Privacy Policy

Last Updated: March 23, 2026

Clients With AI LLC ("Company," "we," "us," or "our"), operated by Carlos Aviles, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website carlosaviles.ai (the "Site") and use our products and services. This policy applies to all visitors, users, and customers of the Site, regardless of location.

Please read this Privacy Policy carefully. By accessing or using the Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Site.

1. Information We Collect

1.1. Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

Create an account or register on the Site;
Purchase products or services;
Subscribe to our email list or newsletter;
Fill out a contact form or survey;
Participate in webinars, group coaching, or consulting calls;
Communicate with us via email or other channels.

The types of personal information we may collect include:

Identity Data: First name, last name, username or similar identifier;
Contact Data: Email address, phone number, mailing address;
Financial Data: Payment card details, billing address (processed securely by Stripe and/or PayPal — we do not store full card numbers on our servers);
Transaction Data: Details about products and services you have purchased from us, purchase amounts, and payment history;
Profile Data: Your business type, interests, preferences, feedback, and survey responses;
Communications Data: Content of emails, messages, and other communications you send to us.

1.2. Information Collected Automatically

When you visit the Site, we automatically collect certain information about your device and your usage of the Site, including:

Device Data: IP address, browser type and version, operating system, device type, screen resolution, and language preferences;
Usage Data: Pages visited, time spent on pages, click paths, referring URL, exit pages, date and time of visit, and other diagnostic data;
Location Data: Approximate geographic location based on IP address;
Cookie and Tracking Data: Information collected through cookies, web beacons, pixels, and similar technologies (see Section 7 below).

1.3. Information From Third Parties

We may receive information about you from third-party sources, including:

Payment processors (Stripe, PayPal) regarding transaction status;
Analytics providers (Google Analytics);
Advertising platforms (Meta/Facebook) regarding ad interactions;
Email marketing platforms (ConvertKit, ActiveCampaign) regarding engagement data.

2. How We Collect Information

We collect information through the following methods:

Direct Interactions: When you fill out forms, create accounts, make purchases, or communicate with us;
Automated Technologies: Through cookies, pixels, server logs, and similar technologies when you interact with the Site;
Third Parties: From analytics providers, advertising networks, payment processors, and email marketing platforms as described above.

3. Purpose of Collection and Use

We use the information we collect for the following purposes:

Service Delivery: To process transactions, deliver products and services, manage your account, and provide customer support;
Communication: To send you transactional emails (order confirmations, receipts), respond to inquiries, and provide requested information;
Marketing: To send you marketing communications, newsletters, promotional materials, and information about products and services that may interest you (with your consent where required by law);
Analytics and Improvement: To understand how you use the Site, analyze trends, improve our products and services, and optimize the user experience;
Advertising: To deliver targeted advertising through platforms like Meta/Facebook and to measure the effectiveness of our advertising campaigns;
Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests;
Security: To detect, prevent, and address fraud, unauthorized access, and other illegal activities;
Contractual Obligations: To fulfill our obligations under any agreements entered into between you and us.

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA), United Kingdom, or other jurisdictions where GDPR or similar regulations apply, we process your personal data based on the following legal grounds:

Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., subscribing to our newsletter, accepting cookies). You may withdraw consent at any time;
Contractual Necessity: Where processing is necessary for the performance of a contract with you (e.g., processing your purchase, delivering digital products, providing consulting services);
Legitimate Interests: Where processing is necessary for our legitimate interests (e.g., improving our services, marketing our products, securing our Site) and your interests and fundamental rights do not override those interests;
Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject (e.g., tax reporting, responding to legal requests).

5. Data Sharing and Disclosure

We may share your personal information with the following categories of third parties:

5.1. Service Providers

Payment Processors: Stripe (stripe.com/privacy) and PayPal (paypal.com/privacy) to process payments securely;
Email Marketing Platforms: ConvertKit and/or ActiveCampaign to manage email subscriptions and deliver email communications;
Analytics Providers: Google Analytics (policies.google.com/privacy) to analyze Site usage;
Advertising Platforms: Meta Platforms/Facebook (facebook.com/privacy/policy) for targeted advertising and conversion tracking via Meta Pixel;
Hosting and Infrastructure: Web hosting providers that store and serve the Site;
Customer Support Tools: Software platforms used to manage customer communications.

5.2. Business Transfers

In the event of a merger, acquisition, reorganization, dissolution, or similar corporate event, your personal information may be transferred as part of the business assets. We will notify you of any such change in ownership or control of your personal information.

5.3. Legal Requirements

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect and defend our rights or property; (c) prevent or investigate possible wrongdoing; (d) protect the personal safety of users or the public; or (e) protect against legal liability.

5.4. With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so.

We do not sell your personal information to third parties.

6. Data Retention

6.1. We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

6.2. Specific retention periods:

Account Information: Retained for as long as your account is active, plus a reasonable period thereafter for legal and business purposes;
Transaction Records: Retained for a minimum of seven (7) years to comply with tax and accounting obligations;
Marketing Data: Retained until you unsubscribe or request deletion, whichever occurs first;
Analytics Data: Retained in aggregated, anonymized form indefinitely for trend analysis;
Communication Records: Retained for a reasonable period based on the nature of the communication.

6.3. When personal information is no longer needed, we will securely delete or anonymize it.

7. Cookies and Tracking Technologies

7.1. Types of Cookies We Use

Essential Cookies: Necessary for the Site to function properly (e.g., session management, shopping cart, authentication). These cannot be disabled;
Analytics Cookies: Used by Google Analytics to collect information about how visitors use the Site, including pages visited, time on site, and traffic sources. This data helps us improve the Site;
Advertising Cookies: Used by Meta Pixel and similar technologies to deliver relevant ads, track conversions, and build advertising audiences;
Functional Cookies: Used to remember your preferences (e.g., language, region) and provide enhanced features.

7.2. Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling cookies may affect the functionality of the Site. You can also opt out of targeted advertising through:

Google Ads Settings: adssettings.google.com
Facebook Ad Preferences: facebook.com/ads/preferences
Network Advertising Initiative: optout.networkadvertising.org
Digital Advertising Alliance: optout.aboutads.info

7.3. Do Not Track

Some browsers transmit "Do Not Track" (DNT) signals. We currently do not respond to DNT signals because no uniform standard for compliance has been adopted. We will continue to monitor developments in DNT technology and update our practices accordingly.

8. Your Rights

8.1. General Rights (All Users)

Regardless of your location, you have the right to:

Access: Request a copy of the personal information we hold about you;
Correction: Request correction of inaccurate or incomplete personal information;
Deletion: Request deletion of your personal information, subject to certain legal exceptions;
Opt-Out of Marketing: Unsubscribe from marketing emails at any time by clicking the "unsubscribe" link in any email or by contacting us directly;
Data Portability: Request a machine-readable copy of your personal data;
Withdraw Consent: Where processing is based on consent, withdraw your consent at any time.

8.2. European Data Subject Rights (GDPR)

If you are located in the EEA or UK, you additionally have the right to:

Restrict Processing: Request that we restrict the processing of your personal data in certain circumstances;
Object to Processing: Object to processing based on legitimate interests or for direct marketing purposes;
Lodge a Complaint: File a complaint with your local data protection authority.

8.3. California Residents' Rights (CCPA/CPRA)

If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting the information, and the categories of third parties with whom we share the information;
Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions;
Right to Opt-Out of Sale: We do not sell your personal information. However, if this changes, you will have the right to opt out;
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights;
Right to Correct: You have the right to request correction of inaccurate personal information;
Right to Limit Use of Sensitive Personal Information: You may direct us to limit the use and disclosure of sensitive personal information to purposes necessary to provide the services.

Categories of Personal Information Collected (per CCPA):

Identifiers (name, email address, IP address);
Commercial information (purchase history, products purchased);
Internet or electronic network activity (browsing history, Site interactions);
Financial information (payment method details — processed by Stripe/PayPal);
Professional or employment-related information (business type, if voluntarily provided);
Inferences drawn from the above (interests, preferences).

To exercise any of your California rights, please contact us at [email protected]. We will verify your identity before fulfilling your request. You may designate an authorized agent to make a request on your behalf.

9. Children's Privacy

9.1. The Site and our products and services are not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18.

9.2. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information as soon as possible.

9.3. If you believe we have collected information from a child under 18, please contact us immediately at [email protected].

10. International Data Transfers

10.1. Our operations are based in the United States. If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located and our central database is operated.

10.2. The data protection laws in the United States may differ from those of your country of residence. By using the Site, you consent to the transfer of your information to the United States and the processing of your information in accordance with this Privacy Policy.

10.3. For transfers of personal data from the EEA or UK to the United States, we rely on appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, or your explicit consent where applicable.

11. Security Measures

11.1. We implement commercially reasonable technical, administrative, and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

SSL/TLS encryption for data in transit;
Secure payment processing through PCI-DSS-compliant providers (Stripe, PayPal);
Access controls limiting personnel access to personal data on a need-to-know basis;
Regular security assessments and updates;
Secure hosting infrastructure with firewalls and intrusion detection.

11.2. Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee the absolute security of your information. You acknowledge that you provide your personal information at your own risk.

12. Changes to This Privacy Policy

12.1. We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any changes will be posted on this page with an updated "Last Updated" date.

12.2. For material changes, we will provide more prominent notice, which may include email notification to the email address associated with your account or a notice on the Site prior to the change becoming effective.

12.3. We encourage you to review this Privacy Policy periodically. Your continued use of the Site after the posting of changes constitutes your acceptance of such changes.

13. Data Protection Officer / Contact

13.1. For all privacy-related inquiries, requests to exercise your data rights, or complaints, please contact our designated privacy contact:

Carlos Aviles
Data Protection Contact
Clients With AI LLC
Email: [email protected]
Website: carlosaviles.ai

13.2. We will respond to all legitimate requests within thirty (30) days. In some cases, we may require additional time (up to 60 additional days), in which case we will notify you of the extension and the reasons for the delay.

13.3. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority.

By using carlosaviles.ai, you acknowledge that you have read, understood, and agree to this Privacy Policy.