PRIVACY POLICY

Effective Date: 7/20/2026
Last Updated: 7/20/26

Frievalt Photography, LLC, doing business through brands and services that may include Seniors Unlocked, Posabella, The VALT, Dead Pixel Stock, Dan Frievalt, and Frievalt Photography (“Company,” “we,” “us,” or “our”), respects your privacy.

This Privacy Policy explains how we collect, use, disclose, store, and protect information when you use our websites, online stores, educational products, email communications, mobile-friendly web applications, and other services, including:

• seniorsunlocked.com

• store.seniorsunlocked.com

• frievaltphotography.com

• posabella.app

• The Posabella posing and session-planning application

• Related landing pages, forms, courses, memberships, events, and services

Collectively, these are referred to as the “Services.”

By accessing or using the Services, you acknowledge the practices described in this Privacy Policy. Use of the Services may also be governed by separate Terms of Use, purchase terms, subscription terms, or other agreements.

1. Information We Collect

The information we collect depends on how you use the Services.

Information You Provide

We may collect information you voluntarily provide, including:

• Name

• Email address

• Mailing address

• Telephone or mobile number

• Business or studio name

• Account login information

• Subscription or membership information

• Purchase history

• Customer-support messages

• Survey and contest responses

• Marketing preferences

• Information submitted through forms, courses, communities, or events

• Images, session boards, notes, descriptions, tags, and other content uploaded to Posabella

• Information included in reviews, testimonials, comments, or community posts

You are responsible for making sure the information you provide is accurate and that you have the right to provide it.

Payment Information

Payments may be processed by third-party payment providers such as Stripe or Kajabi.

We generally do not receive or store your complete credit-card number. Payment providers may collect payment-card information, billing details, transaction information, and fraud-prevention information under their own privacy policies.

We may receive limited transaction information, such as your name, email address, product purchased, subscription status, payment status, and the last four digits or type of payment card.

Posabella Account and Uploaded Content

When you use Posabella, we may collect and store:

• Your account email and profile information

• Your subscription plan and account status

• Session boards and favorites

• Images you upload

• Notes, tags, descriptions, and instructions associated with uploaded images

• App settings and preferences

• Activity needed to operate, secure, and improve the application

Uploaded content is associated with your account and is not intended to be publicly viewable through Posabella unless a sharing feature is provided and you choose to use it.

Although we do not routinely review private uploads, uploaded content may be stored or processed by our hosting, database, security, and storage providers. Authorized personnel may access account information or uploaded content when reasonably necessary to:

• Provide customer support

• Investigate technical or security problems

• Enforce our Terms of Use

• Respond to suspected illegal activity

• Comply with legal obligations

• Protect users, clients, the public, or the Company

Do not upload anything that you would not want stored through an online service.

Information Collected Automatically

When you access the Services, we and our service providers may automatically collect information such as:

• IP address

• Browser type

• Device type

• Operating system

• Referring webpage

• Pages or features viewed

• Dates and times of access

• Login and session information

• Approximate location based on IP address

• App performance and error information

• Cookie, local-storage, and similar identifiers

This information may be used to operate the Services, remember preferences, prevent fraud, diagnose problems, measure performance, and understand how features are used.

2. How We Use Information

We may use information to:

• Create and manage user accounts

• Deliver purchased products and services

• Operate Posabella and save user boards, favorites, images, notes, and settings

• Process purchases, subscriptions, renewals, upgrades, and cancellations

• Send account activation, login, purchase, billing, and service messages

• Respond to questions and provide customer support

• Send educational content, product announcements, and marketing communications

• Personalize the Services and remember user preferences

• Improve features, products, courses, and content

• Diagnose errors and maintain security

• Detect fraud, abuse, unauthorized access, or violations of our agreements

• Administer contests, surveys, promotions, and events

• Maintain business, tax, accounting, and legal records

• Comply with legal obligations

• Protect the rights, safety, and property of users, clients, the public, and the Company

We do not use private Posabella uploads to advertise to you.

We do not use private Posabella uploads to train public or third-party artificial-intelligence models unless we first obtain your express permission.

3. Legal Grounds for Processing

Where applicable law requires a legal basis, we process personal information based on one or more of the following:

• Performance of a contract with you

• Your consent

• Our legitimate business interests

• Compliance with legal obligations

• Protection of the rights and safety of users, the public, or the Company

You may withdraw consent when processing is based on consent, but withdrawal does not affect processing that occurred before withdrawal.

4. How We Disclose Information

We do not sell personal information for money.

We may disclose information to vendors and service providers that help operate our business, including providers of:

• Website and application hosting

• Cloud storage and databases

• Payment processing

• Email delivery and marketing

• Customer-account authentication

• Analytics and error reporting

• Security and fraud prevention

• Customer support

• Course and membership hosting

• Accounting and professional services

These providers may include Stripe, Kajabi, Resend, Vercel, Cloudflare, and other providers used to host, secure, maintain, or deliver the Services.

We may also disclose information:

• At your direction or with your consent

• To complete a transaction you requested

• To professional advisers such as attorneys or accountants

• In connection with a merger, financing, acquisition, sale, restructuring, or transfer of business assets

• To comply with subpoenas, court orders, laws, or government requests

• To investigate fraud, abuse, infringement, security incidents, or violations of our agreements

• To protect the rights, safety, and property of the Company, our users, clients, or the public

We do not authorize service providers to use private Posabella uploads for their own marketing.

5. Uploaded Images and Third-Party Privacy

You may only upload images and other content that you have the legal right and permission to upload.

Photographs may contain personal information, including a person’s face, likeness, clothing, location, activities, or other identifying details. Before uploading client or model images, you are responsible for obtaining any permission, model release, privacy consent, or other authorization required by your agreement with the person pictured and by applicable law.

Do not upload:

• Images copied from another photographer, website, social-media account, publication, or app without permission

• Images that violate copyright, trademark, privacy, publicity, contractual, or other rights

• Images of clients or minors when you lack permission to store or use those images

• Nude, sexually explicit, exploitative, or pornographic content

• Sexualized images of minors

• Illegal, abusive, threatening, hateful, violent, or harassing content

• Images promoting self-harm, criminal conduct, or unsafe behavior

• Malware or files designed to interfere with the Services

You are responsible for content that you share outside Posabella, including content shown or sent to clients. A client may find an image, pose, note, or concept offensive, inappropriate, or upsetting. You are responsible for reviewing content before sharing it and for using professional judgment based on the client’s age, preferences, culture, comfort, consent, and circumstances.

Additional rules for uploaded content appear in the Posabella Terms of Use.

6. Cookies and Similar Technologies

The Services may use cookies, browser storage, pixels, software-development tools, and similar technologies.

These technologies may be used to:

• Keep you signed in

• Remember preferences

• Maintain shopping-cart and checkout information

• Track affiliate referrals

• Operate subscription and account features

• Measure traffic and feature usage

• Detect fraud or suspicious activity

• Improve security and performance

• Deliver or measure marketing where permitted

The cookies and technologies used may change as our Services and service providers change.

Most browsers let you block or delete cookies. Blocking cookies or browser storage may prevent account, checkout, Posabella, course, or membership features from working correctly.

7. Analytics and Advertising

We may use analytics services to understand traffic, app usage, feature performance, and technical problems.

We may use advertising or marketing tools to measure campaigns or communicate with people who have interacted with our websites. Depending on the tool and applicable law, you may be able to limit certain advertising cookies through your browser, cookie controls, or the provider’s settings.

Private Posabella uploads are not used to create advertising audiences.

8. Email Communications

We may send transactional messages relating to:

• Account activation

• Password resets

• Purchases

• Subscription status

• Billing

• Security

• Customer support

• Changes to the Services

• Other account or service matters

You cannot opt out of messages needed to provide or secure your account while your account remains active.

You may opt out of marketing emails by selecting the unsubscribe link in an email or contacting [email protected]. Unsubscribing from marketing does not stop transactional or account-related messages.

9. SMS Messaging

When you voluntarily provide a mobile number and separately consent to receive text messages, we may send messages concerning products, events, educational resources, appointments, account updates, or promotions.

Message frequency may vary. Message and data rates may apply.

You may opt out by replying STOP. You may reply HELP for assistance or contact [email protected].

Consent to receive marketing text messages is not required as a condition of purchase.

Mobile opt-in information and consent will not be sold or shared with third parties for their own marketing purposes. Information may be provided to messaging vendors as needed to deliver requested messages.

10. Data Retention

We retain personal information for as long as reasonably needed to:

• Maintain your account

• Provide products and services

• Preserve uploaded Posabella content

• Complete transactions

• Maintain tax and accounting records

• Resolve disputes

• Enforce agreements

• Prevent fraud or abuse

• Meet legal obligations

Account and uploaded-content retention may continue until you delete the applicable content, request account deletion, or the account is closed under our Terms.

Some information may remain for a limited period in backups, security logs, transaction records, or records that must be retained by law.

11. Account and Content Deletion

You may request access to, correction of, or deletion of personal information by contacting [email protected].

When requesting account deletion, we may need to verify your identity. Deletion may remove access to saved boards, favorites, notes, uploads, purchases, or other account information.

We may retain information when required for legal, accounting, fraud-prevention, dispute-resolution, or security purposes.

Deleting your Posabella account does not automatically delete information held independently by payment processors or other third parties under their own policies.

12. Data Security

We use reasonable administrative, technical, and organizational measures intended to protect personal information.

No website, application, database, storage system, email system, or internet transmission is completely secure. We cannot guarantee that information will never be accessed, disclosed, altered, lost, or destroyed.

You are responsible for maintaining the confidentiality of your login credentials and for promptly notifying us of suspected unauthorized account access.

13. Children’s Privacy

The Services are intended for adults and business users. They are not directed to children under 13, and children under 13 may not create accounts, make purchases, or submit personal information.

If you are under the age of majority where you live, you may only use the Services with the involvement and permission of a parent or legal guardian.

Posabella users may upload photographs of high-school seniors, dancers, athletes, children, or other minors as part of their photography work. Those images must be uploaded by an adult user who has the rights and permissions needed to use and store them. The presence of a minor in an uploaded photograph does not create an account for that minor.

If we learn that personal information was collected directly from a child under 13 without required parental consent, we will take reasonable steps to delete it.

A parent or guardian who believes a child has directly provided personal information may contact [email protected].

14. State and Regional Privacy Rights

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

• Request access to personal information

• Request correction of inaccurate information

• Request deletion

• Obtain a copy of certain information

• Withdraw consent

• Object to or limit certain processing

• Opt out of certain targeted advertising, sales, or profiling

• Appeal a decision concerning a privacy request

These rights are subject to legal exceptions and may not apply in every location.

To submit a request, contact [email protected]. We may ask for information needed to verify your identity and authority to make the request.

We will not discriminate against you for exercising a privacy right provided by law.

15. International Users

The Company is based in the United States. If you access the Services from outside the United States, your information may be transferred to, processed in, and stored in the United States or other countries where our providers operate.

Privacy and data-protection laws in those locations may differ from the laws where you live.

16. External Links and Third-Party Services

The Services may contain links to websites, applications, social-media platforms, or services we do not control.

We are not responsible for the privacy, security, content, or business practices of third parties. Review their policies before providing information or using their services.

17. Community Features and Public Content

Some Services may allow reviews, comments, group posts, contest submissions, testimonials, or other public or shared content.

Information you voluntarily post in a public or shared area may be viewed, copied, saved, or used by others. Do not post private information that you do not want others to see.

A Posabella upload is treated differently from a voluntary public post unless you choose to share it through an available sharing feature.

18. Business Transfers

If the Company or any part of its business is sold, merged, reorganized, financed, or transferred, personal information may be included among the transferred assets, subject to applicable law.

19. Changes to This Privacy Policy

We may update this Privacy Policy as our Services, providers, and legal obligations change.

The updated version will be posted with a revised “Last Updated” date. Material changes may also be communicated by email, an in-app notice, or another reasonable method.

Continued use of the Services after the effective date of a revised policy means the revised policy applies to your future use, to the extent permitted by law.

20. Contact Us

Questions, requests, complaints, or concerns about this Privacy Policy may be directed to:

Frievalt Photography, LLC
Doing business as Seniors Unlocked and Posabella
Email: [email protected]