Effective Date: July 31, 2026

Last Updated: July 31, 2026

Raquel Reyna Lyon operates Divine Nutrition as a California sole proprietorship. Divine Nutrition provides websites, stores, products, programs, assessments, memberships, communities, and related services through ZoCode, Raquel & Davidian, AwakeShift, Foxy5D, Human Design Upgrade, and other brands and offerings identified in this Privacy Policy.

In this Privacy Policy, "Divine Nutrition," "we," "us," and "our" refer to Raquel Reyna Lyon operating the Divine Nutrition sole proprietorship. "Services" refers collectively to the websites, stores, products, programs, assessments, memberships, communities, applications, and other offerings governed by this Privacy Policy, including Zocode.fyi, RaquelandDavidian.com, Foxy5D.com, Skool-hosted communities, Lovable-powered experiences, and related properties that link to this Privacy Policy.

This Privacy Policy explains what personal information we collect, how we use and disclose it, the choices available to you, and how to contact us. It applies only to information processed by or on behalf of Divine Nutrition. Third-party platforms and services process information under their own privacy terms.

1. Personal Information We Collect

"Personal information" means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to an individual or household. Depending on how you use the Services, we may collect the following categories.

1.1 Contact and identifying information

This may include your name, email address, telephone number, billing address, shipping address, account name, social media handle, and other contact information you provide.

1.2 Purchase and transaction information

This may include products or services purchased, order history, transaction dates, payment status, discounts, refunds, subscription status, payment-plan status, billing and shipping details, and limited payment-related information provided by a payment processor. We generally do not receive or store complete payment-card numbers. Payment information is processed by providers such as Stripe, Square, PayPal, or payment processors made available through GoHighLevel, Shopify, Skool, Lovable, or other platforms.

1.3 Account, membership, and community information

This may include account credentials, membership status, profile information, course progress, participation history, community posts, comments, reactions, uploaded materials, and communications within Skool or other membership platforms. Information you post in a community may be visible to other members. Please avoid posting information you do not want other members to see.

1.4 Program, appointment, and service information

When you register for or participate in coaching, mentoring, Human Design, hypnosis-related, educational, or transformational services, we may receive information such as scheduling details, goals, preferences, questions, intake responses, participation notes, and other information you voluntarily provide. We do not request complete medical records through our general Services.

1.5 Communications and support information

This may include emails, text messages, support requests, survey responses, feedback, testimonials, call or meeting details, and other communications you send to us. If a class, event, or session is recorded, we will provide notice and seek consent when required by applicable law or platform rules.

1.6 Device, usage, and online activity information

This may include IP address, device type, browser type, operating system, approximate location inferred from IP address, referring pages, pages viewed, links clicked, session duration, cart activity, purchase funnel activity, email opens and clicks, and similar technical or usage information.

GoHighLevel analytics may process this information. As of the effective date, Google Analytics, Google Ads tracking, and Meta Pixel are not intentionally enabled across the covered Services, although we may enable one or more of these tools in the future. If we materially change our analytics or advertising practices, we will update this Privacy Policy and provide any notices or choices required by law.

1.7 Cookies and similar technologies

We and our service providers may use cookies, pixels, local storage, software development kits, tags, and similar technologies. These technologies support security, authentication, shopping carts, checkout, preferences, analytics, communications, and, if enabled, advertising. Please review our separate Cookie Notice for additional information.

1.8 Information for physical-product fulfillment

If we offer physical merchandise, we may collect shipping addresses, delivery instructions, order details, return information, and communications needed to fulfill or support the order.

1.9 Information you voluntarily share about ZOË

The ZOË Soul Archetype Assessment operates within the participant's personal ChatGPT conversation. Divine Nutrition, ZoCode, Raquel, and Davidian do not receive, view, or store the participant's assessment conversation, responses, or generated report through the custom GPT itself.

If you voluntarily send us a report, screenshot, conversation excerpt, shared-conversation link, testimonial, support request, or other ZOË-related content, we may receive and process that information for the purpose for which you submitted it.

1.10 Information from other sources

We may receive information from payment processors, commerce platforms, referral partners, event platforms, social media services, advertising platforms, public sources, and service providers, where permitted by law.

2. How We Collect Personal Information

We collect personal information:

Directly from you when you purchase, register, subscribe, schedule, contact us, join a community, submit a form, or participate in a Service.

Automatically through cookies, platform analytics, server logs, pixels, and similar technologies.

From service providers and platforms that support our payments, stores, websites, communities, communications, scheduling, analytics, and delivery.

From third parties when you direct them to share information with us or when the sharing is otherwise permitted by law.

3. How We Use Personal Information

We may use personal information to:

Provide, operate, personalize, maintain, and improve the Services.

Process purchases, payments, subscriptions, payment plans, refunds, shipments, and order confirmations.

Deliver digital products, assessment access, reports voluntarily submitted to us, courses, memberships, replays, and other resources.

Schedule and administer appointments, classes, programs, and events.

Provide customer service and technical support.

Authenticate users, maintain accounts, and prevent unauthorized access.

Communicate about purchases, appointments, classes, account status, security, policy changes, and other transactional matters.

Send marketing emails, text messages, promotions, and abandoned-cart communications where permitted and, when required, with your consent.

Measure email opens, link clicks, website use, conversions, and general engagement.

Detect, investigate, and prevent fraud, misuse, security incidents, and violations of our policies.

Protect our rights, intellectual property, users, Services, and business operations.

Comply with legal, tax, accounting, regulatory, and contractual obligations.

Establish, exercise, or defend legal claims and collect amounts properly due.

Carry out another purpose disclosed when the information is collected or with your consent.

We do not use personal information for purposes that are materially incompatible with the purposes described above unless we provide additional notice and obtain consent when required.

4. Marketing Communications

We may send promotional emails or text messages about ZoCode and other Divine Nutrition brands and offerings when permitted by law. Consent to marketing is not a condition of purchasing an ordinary product or service unless the offer expressly states otherwise and the law permits it.

You may unsubscribe from marketing emails by using the unsubscribe link in the message. You may opt out of marketing text messages by replying STOP or following the instructions in the message. Message and data rates may apply. Opting out of marketing does not prevent us from sending non-promotional communications concerning transactions, subscriptions, appointments, security, policy changes, or customer support.

5. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients for legitimate business purposes.

5.1 Service providers and contractors

These may include:

GoHighLevel for websites, stores, customer relationship management, forms, communications, automation, analytics, checkout, and related services.

Shopify for commerce and order-related functions used by certain covered brands.

Skool for memberships, communities, course content, member profiles, discussions, and related features.

Lovable for websites, applications, databases, interactive tools, hosting, technical functionality, and related services.

OpenAI for ZOË and other ChatGPT-based experiences used directly by participants.

Stripe, Square, PayPal, and other payment processors.

Zoom and other meeting, webinar, or class platforms.

Email, SMS, scheduling, hosting, cloud-storage, database, security, content-delivery, analytics, and technical-support providers.

Professional advisers such as accountants, attorneys, insurers, and consultants.

Our direct providers may use their own hosting, storage, security, payment, artificial-intelligence, communications, and infrastructure subprocessors. Those provider lists may change over time.

5.2 Other community members or participants

Information you choose to post in a membership community, group forum, class chat, public comment area, or similar shared space may be visible to other participants. Recordings of group classes may be made available to eligible participants when disclosed as part of the program.

5.3 Legal and safety disclosures

We may disclose information when reasonably necessary to comply with law, legal process, court order, government request, tax obligation, or regulatory requirement; to enforce agreements; to collect amounts properly due; to protect rights, property, safety, or security; or to investigate suspected fraud or unlawful conduct.

5.4 Business changes

Information may be disclosed in connection with a proposed or completed reorganization, financing, sale, transfer, merger, acquisition, or other change involving some or all of the business or its assets, subject to applicable law.

5.5 With your direction or consent

We may disclose information when you ask us to do so or consent to the disclosure.

6. Sale, Sharing, and Targeted Advertising

We do not sell personal information for monetary consideration.

As of the effective date, we do not intentionally use Meta Pixel, Google Ads tracking, or similar cross-context behavioral advertising technologies across the covered Services. If we enable advertising technologies that constitute "selling," "sharing," or targeted advertising under an applicable privacy law, we will update our notices and provide any legally required opt-out method, including recognition of qualifying browser-based opt-out preference signals where required.

We do not knowingly sell or share the personal information of individuals under 18 years of age.

7. ZOË, ChatGPT, and Assessment Privacy

The ZOË Soul Archetype Assessment is delivered through a custom GPT operating within ChatGPT.

ZOË does not use external Actions or APIs to transmit assessment responses to Divine Nutrition, ZoCode, GoHighLevel, Lovable, or another external database.

Divine Nutrition, ZoCode, Raquel, and Davidian do not have access to individual ZOË conversations through the GPT builder interface.

Assessment responses and generated reports operate within the participant's ChatGPT conversation unless the participant voluntarily shares them.

OpenAI processes ChatGPT conversations under its own terms, privacy policies, product configuration, plan terms, and account-level data controls. Please review OpenAI's current privacy information and manage your ChatGPT data controls directly through your OpenAI account.

Privacy Note: To protect the privacy of your assessment responses, do not use ChatGPT's Share feature or distribute a shared-conversation link. Anyone who receives or gains access to such a link may be able to view the conversation included in it.

If you voluntarily submit ZOË-related content to us, that information will be handled under this Privacy Policy. Requests concerning information held only by OpenAI must be directed to OpenAI through its available privacy and account controls.

8. Artificial Intelligence and Automated Processing

We may use artificial-intelligence-enabled tools to support content delivery, customer service, drafting, organization, automation, interactive experiences, and other business functions. We seek to avoid submitting personal information to an AI provider unless reasonably necessary for the relevant function and permitted by our agreements and applicable law.

We do not intentionally use solely automated decision-making to make decisions that produce legal or similarly significant effects concerning individuals. Payment processors and security providers may use automated systems for fraud detection, transaction screening, and account security.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including legal, accounting, tax, security, contractual, operational, and dispute-resolution needs. Our general retention approach is:

Purchase, payment, contract, and tax records: generally seven years after the transaction or end of the customer relationship, unless a different period is required.

Customer and membership accounts: while active and for a reasonable period after closure or expiration.

Program, appointment, and service records: generally three years after the last interaction, unless an active relationship, dispute, agreement, insurance requirement, or legal obligation supports longer retention.

Support communications: generally three years after resolution.

Marketing contact information: until you unsubscribe, withdraw consent, or the information is no longer reasonably needed.

Unsubscribe and suppression records: for as long as reasonably necessary to honor your opt-out.

Analytics and technical records: according to operational need and the shortest reasonable provider setting available to us.

Privacy requests and responses: at least twenty-four months when required by California privacy rules.

Fraud, security, dispute, and collection records: for as long as reasonably necessary to investigate, resolve, document, or defend the matter.

When information is no longer reasonably necessary, we may delete, deidentify, aggregate, or securely dispose of it, subject to technical limitations, backups, legal holds, and permitted exceptions.

10. Data Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information and the Services. These may include access controls, password protections, platform security features, encryption used by service providers, limited access, and business procedures intended to reduce unauthorized access or disclosure.

No system, transmission, platform, or storage method is completely secure. We cannot guarantee absolute security. You are responsible for protecting your account credentials, using secure devices and networks, and notifying us if you suspect unauthorized activity involving an account or communication with us.

11. Your Privacy Choices and Rights

Depending on your location and applicable law, you may have the right to request that we:

Confirm whether we process your personal information.

Provide access to or a copy of personal information.

Correct inaccurate personal information.

Delete personal information, subject to exceptions.

Provide certain information in a portable format.

Restrict or object to certain processing.

Opt you out of the sale or sharing of personal information, targeted advertising, or certain profiling.

Limit certain uses or disclosures of sensitive personal information where applicable.

Honor withdrawal of consent for future processing based on consent.

Review an appeal concerning a denied privacy request where applicable.

You may exercise an applicable right by emailing [email protected] with the subject line "Privacy Request" or by writing to the mailing address in Section 18. Please describe your request and the Service involved.

We may need to verify your identity and authority before responding. Verification may require matching information you provide with information already associated with your account or transaction. An authorized agent may submit a request where permitted, but we may require proof of authorization and may verify the request directly with you.

We will not unlawfully discriminate against you for exercising an applicable privacy right. We may retain information needed to complete transactions, provide requested Services, protect security, comply with law, maintain suppression lists, or exercise or defend legal claims.

If a request concerns information held by a third-party platform and not by Divine Nutrition, you may need to submit the request directly to that platform.

12. California Privacy Information

California residents may have rights under the California Consumer Privacy Act, as amended, when that law applies to our processing. The categories of personal information we may collect, the sources, purposes, and recipient categories are described in Sections 1 through 6 of this Privacy Policy.

We do not sell personal information for money. If we later engage in activity legally defined as sharing personal information for cross-context behavioral advertising, we will provide required notice and an opt-out mechanism. We will also recognize qualifying opt-out preference signals where required by law.

California residents may submit applicable requests using the methods described in Section 11. We may deny or limit a request where an exception applies and will explain the basis when required.

13. EEA, United Kingdom, and Other International Visitors

The Services are operated from the United States and are primarily directed to customers located in the United States. We do not presently direct advertising or promotional campaigns to individuals located in the European Economic Area or the United Kingdom. Our Services may nevertheless be accessible from other locations, and occasional international customers may purchase or participate.

Where European data-protection law applies, our legal bases may include performance of a contract, compliance with legal obligations, consent, protection of legal rights, and legitimate interests that are not overridden by your rights. Those interests may include operating the Services, supporting customers, securing platforms, maintaining records, and improving business operations.

Personal information may be processed in the United States and other countries where our providers or their subprocessors operate. Those countries may have different data-protection laws. Where required, we rely on appropriate contractual, consent-based, or other legally recognized transfer mechanisms.

Depending on applicable law, you may have rights of access, correction, deletion, restriction, portability, objection, and withdrawal of consent, and the right to complain to an appropriate supervisory authority. Contact us using Section 11 to make a request concerning information held by Divine Nutrition.

14. Children and Age Restriction

The Services are intended only for adults age 18 and older. We do not knowingly offer the Services to minors or knowingly collect personal information from individuals under 18 through the Services. If you believe a minor has provided personal information to us, contact [email protected] so we can review the matter.

15. Third-Party Sites and Platforms

The Services may link to or operate through third-party websites, applications, platforms, payment processors, social media services, or embedded content. Their privacy practices are governed by their own policies. We are not responsible for the privacy or security practices of third parties, and we encourage you to review their current terms and privacy notices.

16. Do Not Track and Opt-Out Preference Signals

Some browsers offer a "Do Not Track" setting, but there is no uniform industry standard for interpreting it. We do not currently respond to general Do Not Track signals.

Where applicable law requires us to recognize a qualifying opt-out preference signal, such as a properly configured Global Privacy Control signal, we will process it as required for the browser or device from which it is received.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our Services, providers, business practices, or legal requirements. The revised policy will display a new "Last Updated" date. Material changes may also be communicated through the Services or by another reasonable method where required.

18. Contact Us

For privacy questions, requests, or complaints, contact:

Email: [email protected]

Mail:

Divine Nutrition

17595 Harvard Avenue, Suite C-2590

Irvine, California 92614

United States

If you are located in a jurisdiction that provides a right to complain to a privacy regulator, you may also contact the regulator that serves your place of residence.

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