This Privacy Policy describes how Javitusa Media, LLC (“Phroogal,” “we,” “us,” or “our”) collects, uses, and protects your information when you use Phroogal.com, Smile Money Academy, our Marketplace, AI assistant (“pAI”), downloadable resources, and related services (collectively, the “Services”).
By using our Services, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use.
1. Information We Collect
Information You Provide Voluntarily
Name, email, payment information, or other details provided when you register for memberships, subscriptions, courses, downloads, or when you contact us.
Information shared in community forums, comments, reviews, or interactive features.
Information Collected Automatically
IP address, browser type, device information, operating system, referring URLs, access times, and pages visited.
Usage patterns such as clicks, navigation, and interactions.
Cookies and Tracking Technologies
We use session and persistent cookies to personalize your experience, remember preferences, and analyze usage.
You may disable cookies in your browser settings, but some Services may not function properly.
Information from Third Parties
We may receive data from payment processors, learning platforms, analytics providers, affiliates, and advertising networks.
2. How We Use Information
We use your information to:
Operate, maintain, and improve our Services.
Process memberships, subscriptions, and course access.
Deliver downloads and digital resources.
Respond to inquiries and provide support.
Send newsletters, promotions, or surveys (with opt-out options).
Monitor analytics, advertising, and user behavior.
Detect and prevent fraud, misuse, or illegal activity.
Comply with legal obligations.
3. AI Assistant (pAI)
pAI is provided for educational and informational purposes only.
Do not submit sensitive personal information (e.g., account numbers, SSNs, passwords).
Conversations may be logged in anonymized or aggregated form to improve services. These are not sold or used to identify individual users.
Phroogal disclaims liability for reliance on AI-generated responses.
Affiliate partners when you engage with their services.
Legal authorities when required by law or to protect rights, safety, or property.
We do not sell personal information.
8. Publicly Available Information
Any data you post in forums, comments, or reviews may become public and viewable by others. Exercise caution when sharing personal information.
9. Data Security
We use SSL encryption and commercially reasonable safeguards to protect data. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.
10. Data Retention
We retain personal information only as long as necessary to fulfill purposes described in this Policy, comply with legal requirements, or resolve disputes. Data may be anonymized for statistical purposes.
11. Children’s Privacy
We do not knowingly collect data from children under 13.
Users under 13 must not use our Services.
If we learn we have collected data from a child under 13, we will promptly delete it.
12. International Users
By using our Services outside the U.S., you consent to transfer of your data to the U.S. or other jurisdictions. Where required, safeguards are applied to protect transferred data (e.g., EU standard contractual clauses, adequacy decisions).
13. Your Rights
Depending on your location (e.g., California under CCPA, EU under GDPR), you may have rights to:
Access, correct, or delete your personal information.
Restrict or object to processing.
Request data portability.
Withdraw consent for marketing.
To exercise these rights, contact info@phroogal.com. We may require verification of identity.
14. Do Not Track Signals
We do not respond to “Do Not Track” browser signals at this time due to lack of industry standards.
15. Third-Party Links & Advertisers
Our Services may contain third-party links, ads, or content. We are not responsible for the practices of third-party sites. Access at your own risk.
16. Changes to This Policy
We may update this Privacy Policy at any time. The latest version will be posted with a new “Last Updated” date.
17. Contact Information
For questions about this Privacy Policy or your data rights, contact us: info@phroogal.com
