Privacy Policy

01About This Policy

This Privacy Policy explains how RAW Recovery LLC collects, uses, and protects personal information when you visit and use our public websites: rawrecoveryandwellness.com, emotionalfortitude.com, and fortitudeprogram.com (together, the “Sites”). The same policy applies to all three Sites.

In this policy, “we,” “us,” and “RAW” mean RAW Recovery LLC, a California limited liability company. “You” means anyone who visits the Sites, contacts us, books a call, takes an assessment, submits an application, or signs up for our emails.

Our members-only client portal at clients.emotionalfortitude.com and the RAW app are covered by a separate Member Portal Privacy Policy. If you enroll in a RAW program, that policy also applies to the information you share as a member.

By using the Sites, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Sites.

02Information We Collect

A. Information You Give Us

We collect the information you choose to provide when you:

• Book a call through Calendly: your name, email address, phone number if you provide it, your chosen time, and any answers you give to the booking questions. We do not record or transcribe calls without telling you first and getting your consent;
• Apply to The Fortitude Program™ through Typeform: your name, contact details, and your answers to the application questions;
• Take an assessment through ScoreApp: your name, email address, your answers, and your results;
• Sign up for emails or download a resource: your name and email address; and
• Contact us by email or phone: your contact details and whatever you include in your message.

B. Information Collected Automatically

When you visit the Sites, we, our hosting provider, and our analytics provider automatically collect:

• IP address, browser type, operating system, and device type;
• Pages viewed, time spent on pages, and how you move through the Sites;
• The website or link that brought you to the Sites; and
• Date and time stamps and standard server log data.

C. Information From Others

If a treatment center, sober living home, clinician, or family member refers you to RAW, they may share your name and contact details with us so we can reach out. We use that information only to follow up on the referral.

03Sensitive Disclosures

Some of our booking questions, applications, and assessments ask about your recovery, your emotional life, your relationships, and what you want to change. You may choose to share personal information about substance use, mental and emotional health, trauma, or family history.

You are never required to share this information. Anything you share is shared by choice, and you can leave a question blank or tell us you would rather talk about it on a call.

• What you share in an application, assessment, or booking form is seen only by RAW staff and coaches who need it to respond to you and assess fit.
• We do not use your personal disclosures for advertising, profiling, or marketing to other companies.
• We do not sell or share your personal disclosures with third parties, except as described in Section 5 or as required by law.

04How We Use Your Information

We do not use your information to:

• Sell your data to advertisers or data brokers;
• Run behavioral or retargeting advertising based on what you share with us;
• Train third-party artificial intelligence models on your personal disclosures; or
• Send you offers from other companies.

05Service Providers & Disclosures

We use the following service providers to run the Sites and respond to you. Each processes information on our behalf under its own privacy policy and applicable law.

We may also disclose information:

• To comply with the law: in response to a valid court order, subpoena, or other legal process;
• To protect safety: when we believe in good faith that disclosure is necessary to prevent imminent harm to you or others;
• In a business transfer: if RAW is acquired, merges, or sells its assets, your information may transfer as part of that transaction, and we will notify you; and
• With your consent: for any other purpose you explicitly approve.

We do not sell your personal information.

06Email Communications

If you sign up for our emails, take an assessment, or apply to a program, we may send you emails related to what you signed up for, such as your assessment results, information about The Fortitude Program™, and occasional writing from our team.

Every marketing email includes an unsubscribe link. You can also ask us to remove you at any time using the contacts in Section 14. If you unsubscribe, we may still send you messages you need, such as replies to your inquiry or confirmations of a call you booked.

Newsletters we publish on Substack are managed by Substack under its own privacy policy when you subscribe there.

07Cookies & Analytics

The Sites use cookies and similar technologies, mainly to keep the Sites working and to understand how they are used, not for advertising.

We do not use advertising cookies or retargeting pixels on the Sites.

Managing Cookies

You can block or delete cookies in your browser settings. If you block cookies used by an embedded tool, that booking form, application, or assessment may not work.

Do Not Track and Global Privacy Control

Some browsers send a “Do Not Track” signal. There is no common industry standard for responding to it, so the Sites do not change how they operate when they receive one. The analytics described above still run unless you use the opt-out add-on.

Because we do not sell personal information or use it for cross-context behavioral advertising, there is nothing for a Global Privacy Control signal to opt you out of. We still treat a Global Privacy Control signal as a valid request to opt out of sale or sharing.

08Third-Party Links & Embeds

The Sites link to and embed content from other services, including Calendly, Typeform, ScoreApp, Substack, and our member portal on Kajabi. When you use those services, the information you give them is handled under their own terms and privacy policies, which we do not control. We encourage you to read them.

09Data Retention

We keep personal information only as long as we need it for the purposes it was collected for, to keep business records, to meet legal obligations, to resolve disputes, and to enforce our agreements.

If you enroll in a program, retention of your member information is described in the Member Portal Privacy Policy. When we no longer need information, we delete it securely or de-identify it so it can no longer be linked to you.

10California Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA):

Right to Know

Ask what personal information we have collected about you, where it came from, why we collected it, and who we have shared it with in the past 12 months.

Right to Delete

Ask us to delete personal information we collected from you, subject to legal exceptions such as records we must keep.

Right to Correct

Ask us to correct inaccurate information we hold about you.

Right to Opt Out

We do not sell your personal information or share it for cross-context behavioral advertising. We will still honor any opt-out request.

Right to Limit Sensitive Information

Ask us to limit our use of your sensitive personal information to what is needed to respond to you and provide our services.

Right to Non-Discrimination

We will not treat you differently, or change our services or pricing, for exercising any of these rights.

Shine the Light (Civil Code §1798.83)

California residents may ask whether we disclosed personal information to third parties for their direct marketing in the previous calendar year. We do not disclose personal information to third parties for their direct marketing.

How to Make a Request

To exercise any of these rights, contact us using the details in Section 14. We will respond to verified requests within 45 days. We may need to confirm your identity first, usually by confirming the email address you used with us. You may also have an authorized agent make a request for you. We will need your written authorization and may verify the agent’s identity.

11Children’s Privacy

The Sites and our programs are for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has given us personal information, contact us and we will delete it.

12Data Security

We maintain reasonable administrative, technical, and physical safeguards to protect your information, including:

• SSL/TLS encryption for data sent to and from the Sites;
• Staff access to submissions on a need-to-know basis;
• Reputable providers for hosting, forms, booking, and email; and
• Secured administrator accounts for the Sites.

13Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices, the law, or the Sites. When we make changes, we will post the updated policy on this page with a new “Last updated” date. For material changes, we will also email people on our email list. If you keep using the Sites after an update takes effect, you accept the revised policy.

14Contact Us

For privacy questions, California privacy requests, or anything else about how we handle your information, contact:

Mailing address: RAW Recovery LLC, PO Box 2157, 24001 Calle de la Magdalena, Laguna Hills, CA 92637

Response time: We acknowledge privacy requests within 5 business days and respond fully within 45 days.