for seven (7) years as part of our transaction and financial records, after which they are also deleted automatically.

21.12 Automated crawlers

Requests we identify as search-engine crawlers, social media preview bots, monitoring services or automated tooling are excluded from attribution entirely, as are requests originating from our own infrastructure.

22. Refunds

Refunds are covered by our Refund Policy. Digital product sales are final, except where mandatory consumer protection law provides otherwise or the content is defective or cannot be delivered. Make Your Next Moves coaching follows the coaching rules in the Refund Policy, and RUSS purchases (made on damianmartinez.com) follow its Refund Policy, Section 3A. Nothing in our policies limits non-excludable rights you have under mandatory consumer protection law.

Digital product sales are final because:

• Digital products are delivered instantly upon purchase and cannot be "returned"
• Consulting time slots are reserved exclusively for you and cannot be resold once booked
• Access to digital content is granted immediately upon payment

If you experience a technical issue preventing access to a purchased product, contact support@mybiblekit.com and we will work to resolve the issue.

23. Third-Party Links

Our website may contain links to third-party websites, including social media platforms, payment processors, retailers such as Amazon, and scheduling tools. We are not responsible for the privacy practices of these external websites. We encourage you to review the privacy policies of any third-party sites you visit.

24. WIP Video Publisher and YouTube API Access

We operate an internal application called WIP Video Publisher that publishes and manages our own videos on our own YouTube channel, @wisdomintopractice. This section describes that application. It is separate from the YouTube video players that may appear on this website, which are covered in Sections 3 and 6.

Who Authorizes It, and Whose Data Is Involved

WIP Video Publisher is authorized by a single Google account that we control and that owns our YouTube channel. Visitors to this website are never asked to connect a Google or YouTube account, and the application has no access to any visitor's Google account. No site visitor, customer, subscriber, or newsletter reader grants this application anything.

What It Is Permitted To Do

When our own account authorizes the application, we grant two Google permissions and no others:

• youtube.upload — upload a video file to our channel.
• youtube.force-ssl — set the thumbnail, title, description, tags, and category of videos we uploaded, upload and replace their subtitle tracks, post and pin one comment of our own on them, add them to our own playlists, set a cover image on those playlists, set their visibility, and schedule their publication.

Using these permissions, the application uploads our devotional videos, sets their titles, descriptions, tags, and thumbnails, adds them to our playlists, and controls when they become visible. Videos are uploaded as private and are made public only by a deliberate, separate action.

Subtitles and Our Own Comments

The application uploads a subtitle track for each video. The subtitles are written from the same script we narrate, on our own server, so that the teaching can be read with the sound off and is accessible to viewers who are deaf or hard of hearing. No speech, audio, or video belonging to any other person is processed to produce them, and no viewer data is involved. When we correct a track, the application deletes the track it uploaded previously and replaces it with the corrected one. It does not read, add, or alter subtitles on any video that is not ours.

The application also posts one comment of our own underneath each of our videos and pins it, so that the written devotional and the related links sit at the top of the comments. It does not read, reply to, moderate, or store anyone else's comments.

What It Does Not Do

• It does not read, collect, or store information about people who watch, comment on, like, or subscribe to our channel.
• It does not access any other YouTube channel.
• It does not access Gmail, Google Drive, Google Contacts, Google Calendar, or any other Google service belonging to any person.
• It does not use YouTube data for advertising, profiling, training machine-learning models, or any purpose unrelated to publishing our own videos.
• It does not transfer YouTube data to any third party. The data stays between our server and Google.

What Is Stored, Where, and For How Long

Authorizing the application produces an OAuth refresh token. That token is stored in a single file on our own server, readable only by the account that runs the application. It is never placed in version control, never written to logs, never copied into cloud storage, and never shared. No YouTube viewer data, subscriber data, or analytics data is stored by the application at all.

The token is retained until it is revoked or until we stop operating the application, at which point the file is deleted.

How To Revoke It

Because only our own account authorizes this application, revocation is ours to perform. We can revoke access at any time from the Google Account permissions page, at either myaccount.google.com/permissions or security.google.com/settings/security/permissions, by selecting WIP Video Publisher and removing its access. Revocation takes effect immediately: the stored token stops working, and the application can no longer upload to, or change anything on, our channel. We can also revoke access by deleting the stored token from our server.

Any person may revoke an application's access to their own Google account at those same two pages. We state this because it is a right that belongs to every Google account holder, not because this application has ever been granted access to yours. If you believe our channel or this application has handled information incorrectly, contact us using Section 19.

Deletion of Stored Data

The application stores no YouTube user data, so there is no viewer, subscriber, comment, or analytics data for it to delete. The only Google-derived item it holds is the OAuth refresh token described above.

When access is revoked, or when we stop operating the application, the token file is deleted from our server and no copy of it remains in a backup, an archive, or a log. The working files the application produces, such as video masters, thumbnails, and subtitle files, are our own content rather than Google data; once a video is published they are deleted from the working directory or moved into our own private storage. If you have contacted us about our channel and want your message deleted, use the rights described in Sections 7 and 19.

Google's Terms

WIP Video Publisher uses YouTube API Services. By extension its operation is subject to the YouTube Terms of Service and the Google Privacy Policy. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.

This Privacy Policy is effective as of November 4, 2026 (version 3.5, privacy-2026-11-04-studio), which adds Section 5C covering Bible Study Studio on wisdomintopractice.com/study/ and MyBibleKit.com: account and sign-in codes, orders and study settings, membership and credit records, Stripe payments, private file storage and the shared account across both websites. Version 3.4 (privacy-2026-10-26-ytapi2), effective October 26, 2026, expanded Section 24 describing WIP Video Publisher and its YouTube API access to cover subtitle tracks and pinned comments, how that access is revoked, and how stored data is deleted. EntrepreNEW, Inc. reserves the right to modify this policy at any time in accordance with applicable law and Section 18. Previous version: 3.3 (privacy-2026-10-20-ytapi, effective October 20, 2026); before that 3.2 (privacy-2026-10-19-russ2, effective October 18, 2026); before that 3.1 (privacy-2026-10-18-russ, effective October 18, 2026); before that 3.0 (privacy-2026-10-18, effective October 18, 2026); before that 2.3 (effective August 22, 2026, last updated October 15, 2026).