SPIRITWALKER®
wearespiritwalker.com
PRIVACY POLICY
Effective Date: March 19, 2026 | Last Updated: March 19, 2026
1. WHO WE ARE
This Privacy Policy explains how SPIRITWALKER INTERNATIONAL LLC, a New York limited liability company doing business as SPIRITWALKER® (“SPIRITWALKER,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information in connection with https://wearespiritwalker.com/ and all related services, integrations, and digital properties (the “Services”).
By using the Services, you consent to the practices described here. This Policy is incorporated into our Terms of Service.
2. INFORMATION WE COLLECT
(a) Information you provide directly. When you contact us, book a session, make a purchase, submit a testimonial, or apply to participate in our programs, we may collect your name, email address, telephone number, areas of interest, the contents of your messages, and booking details. Payment-card information is collected and processed directly by our third-party payment processor (PayPal); we do not store full card numbers.
(b) Information collected automatically. When you use the Services, we and our analytics providers may collect device and usage data such as IP address, browser type, pages viewed, referring URLs, and interactions, through cookies and similar technologies, including Google Tag Manager / Google Analytics (see Section 7).
(c) Information from TikTok. If you connect your TikTok account or interact with our TikTok-integrated features, we receive certain data from TikTok as described in Section 4.
3. HOW WE USE INFORMATION
We use personal information to: provide, operate, and improve the Services; schedule and deliver sessions and events; process payments; respond to inquiries; send service and (with your consent where required) marketing communications; maintain security and prevent fraud; and comply with legal obligations. We process email and SMS communications consistent with the CAN-SPAM Act (15 U.S.C. § 7701 et seq.) and the Telephone Consumer Protection Act (47 U.S.C. § 227); you may opt out of marketing at any time.
For users in the EEA/UK, our legal bases are: performance of a contract; your consent; our legitimate interests; and compliance with legal obligations (GDPR, Regulation (EU) 2016/679, Art. 6).
4. TIKTOK DATA — WHAT WE RECEIVE, HOW WE USE IT, AND YOUR CONTROLS
(a) What we receive. If you authorize a TikTok integration with SPIRITWALKER, TikTok provides us only the data covered by the permissions/scopes you approve. Depending on the permissions enabled for our app, this may include your TikTok open ID, profile/display name, avatar/profile image, profile link, bio description, verification status, OAuth access/refresh tokens, and content you specifically direct us to upload to TikTok as part of a draft or private test workflow.
(b) How we use it. We use TikTok data solely to provide the feature you requested: authenticating the connected TikTok account, verifying account identity, preparing approved SPIRITWALKER content packages, and, only when specifically authorized, uploading content to TikTok through the Content Posting API. We do not use TikTok data for unrelated marketing, profiling, resale, or model training.
(c) Content Posting API. Our TikTok integration is designed for a controlled SPIRITWALKER publishing workflow. Direct public posting is not enabled by default. Content is prepared, reviewed, and uploaded only when authorized through the app workflow and subject to TikTok’s available privacy settings and API requirements.
(d) What we do NOT do. We do not sell TikTok data. We do not share TikTok data for cross-context behavioral advertising. We do not use TikTok data to train artificial-intelligence or machine-learning models. We handle TikTok data in accordance with the TikTok Developer Terms of Service and applicable TikTok developer policies.
(e) Retention. We retain TikTok data only as long as needed to provide the requested integration, maintain the authorized connection, comply with TikTok API requirements, or satisfy legal obligations. If you revoke access or request deletion, we delete or de-identify TikTok data we hold within a reasonable period, subject to limited legal retention requirements.
(f) Your controls. You may revoke SPIRITWALKER’s TikTok access in your TikTok account settings. You may also request deletion of TikTok data we hold by contacting legal@wearespiritwalker.com.
5. HOW WE SHARE INFORMATION
We do not sell your personal information. We may share it with: service providers (e.g., hosting, analytics, payment processing, email/scheduling tools) bound by confidentiality obligations; professional advisors; authorities where required by law, subpoena, or court order; and a successor entity in connection with a merger, acquisition, or asset sale. TikTok data is shared only as described in Section 4.
6. COOKIES & TRACKING TECHNOLOGIES
We use cookies and similar technologies for functionality, analytics, and performance, including Google Tag Manager / Google Analytics. You can control cookies through your browser settings and, where applicable, through a cookie-consent banner on the Services.
7. DATA RETENTION & SECURITY
We retain personal information for as long as necessary to fulfill the purposes described here, comply with legal obligations, resolve disputes, and enforce agreements. We implement reasonable administrative, technical, and physical safeguards designed to protect personal information, consistent with the data-security requirements of the New York SHIELD Act (N.Y. Gen. Bus. Law § 899-bb). In the event of a breach of private information, we will provide notice as required by N.Y. Gen. Bus. Law § 899-aa and other applicable law. No method of transmission or storage is perfectly secure.
8. YOUR PRIVACY RIGHTS
(a) California residents (CCPA/CPRA, Cal. Civ. Code § 1798.100 et seq.). You have the right to know, access, correct, and delete personal information, to opt out of “sale” or “sharing” (we do not sell personal information), and to non-discrimination for exercising these rights.
(b) EEA/UK residents (GDPR). You have the right to access, rectify, erase, restrict, and port your data, to object to processing, and to withdraw consent. You may lodge a complaint with your supervisory authority. International transfers are made under appropriate safeguards (e.g., Standard Contractual Clauses).
(c) Other U.S. states. Residents of states with comprehensive privacy laws may have similar rights to access, correct, delete, and opt out.
(d) How to exercise your rights. Submit a request to legal@wearespiritwalker.com. We will verify your identity and respond within the time required by applicable law.
9. CHILDREN'S PRIVACY
The Services are intended for adults (18+) and are not directed to children. We do not knowingly collect personal information from children under thirteen (13), consistent with COPPA (15 U.S.C. §§ 6501–6506). If you believe a child has provided us information, contact us and we will delete it.
10. THIRD-PARTY LINKS & PLATFORMS
The Services may link to or integrate with third parties (including TikTok, our payment processor, and social platforms). Their privacy practices are governed by their own policies, and we are not responsible for them.
11. CHANGES TO THIS POLICY
We may update this Policy from time to time. Material changes will be posted here with an updated “Last Updated” date and, where required, communicated to you directly. Your continued use of the Services after changes take effect constitutes acceptance.
12. CONTACT US
SPIRITWALKER INTERNATIONAL LLC
2424 BROADWAY 7, NEW YORK, NY 10024
Email: legal@wearespiritwalker.com
© 2026 SPIRITWALKER INTERNATIONAL LLC. All rights reserved. SPIRITWALKER® is a registered trademark of SPIRITWALKER INTERNATIONAL LLC (U.S. Reg. No. 6,660,003).