Gearvana Ventures LLC d/b/a Cellular Repair School (“Company,” “we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our websites and services. Please read this policy carefully. By accessing or using our Service, you acknowledge you have read and understood this Policy.

1. WHO WE ARE

2. INFORMATION WE COLLECT

2.1  Information You Provide

We collect information you provide directly when you: create an account, enroll in a course, make a purchase, sign an enrollment agreement, contact support, or participate in live sessions. This includes:

• Identity data: full name, date of birth, email address, phone number, billing address.
• Payment data: credit/debit card type and last four digits (full card numbers are processed by our payment processor and never stored by Company).
• Account data: username, password (hashed), enrollment history, LMS activity logs.
• Communications: emails, support tickets, survey responses, testimonials you voluntarily provide.
• Signature data: electronic signatures, IP addresses, timestamps captured via our e-signature platform.

2.2  Information Collected Automatically

When you use the Service, we automatically collect:

• Technical data: IP address, browser type and version, operating system, device identifiers, time zone.
• Usage data: pages visited, content accessed, LMS login timestamps, session duration, clickstream data.
• Cookie data: see Section 8 (Cookies) below.

2.3  Information from Third Parties

We may receive information about you from payment processors (Stripe), e-signature platforms (WPSignature/ApprovMe), learning management system providers (Tech HQ), and analytics providers (Google Analytics).

3. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

• To process enrollments, payments, and deliver purchased digital products and services.
• To create and manage your LMS account and provide customer support.
• To send transactional communications (receipts, access credentials, enrollment confirmations).
• To send marketing communications where you have given consent (you may opt out at any time).
• To maintain access logs, IP records, and login timestamps as evidence of digital delivery for dispute resolution purposes.
• To comply with legal obligations, enforce our Terms, and protect our rights.
• To analyze usage patterns and improve our Service.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

4. LEGAL BASIS FOR PROCESSING (GDPR)

For users located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data on the following legal bases:

• Contract performance: processing necessary to fulfill your enrollment agreement and deliver the purchased digital product.
• Legitimate interests: maintaining security records (access logs, IP addresses) to defend against fraudulent payment disputes; enforcing our Terms and Conditions.
• Legal obligation: complying with applicable laws, tax requirements, and regulatory obligations.
• Consent: sending marketing emails and using non-essential cookies, where we have obtained your explicit consent. You may withdraw consent at any time.

5. DATA SHARING & DISCLOSURE

We do NOT sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information in the following limited circumstances:

5.1  Service Providers

We share data with vetted third-party vendors who process it on our behalf, including:

All service providers are contractually required to process data only as directed and to maintain appropriate security measures.

5.2  Legal & Compliance Disclosures

We may disclose your information: (a) when required by law, court order, or government authority; (b) to enforce our Terms and Conditions or Billing Policy; (c) to protect the rights, property, or safety of Company, our students, or the public; or (d) in connection with a merger, acquisition, or sale of all or substantially all of Company’s assets (you will be notified of any such change).

5.3  Dispute Evidence

In the event of a payment dispute or chargeback, we may share relevant records — including your signed enrollment agreement, LMS login timestamps, IP address logs, and access records — with our payment processor, card networks (Visa, Mastercard, etc.), and acquiring bank as required to defend against the dispute. This is a legitimate interest under applicable data protection law.

6. DATA RETENTION

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law. Specifically:

• Account and enrollment records: retained for the duration of your enrollment plus 5 years, to support dispute resolution and legal compliance.
• Payment records and signed agreements: retained for 7 years in accordance with financial recordkeeping requirements.
• LMS access logs and IP records: retained for 3 years minimum for dispute defense purposes.
• Marketing communications: until you opt out, after which we retain a record of your opt-out.

When data is no longer required, it is securely deleted or anonymized.

7. YOUR PRIVACY RIGHTS

7.1  All Users

Regardless of your location, you have the right to: access the personal data we hold about you; request correction of inaccurate data; opt out of marketing communications at any time; and request deletion of your data, subject to legal retention requirements.

7.2  California Residents — CCPA/CPRA Rights

7.3  EEA, UK & Swiss Residents — GDPR Rights

8. COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies — including web beacons and pixel tags — on our websites to enable core functionality, remember your preferences, analyze usage, and deliver relevant advertising.

The four categories of cookies we use are: Strictly Necessary (required for the Service to function), Functional (preferences and settings), Analytics (usage measurement via Google Analytics), and Marketing/Retargeting (Facebook Pixel, Google Ads). See our Cookie Policy for the full breakdown and opt-out instructions.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption for data in transit, AES-256 encryption for stored payment data (via Stripe), role-based access controls, and regular security reviews.

No method of electronic transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the security of your account credentials.

10. CHILDREN’S PRIVACY

The Service is intended for users 18 years of age and older. We do not knowingly collect personal information from individuals under 18. If we become aware that a minor has provided us with personal information, we will delete it promptly. If you believe we have inadvertently collected information from a minor, contact us immediately at Registration@CellularRepairSchool.com.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or by a prominent notice on our website at least 30 days before the changes take effect. We will update the ‘Last Updated’ date at the top of this page. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

12. CONTACT & DATA PROTECTION OFFICER

For questions, requests, or complaints about this Privacy Policy or our data practices, contact us:

EEA/UK users may also contact your local supervisory authority. A list of EU data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en