Privacy Policy

Effective Date: September 8, 2026

1. CONTROLLER AND CONTACT INFORMATION

Strategy Mastery LLC, a New Mexico (USA) limited liability company, operating under the brand "La Casa del Estratega," is the controller of personal data collected through our website https://lacasadelestratega.com and related services.

Our contact information is:

Strategy Mastery LLC

1209 Mountain Road Pl NE, Ste R

Albuquerque, NM 87110

Usa

Email: info@lacasadelestratega.com

For data protection inquiries, please contact us at the email address above with the subject line "Privacy Inquiry."

2. DATA WE COLLECT

We collect personal data in the following categories:

Contact Form Data. When you submit a contact form on our website, we collect the following information you voluntarily provide: your name, email address, phone number or WhatsApp contact, and any message content you enter.

Technical and Log Data. Our web servers automatically collect information about your interactions with our website, including your IP address, browser type, operating system, pages visited, time spent on pages, referring URL, and the date and time of access. This information is collected through server logs and first-party analytics.

Cookie Preferences. We store your cookie consent preferences in your browser using local storage under the identifier "lcde_cookie_consent_v1." This preference record allows us to honor your choices about analytics and marketing cookies on future visits.

Purchase Data. If you purchase our "Método Solera" training program, our third-party payment processor collects and processes payment information including your name, billing address, email, and payment method details. The payment processor handles all payment card information in compliance with Payment Card Industry Data Security Standards. We do not directly store your full payment card details on our servers; instead, we receive a confirmation of successful payment and create a customer record tied to your email and order information.

Customer Account Data. After purchase, we maintain records including your name, email address, order date, purchased program, and access credentials to the training platform, community, and scheduled calls.

Video Viewing Data. If you watch embedded video content (such as our sales video), the third-party video hosting service may collect information about your viewing behavior, device, and IP address, subject to that provider's privacy practices.

3. PURPOSES FOR DATA COLLECTION

We collect and process your personal data for the following purposes:

To respond to your inquiries submitted via our contact form and to provide customer support.

To process your purchase, deliver access to the "Método Solera" program, and manage your account and program access.

To send you transactional emails confirming your purchase, account status, and program updates.

To comply with applicable legal, tax, and accounting requirements, including record-keeping obligations in the United States and your country of residence.

To improve our website, identify technical issues, and optimize user experience through analytics and log analysis.

To send you marketing communications (newsletters, program updates, special offers) only if you have opted in to receive such communications.

To enforce our terms of service, prevent fraud, and protect the security and integrity of our platform.

4. LEGAL BASES FOR DATA PROCESSING

In accordance with the General Data Protection Regulation (GDPR) (where applicable to you), we process your personal data on the following legal bases:

Contract. We process contact form data, purchase data, and customer account data because processing is necessary to perform our contract with you—namely, to respond to inquiries, process your purchase, deliver the program, and provide ongoing support and access to the training platform, community, and calls.

Legal Obligation. We retain customer records, payment information, and transaction data to comply with applicable tax laws, accounting requirements, and legal obligations in the United States and the European Union, which may require retention of business records for up to six years.

Legitimate Interest. We process technical and log data, including IP addresses and browsing behavior, to maintain website security, prevent fraud, analyze platform performance, identify and resolve technical problems, and improve user experience. We have assessed that our interest in maintaining a secure, functional platform is not overridden by your interests or fundamental rights.

Consent. We process analytics and marketing cookies, and send marketing emails, only on the basis of your affirmative consent. You may withdraw consent at any time by adjusting your cookie preferences or unsubscribing from marketing emails. Withdrawal of consent does not affect the lawfulness of prior processing.

5. RECIPIENTS AND PROCESSORS

Your personal data may be disclosed to or processed by the following third parties:

Hosting Provider. Our website is hosted in Germany by Hetzner. Your technical and log data (including IP address, pages accessed, browser information) is processed by Hetzner's servers and logs. Hetzner is a data processor subject to appropriate data protection agreements.

Email Services. Your contact form data and customer email address are processed by email delivery systems to send you inquiries responses, transactional emails, and program updates. These email processors are contractually bound to protect your data and use it only as instructed.

Video Hosting Provider. If you view embedded video content (such as sales videos), a third-party video hosting provider receives your IP address, device information, and viewing analytics. This provider is a data processor operating under standard contract terms.

Payment Processor. Your payment information is collected and processed by a third-party payment processor selected at checkout. We do not store full payment card details; the processor handles all sensitive payment data in compliance with PCI DSS standards. The specific processor is identified at the time of purchase.

Customer Relationship Management (CRM) and Email Marketing Tools. If you are a customer or opt into our mailing list, your email address and account information may be processed by CRM and email marketing platforms (only if you have consented to marketing communications). These platforms are data processors bound by data protection agreements.

Accountants and Legal Advisors. Your transactional and account data may be shared with our accountants and legal advisors as necessary to comply with tax, accounting, and legal obligations.

Public Authorities. We may disclose your data if required by law, court order, or government request, or to protect our legal rights and the security of our platform.

6. INTERNATIONAL DATA TRANSFERS

Strategy Mastery LLC is located in New Mexico, USA. Your personal data collected on our website is processed and stored in the United States and potentially in Germany (where our hosting provider operates).

For users located in the European Union or European Economic Area: When your data is transferred from the EU to the United States, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and incorporated into our agreements with processors. Additionally, to the extent the Data Privacy Framework (DPF) applies to our data processors, we rely on the DPF adequacy determination. These mechanisms provide appropriate safeguards for your data in accordance with GDPR requirements.

For users located outside the EU: Your data may be transferred to and processed in the United States and other countries. By using our website and services, you acknowledge and consent to such transfers. If your country has specific data transfer restrictions, please contact us for clarification regarding applicable safeguards.

7. DATA RETENTION PERIODS

We retain your personal data as follows:

Contact Form Inquiries. Data from contact forms (name, email, phone, message) is retained for 12 months from the date of submission, after which it is deleted unless you become a customer.

Customer and Account Data. Once you purchase the "Método Solera" program, we retain your name, email, order information, and account access credentials for the duration of your account and program access, plus any contractually specified retention period (as stated in your purchase confirmation and program terms).

Transactional and Accounting Records. In compliance with applicable tax and accounting laws, we retain customer payment records, receipts, and transaction histories for up to six years from the date of transaction.

Cookie Preference Records. Your cookie consent preference is stored in your browser's local storage and is retained until you clear your browser data or modify your preference through our cookie control.

Technical and Log Data. Server logs containing IP addresses and technical information are retained according to Hetzner's standard retention policy, typically 30-90 days, unless required to be retained longer for security or legal purposes.

Email Communications. If you subscribe to our mailing list, we retain your email address and engagement data (opens, clicks) for the duration of your subscription and for 12 months after unsubscription, unless applicable law requires otherwise.

Consent Records. We maintain records of your cookie consent and email opt-in decisions to demonstrate compliance with privacy regulations.

8. YOUR RIGHTS UNDER THE GDPR

If you are located in the European Union, European Economic Area, United Kingdom, or other jurisdictions implementing equivalent privacy laws, you have the following rights:

Right of Access. You have the right to request a copy of the personal data we hold about you in a structured, commonly used, and machine-readable format.

Right to Rectification. You have the right to request correction of inaccurate or incomplete personal data we hold about you.

Right to Erasure (Right to be Forgotten). You have the right to request deletion of your personal data, subject to certain exceptions (such as ongoing legal obligations to retain records for tax or accounting purposes). We will comply with erasure requests within 30 days unless legal requirements require retention.

Right to Restrict Processing. You have the right to request that we limit our processing of your data while we assess a rights conflict or pending resolution of a dispute.

Right to Data Portability. You have the right to request that we provide your personal data in a portable format and transmit it to another controller of your choice.

Right to Object. You have the right to object to processing of your data for marketing purposes, analytics, or other legitimate interests. We will cease such processing within 30 days of your objection.

Right to Withdraw Consent. If your data processing is based on your consent (such as for marketing cookies or marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Right to Lodge a Complaint. If you believe we have violated your privacy rights, you have the right to lodge a complaint with your local data protection authority, including:

In Spain: Agencia Española de Protección de Datos (AEPD) at www.aepd.es
In the European Union: Your respective national data protection authority
In the United Kingdom: Information Commissioner's Office (ICO) at www.ico.org.uk

To exercise any of these rights, please contact us in writing at info@lacasadelestratega.com with the subject line "Data Rights Request" and specify which right you are exercising. We will respond within 30 days (or as required by applicable law).

9. CALIFORNIA CONSUMER PRIVACY RIGHTS AND SIMILAR US STATE PRIVACY LAWS

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) grant you the following rights, which also apply under similar privacy laws in other US states:

Right to Know. You have the right to request what personal information we collect, use, and share about you.

Right to Delete. You have the right to request deletion of personal information we have collected about you, subject to certain exceptions (such as information necessary to perform contracted services or comply with legal obligations).

Right to Correct. You have the right to request correction of inaccurate personal information we maintain about you.

Right to Opt Out of Sale or Sharing. You have the right to opt out of the "sale" or "sharing" of your personal information. We do not sell your personal data to third parties for monetary consideration. We do not share your data with third parties for cross-context behavioral advertising. Therefore, this right does not apply to our practices.

Right to Non-Discrimination. We will not deny you goods or services, charge different prices, or provide different levels of service based on your exercise of privacy rights under the CCPA/CPRA, except where differences are justified by legitimate business purposes.

To exercise any of these rights, please submit a verifiable consumer request to info@lacasadelestratega.com with the subject line "CCPA Rights Request" or "State Privacy Rights Request." We will verify your identity and respond within 45 days. You may also designate an authorized agent to submit requests on your behalf.

10. MINORS

Our "Método Solera" program and website are intended for adults aged 18 years and older. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that we have collected data from a minor, we will delete such data promptly. If you are a parent or guardian and believe we have collected data from a minor, please contact us at info@lacasadelestratega.com immediately.

11. SECURITY MEASURES

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit using SSL/TLS protocols on our website.

Secure storage of customer account data on protected servers.

Limited access to personal data by authorized employees and contractors bound by confidentiality obligations.

Regular security assessments and monitoring of our infrastructure.

PCI DSS compliance standards for payment processing through third-party processors.

However, no security measure is completely foolproof. We cannot guarantee absolute security of your data. You use our website and services at your own risk. If you have security concerns, please contact us immediately at info@lacasadelestratega.com.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on our website with a new "Effective Date." Your continued use of our website and services following such changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy regularly to stay informed about how we protect your personal data.

If we make material changes that significantly affect your rights or how we process your data, we will notify you by email (if we have your email address) or by posting a prominent notice on our website.

13. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at: