Effective date: July 31, 2026
Last updated: July 31, 2026
This Privacy Policy explains how Debora T DiBiasie, doing business through the AVBrands, as applicable, collects, uses, retains, protects, and discloses personal information through AltaVidaSites.
For purposes of this Privacy Policy:
“We,” “us,” and “our” refer to Debora T DiBiasie, doing business through the AVBrands, as applicable, and, where appropriate, authorized service providers acting on our behalf.
“AVBrands” collectively means AltaVida Capital, AltaVida Unlimited, and AltaVida Offices.
“AltaVidaSites” collectively means:
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household. The precise meaning may vary under applicable law.
This Privacy Policy applies to personal information collected through AltaVidaSites and related communications unless a separate product, service, transaction, program, or written agreement provides a different privacy notice.
By using AltaVidaSites or submitting personal information, you acknowledge the practices described in this Privacy Policy.
This Privacy Policy applies to information collected through:
This Privacy Policy does not govern the independent privacy practices of government agencies, financial institutions, insurers, employers, professional firms, social-media platforms, or other third parties whose websites, applications, or services may be linked to or accessible through AltaVidaSites.
Depending on how you use AltaVidaSites, we may collect the following categories of information.
This may include:
When an account or protected application is offered, we may collect:
Passwords are intended to be processed through secure authentication systems and should not be retained by us in readable form.
Our assessments and calculators may collect information concerning:
“Tool” means an assessment, calculator, questionnaire, report generator, or similar interactive resource offered through AltaVidaSites.
Tools are designed for educational planning. Unless specifically requested through an approved secure process, users should provide estimated amounts or ranges rather than complete financial statements or unnecessary sensitive records.
When a user requests insurance information or contact from a licensed professional, we may collect information such as:
A formal insurance application may require additional information under separate carrier forms, disclosures, agreements, and privacy notices.
For business tools, office services, invoices, referrals, or professional inquiries, we may collect:
Users must have lawful authority to submit information concerning another individual or business.
We may collect information contained in:
If paid products or services are offered, we may collect:
Complete payment-card information is intended to be processed by independent payment processors rather than stored directly by us.
When you access or use AltaVidaSites, certain information may be collected automatically through technologies active on the applicable site, such as server logs, cookies, analytics tools, authentication systems, and similar technologies.
This information may include:
Additional information about these technologies, their purposes, and available user choices is provided in our Cookie Policy.
We may receive personal information from:
When another person provides information about you, that person represents that they have lawful authority to do so.
AltaVidaSites does not request or require users to submit the following information through site forms, assessments, calculators, email, social-media messaging, chat, or other ordinary communication channels:
Users should not submit information concerning another individual unless they have lawful authority to provide it and the information is reasonably necessary for the requested interaction.
If unsolicited sensitive information is submitted, we may delete it, restrict access to it, securely dispose of it, or retain it only when legally or operationally necessary.
Any information required for a formal insurance application must be submitted through the separate, authorized process identified by the applicable licensed insurance professional, insurance agency, or carrier. That information is subject to the privacy notices, forms, security procedures, and legal requirements applicable to that insurance process.
We may use personal information to:
We will not use personal information for a materially different purpose without providing additional notice or obtaining consent when required by applicable law.
AltaVidaSites may use automated rules, formulas, calculations, answer mappings, scoring systems, or AI-assisted processes to:
These processes are intended to provide educational organization and general planning information.
They are not intended to:
A score, label, estimate, recommendation, or priority generated by a Tool is not an official or legally binding determination.
Where applicable law grants rights concerning automated decision-making or profiling, we will provide required notices, reviews, and controls.
We may use artificial intelligence and other technology-assisted services to help:
When an AI-assisted service processes personal information submitted by a user, we will limit the information used to what is reasonably necessary for the stated purpose and provide additional notice when required by applicable law.
We do not intentionally submit highly sensitive personal information to a general-purpose AI service unless:
Users should not enter confidential or highly sensitive information into an open-text field unless the field specifically requests that information and explains how it will be handled.
AI-assisted outputs may contain errors or omissions and should not be treated as official, professional, or legally binding determinations.
We may send transactional and marketing communications as described below.
Transactional communications may include:
Transactional communications may continue after a user unsubscribes from marketing when reasonably necessary to provide a requested service, administer an account, complete a transaction, protect security, or comply with applicable law.
With consent or as otherwise permitted by applicable law, we may send:
Recipients may unsubscribe from marketing communications by using the unsubscribe link provided in the message or by contacting us.
An unsubscribe request may not remove information that must be retained for suppression-list, legal, security, transaction, recordkeeping, or compliance purposes.
AltaVidaSites may use:
Essential technologies may be necessary to operate AltaVidaSites, authenticate users, maintain security, remember requested settings, or provide requested functions. These technologies may not be disabled through ordinary consent controls when they are strictly necessary for the requested service.
Nonessential technologies will be used and managed in accordance with applicable notice, consent, and opt-out requirements.
Our Cookie Policy provides additional information concerning:
The technologies used may vary among AltaVidaSites. Users should review the Cookie Policy and consent controls displayed on the applicable site.
We may disclose personal information in the circumstances described below.
We may disclose personal information to service providers and contractors that perform functions such as:
Service providers and contractors may process personal information only for authorized purposes and subject to applicable contractual, confidentiality, security, and legal restrictions.
AltaVidaSites may allow users to request information, services, demonstrations, consultations, referrals, or introductions involving selected independent business partners and professionals.
Depending on the user’s request, these recipients may include:
When a user requests or affirmatively authorizes an introduction, we may disclose information reasonably necessary to respond to the request, such as:
The receiving business or professional may use the information to contact the user, provide requested information, evaluate service needs, schedule a consultation, administer the requested service, or perform other purposes disclosed when the information is collected.
We retain the primary client relationship and control of its contact database. Providing limited information to an authorized professional, closer, case designer, agency, carrier, or service partner does not transfer ownership or control of the client relationship or authorize the recipient to add the individual to an unrelated marketing list.
Except where independently required by law or necessary to administer the requested transaction, recipients may use the information only for the specific purpose authorized by the user.
Independent recipients may maintain their own privacy policies, security practices, professional responsibilities, eligibility requirements, and terms of service. Users should review any separate privacy notice provided by the receiving professional or organization.
We may receive referral fees, commissions, revenue-sharing payments, marketing compensation, or other business benefits when a user purchases or obtains a product or service through one of these relationships. Any effect on the user’s price will be disclosed when legally required.
We will not disclose a user’s information to an independent business or professional for direct marketing unrelated to the user’s request without the user’s authorization or another lawful basis.
AltaVidaSites may contain affiliate links, product recommendations, promotional links, or other links to independent merchants and service providers.
When a user selects an affiliate link:
We do not control the independent merchant’s collection, use, retention, disclosure, or security of personal information.
Unless expressly disclosed, we do not receive or store a user’s complete payment-card information, account password, or complete transaction record from an affiliate merchant. We may receive limited information concerning referral activity, conversion status, commission eligibility, or the category of a qualifying purchase.
The presence of an affiliate link does not mean that the merchant sponsors, controls, or endorses the AVBrands. Product and service availability, pricing, warranties, returns, delivery, customer service, and transactions are governed by the independent merchant’s terms.
We may disclose personal information when reasonably necessary to:
Personal information may be disclosed in connection with a proposed or completed:
Recipients will be expected to handle personal information in accordance with applicable law and relevant contractual obligations.
We may disclose personal information when a user directs us to do so, requests the disclosure, or provides legally valid consent.
We do not sell, rent, license, publish, or distribute contact lists or databases containing users’ names, email addresses, telephone numbers, assessment responses, or other personal information.
We do not permit business partners, referral recipients, affiliate merchants, or other third parties to browse, access, or obtain our complete contact database.
We do not disclose personal information to unrelated third parties for their independent, unsolicited marketing.
When a user expressly requests a product, service, consultation, demonstration, referral, or professional introduction, we may provide the minimum information reasonably necessary to the specific business or professional identified to the user at the time of the request.
Before making such a disclosure, we will provide notice describing:
We may receive a referral fee, commission, revenue-sharing payment, or other compensation if the user completes a purchase or transaction. We will not disclose the user’s information to additional recipients merely because the initial referral did not result in a transaction.
Recipients may be required by contract to:
Depending on the circumstances and applicable law, a compensated disclosure may be legally characterized as a “sale” even when no contact list is sold and the disclosure occurs at the user’s request. If a disclosure is legally treated as a sale or sharing of personal information, we will provide any notice, consent, opt-out mechanism, and other rights required by applicable law.
Affiliate links ordinarily do not involve us providing the merchant with our contact database. When a user voluntarily selects an affiliate link, the user interacts directly with the independent merchant, and the merchant collects information under its own privacy policy. We may receive limited referral, conversion, or commission information, but we do not provide the merchant with our complete contact database.
We use third-party service providers and technology platforms to support AltaVidaSites and related services.
These providers may perform functions such as:
These providers may process personal information only as reasonably necessary to perform authorized services or as otherwise permitted by applicable law and relevant agreements.
The specific providers used may differ among AltaVidaSites and may change as our technology and operational needs change.
Material changes affecting our privacy practices will be reflected in this Privacy Policy, the Cookie Policy, or another applicable notice.
We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including:
Retention periods may vary according to:
When a Tool or separate privacy notice states a specific retention period, that stated period will apply to the covered information, subject to disclosed legal, security, backup, transaction, and dispute-related exceptions.
When personal information is no longer reasonably necessary, we may delete, deidentify, aggregate, or securely dispose of it, subject to applicable legal, contractual, security, and recordkeeping requirements.
Deletion from active systems may not immediately remove information from encrypted backups, archival systems, fraud-prevention records, legal holds, transaction records, or records that must be retained by law. Information retained in backups will remain protected and will be deleted or overwritten according to the applicable backup schedule.
We use administrative, technical, and physical safeguards designed to protect personal information according to its nature, sensitivity, and the risks associated with its processing.
Safeguards may include:
No security system is perfect. We cannot guarantee that unauthorized access, loss, misuse, alteration, or disclosure will never occur.
Users are responsible for protecting their devices, passwords, accounts, access links, and copies of information. Users should notify us promptly if they suspect unauthorized access or misuse.
If we discover a security incident involving personal information, we may take appropriate steps to investigate, contain, remediate, document, and respond to the incident.
Depending on the circumstances, those steps may include:
Users should notify us promptly if they suspect unauthorized access to an account, access link, report, submission, or communication associated with AltaVidaSites.
Depending on the user’s interaction with AltaVidaSites and applicable law, users may be able to:
Some requests may be limited by:
Withdrawing consent or requesting deletion will not necessarily affect processing or disclosures that lawfully occurred before the request was received.
This section applies to the extent we are subject to the California Consumer Privacy Act or another applicable California privacy law.
Depending on the circumstances, California consumers may have rights to:
Whether a particular right applies depends on the applicable law, the nature of the request, the information involved, statutory thresholds, and available exceptions.
Depending on the user’s interaction, we may collect:
The specific information collected depends on the applicable site within AltaVidaSites, Tool, form, transaction, or communication used.
Sources may include:
We may collect, use, retain, and disclose personal information for the purposes described in Sections 6 through 13 of this Privacy Policy.
Depending on the user’s request and interaction, recipients may include:
We do not sell, rent, license, publish, or distribute contact lists or permit third parties to access our complete contact database.
Residents of certain states may have additional rights concerning:
The availability and scope of these rights vary by jurisdiction and may depend on statutory thresholds, exemptions, the type of information involved, and the nature of the user’s relationship with us.
We will respond to valid requests as required by applicable law. When legally required, we will provide instructions for appealing a denied request.
Some browsers offer a “Do Not Track” setting. Because there is no single uniform standard governing ordinary Do Not Track signals, AltaVidaSites may not respond to every Do Not Track setting.
Where required by applicable law, we will process legally recognized opt-out preference signals, such as a valid Global Privacy Control signal, for the applicable browser or device.
A browser-based preference signal may not apply to personal information associated with another browser, device, account, or offline interaction unless legally required and technically identifiable.
The general AltaVidaSites are not directed to children under 13 and are not intended to collect personal information directly from children under 13.
Financial-literacy materials intended for children or families must be accessed and administered by:
Children should not independently:
If we learn that personal information was submitted directly by a child under 13 without legally sufficient authorization, we may delete the information, restrict access to it, disable the associated account or submission, and take other appropriate steps to prevent further collection.
Certain family educational programs offered through the AVBrands, including NAMA’s Little Money Lab, may provide supplemental privacy notices addressing their specific practices. Those supplemental notices should be read together with this Privacy Policy and will control for the applicable program if a conflict exists.
AltaVidaSites may link to, display, recommend, or embed content from:
Third parties may collect information through their websites, applications, embedded content, cookies, pixels, referral identifiers, accounts, or transaction processes under their own privacy policies.
We do not control the privacy, security, accessibility, availability, pricing, terms, or business practices of independent third parties.
A link, recommendation, referral, introduction, or embedded resource does not necessarily mean that the third party sponsors, controls, or endorses the AVBrands.
Users should review the applicable third party’s privacy policy, cookie notice, and terms before submitting information, creating an account, or completing a transaction.
When users interact with the AVBrands through a social-media platform, both we and the platform may receive information concerning the interaction.
This information may include:
The platform’s collection, use, retention, and disclosure of information are governed by its own privacy policy and settings.
Public comments, shares, reactions, photographs, videos, and posts may be visible to other users and the general public.
Users should not post sensitive, confidential, financial, insurance, benefits, health, identification, or account information publicly.
We are based in the United States. Personal information may be stored or processed in the United States or in other countries where authorized service providers operate.
Privacy and data-protection laws in those locations may differ from the laws in the user’s jurisdiction.
We will use service providers and contractual or technical safeguards appropriate to the nature of the information and the services performed.
This section does not represent that the AVBrands actively market or offer services in every country where a service provider may maintain infrastructure.
A person submitting a privacy request for another individual may be required to provide:
We may contact the affected individual directly to verify the representative’s authority when permitted by applicable law.
Information submitted to establish identity or authority will be used only for verification, security, recordkeeping, and compliance purposes.
We may also contact the individual directly to verify authorization where permitted.
To protect personal information, we may verify a privacy request by comparing information provided with information reasonably available in our records.
The verification process may vary according to:
We will request only the information reasonably necessary to verify identity and authority.
We may decline, delay, or limit a request when identity or authority cannot be reasonably verified or when another exception applies under applicable law.
Where required by applicable law, we will not unlawfully discriminate or retaliate against an individual for exercising a privacy right.
This does not prevent us from:
Any financial incentive or price or service difference involving personal information will be administered in accordance with applicable notice and consent requirements.
We may update this Privacy Policy to reflect changes in:
The revised Privacy Policy will display an updated “Last updated” date.
When required by applicable law, we may provide additional notice, request renewed consent, or obtain new authorization before applying a materially different practice to previously collected personal information.
Previous versions may be retained for legal, compliance, security, and operational records.
Questions, concerns, privacy requests, and requests to exercise applicable privacy rights may be directed to:
AltaVidaSites
Operated by: Debora T DiBiasie, doing business through the AVBrands
Email: wealth@altavidacapital.com
Please include sufficient information to identify the nature of the request, but do not send Social Security numbers, account passwords, complete financial-account numbers, medical records, identification documents, or other unnecessary sensitive information by ordinary email.
We may request additional information through an appropriate process when reasonably necessary to verify identity or authority.
Contacting the AVBrands or AltaVidaSites does not create a legal, financial, benefits, insurance, tax, healthcare, fiduciary, or other professional relationship.