Privacy Policy

Harmonic Brilliance | Raquel Spencer Effective Date: March 30, 2026.

01 | Overview

Harmonic Brilliance, operated by Raquel Spencer ("Harmonic Brilliance," "we," or "us"), is committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use it, who we share it with, and what choices you have.

By using our website, platform, or services, you agree to the practices described in this policy. This policy is incorporated by reference into our Terms and Conditions.

02 | Information We Collect

We collect information in the following ways:

Information you provide directly:

  • Name and email address at signup or purchase

  • Billing information provided at checkout (processed securely by our payment processor; we do not store full card numbers)

  • Communications you send to us, including support requests and replies to our emails

Information collected automatically:

  • Pages visited and content accessed within the platform

  • General location data (country or region level, derived from IP address)

  • Device type and browser information for platform functionality purposes

  • Email engagement data (whether an email was opened or a link was clicked)

Information from third-party services we use:

  • Purchase and subscription status from our payment and CRM platform

  • Content access records tied to your membership tier

03 | How We Use Your Information

We use the information we collect to:

  • Create and manage your membership account and content access

  • Process payments and send billing-related communications

  • Deliver content, session recordings, series, and platform updates you have purchased or enrolled in

  • Send you membership emails, event reminders, and educational content related to your tier

  • Personalize your member experience, including displaying your purchased content in your library

  • Respond to your questions and support requests

  • Improve our platform, content, and member experience over time

  • Comply with legal obligations

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

04 | Email Communications

When you join Harmonic Brilliance, you will receive transactional emails related to your membership, including welcome sequences, access delivery, billing confirmations, and event notifications. These are part of the service you enrolled in.

You may also receive educational and community emails from Raquel Spencer related to the work of Harmonic Brilliance. You can opt out of non-transactional emails at any time using the unsubscribe link in any email. Note that opting out of marketing emails does not affect transactional messages related to your active membership or purchases.

05 | How We Share Your Information

We do not sell your personal information. We share it only in the following limited circumstances:

Service providers: We work with third-party platforms to operate our membership, process payments, deliver email, and host content. These providers are contractually required to use your information only to perform services on our behalf.

Our current key service providers include:

  • Payment and CRM processing (GoHighLevel)

  • Website and content hosting (Squarespace)

  • Infrastructure and personalization (Cloudflare)

  • Video hosting (YouTube)

  • Audio hosting (SoundCloud)

Legal compliance: We may disclose your information if required to do so by law, court order, or government authority, or to protect the rights, property, or safety of Harmonic Brilliance, our members, or others.

Business transfers: In the event of a merger, acquisition, or sale of substantially all assets, your information may be transferred as part of that transaction. We will notify affected members in advance.

We do not share your information with advertisers or data brokers.

06 | Data Retention

We retain your personal information for as long as your membership is active and for a reasonable period afterward to fulfill legal, billing, and operational obligations. If you cancel your membership and request deletion of your account data, we will honor that request to the extent permitted by law and our record-keeping obligations.

To request data deletion, contact us at the email address listed in Section 10.

07 | Cookies and Tracking

Our website and platform may use cookies and similar tracking technologies to support core functionality, remember your login state, and understand how members engage with content.

You can configure your browser to refuse cookies or alert you when cookies are being set. Some features of the platform may not function correctly if cookies are disabled.

We do not use third-party advertising cookies or sell behavioral data to ad networks.

08 | Children's Privacy

Harmonic Brilliance is not directed at children under the age of 13, and we do not knowingly collect personal information from anyone under 13. If you believe a child has provided us with personal information, please contact us and we will promptly delete it.

09 | Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information, including the right to:

  • Access the personal data we hold about you

  • Request correction of inaccurate information

  • Request deletion of your data, subject to legal and operational limitations

  • Withdraw consent where processing is based on consent

  • Lodge a complaint with a data protection authority in your jurisdiction

To exercise any of these rights, contact us at the address in Section 10. We will respond within a reasonable timeframe and in accordance with applicable law.

10 | Contact

If you have questions about this Privacy Policy, want to request access to or deletion of your data, or need to reach us for any reason related to your privacy, contact us at:

Harmonic Brilliance Email: support@harmonicbrilliance.com Website: harmonicbrilliance.com

11 | Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date at the top of this page. For material changes, we will notify active members by email or through the platform.

Your continued use of Harmonic Brilliance following any updates constitutes your acceptance of the revised policy.

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ADDENDUM A | California Residents (CCPA / CPRA)

This section applies to members and visitors who are residents of the State of California. It supplements the Privacy Policy above and is provided in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

Categories of personal information we collect:

  • Identifiers (name, email address, IP address)

  • Commercial information (purchase history, membership tier, subscription status)

  • Internet or network activity (pages visited, content accessed, email engagement)

  • Geolocation data (general region, derived from IP address)

  • Inferences drawn from the above to understand member preferences and content interests

We collect this information for the business purposes described in Section 03 of this policy.

We do not sell your personal information. We do not share your personal information with third parties for cross-context behavioral advertising.

Your rights as a California resident:

  • The right to know what personal information we collect, use, disclose, and share

  • The right to delete personal information we hold about you, subject to certain exceptions

  • The right to correct inaccurate personal information

  • The right to opt out of the sale or sharing of personal information (we do not sell or share for advertising purposes)

  • The right to limit the use and disclosure of sensitive personal information

  • The right to non-discrimination for exercising any of these rights

To exercise your rights, contact us at support@harmonicbrilliance.com. We will verify your identity before processing your request and respond within 45 days, with an extension of up to an additional 45 days when reasonably necessary.

You may also designate an authorized agent to submit a request on your behalf. Authorized agent requests must include written authorization signed by you.

For questions or concerns specific to your California privacy rights, contact us at: Harmonic Brilliance Email: support@harmonicbrilliance.com

ADDENDUM B | European Union, United Kingdom, and EEA Residents (GDPR / UK GDPR)

This section applies to individuals located in the European Union, the United Kingdom, or the European Economic Area. It supplements the Privacy Policy above and is provided in accordance with the General Data Protection Regulation (GDPR) and, where applicable, the UK GDPR.

Data Controller: Raquel Spencer, operating as Harmonic Brilliance, is the data controller responsible for your personal information.

Contact: support@harmonicbrilliance.com

Lawful Bases for Processing:

We process your personal information on the following legal bases:

  • Contract: Processing is necessary to deliver the membership, content, and services you have purchased or enrolled in.

  • Legitimate interests: We process certain data (platform analytics, email engagement) to operate and improve our services, where those interests are not overridden by your rights.

  • Consent: Where we send non-transactional marketing or educational emails, we rely on your consent. You may withdraw consent at any time using the unsubscribe link in any email.

  • Legal obligation: We retain certain records to comply with financial, tax, and legal requirements.

International Data Transfers:

Harmonic Brilliance is based in the United States. If you are located in the EU, UK, or EEA, your personal information will be transferred to and processed in the United States. We take steps to ensure appropriate safeguards are in place for such transfers, including relying on service providers who participate in recognized data transfer frameworks or offer standard contractual clauses approved by the European Commission.

Your Rights Under GDPR:

  • The right to access your personal data and receive a copy of it

  • The right to rectification of inaccurate or incomplete data

  • The right to erasure ("right to be forgotten"), subject to legal retention obligations

  • The right to restrict processing in certain circumstances

  • The right to data portability in a structured, machine-readable format

  • The right to object to processing based on legitimate interests

  • The right to withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal

  • The right to lodge a complaint with your local supervisory authority

To exercise any of these rights, contact us at support@harmonicbrilliance.com. We will respond within 30 days. Complex or multiple requests may require an extension of up to two additional months, and we will notify you if that is the case.

Supervisory Authority:

If you are in the EU or EEA and believe we have not handled your data in accordance with the GDPR, you have the right to lodge a complaint with your national data protection authority. If you are in the UK, you may contact the Information Commissioner's Office (ICO) at ico.org.uk.

Retention:

We retain personal data for as long as necessary to fulfill the purposes described in this policy, including legal and financial record-keeping obligations. Membership data is generally retained for the duration of your membership and up to 7 years afterward for tax and financial compliance purposes.