Privacy Policy

EVADON LLC ("EVADON", "we", "us") operates the Pacific All Stars application (the "App"), a training, onboarding, recognition, and team-support platform for invited users and support teams. This Privacy Policy explains what personal information we collect, how we use it, how we share it, and the choices and rights available to you. Our Cookie and Analytics Policy explains our use of cookies, local storage, analytics, and similar technologies.

By creating an account, accepting the current legal documents, or continuing to use the App after an update that requires re-acceptance, you agree to this Privacy Policy and our Terms of Service.

1. Who is responsible for your information

EVADON LLC is responsible for the personal information described in this Privacy Policy.

Contact: Use our contact form to reach us with any privacy question or request.

2. Information we collect

We collect information directly from you, automatically when you use the App, from your sponsor or invite relationship, from service providers, and, if you choose to connect it, from a connected partner-company account.

Account and registration information

We collect your first name, last name, email address, hashed password or passwordless authentication records, country, invite code, sponsor relationship, legal-document consent records, and account status. We may also collect pending registration information while you complete email verification.

Profile and contact information

We collect profile information such as your avatar, phone number, timezone, city, postal code, "my why" statement, partner-company account name, partner-company account ID, social profile links, alternate email address, and SMS/contact details if you provide them.

Onboarding responses

We collect your onboarding answers, including product experience, product story, business knowledge, desired outcome, commitment level, DISC quick-pick, motivator quick-pick, entrepreneurial self-efficacy confidence answers, onboarding progress, and PWA install status. These answers are self-reported by you.

Business, training, and recognition activity

We collect information about courses, lessons, completed lesson actions, star ratings, trackers, points, achievements, achievement approvals, leaderboards, learning streaks, heatmaps, feedback, the time you spend watching training videos (including the daily and weekly watch-minute totals we record to provide in-app progress features), and recognition images or slides generated for achievements.

Organization and sponsor/upline information

The App stores your sponsor and downline/upline relationships. Depending on your role and position in the organization, your sponsor or eligible upline may be able to see information about you, including your name, avatar, country, city, postal code, account creation date, last activity, contact details you provide, email deliverability status, lifetime and weekly points, course progress, tracker activity, learning streaks, and activity heatmap.

To support coaching and help you complete training, we may also share progress and engagement insights derived from this activity — such as course progress, learning streaks, training watch-time, and indicators that you may be falling behind — together with suggested actions your sponsor or upline can take to help. These insights are provided to support your learning and progress. They are not a measure, promise, prediction, or guarantee of income, rank, achievement, or business success.

App usage, analytics, and technical information

We collect usage and technical information such as pages and actions used, in-app searches, device/browser type, operating system, app version, platform, PWA status, approximate location derived from IP address, IP address, user agent, session information, personal access token metadata, and last-used token IP address.

We use analytics to support the product, understand usage, and improve the App, and may associate analytics events with your account identifier. We currently use Matomo, and may use other analytics providers over time (for example Mixpanel or analytics built into our native mobile apps) for the same purpose. Our Cookie and Analytics Policy describes our analytics technologies, how we ask for analytics consent, and how you can change your choice. We are also building a first-party watch-time tracker for training videos, which lets us measure video progress ourselves and reduces our reliance on third-party analytics.

Email, notification, and support information

We collect email delivery information such as delivery, open, click, bounce, unsubscribe, reject, suspension, and spam events, along with message IDs, timestamps, reasons, categories, and related provider event data. We use this to deliver account and service messages, diagnose email problems, and protect account security.

If push notifications are offered and you opt in, we may store a device token linked to your account and send notifications through Apple Push Notification service (APNs), Firebase Cloud Messaging (FCM), or another push provider.

If you submit feedback or support requests, we collect the content of those messages and related account information.

Uploaded content and media

We collect files and content you upload or provide, including avatar images, goal descriptions, profile text, feedback, and other in-app content.

If you attend, speak at, or participate in Pacific All Stars events, trainings, calls, or recordings, we may collect photos, video, audio, transcripts, your name, likeness, voice, statements, and related event metadata, subject to the consent and release terms in the Terms of Service.

Video engagement

We host and deliver training and other videos using third-party video services, currently YouTube (for embedded training videos) and Mux (for video delivery). When you watch these videos, the provider may collect video playback and engagement information such as videos viewed, playback events, device/browser data, approximate location, and error/performance data, and may set cookies or use similar technologies. Embedded YouTube players in particular may set cookies and collect data on YouTube's own servers. See our Cookie and Analytics Policy. We also record our own in-app watch-time totals (see above).

Connected partner-company account information

We may offer an optional feature that lets you connect an account you hold with a partner company. If you choose to connect such an account, you authorize us to collect and process the information made available through that connection for App features such as activity tracking, achievement verification, badges, coaching, reporting, fraud prevention, and support.

Connected data may include your account or participant identifiers, account status, sales or volume data, customer/order-related data, product or transaction metadata, achievement-eligibility data, sync status, sync timestamps, and error logs.

If this feature is offered, we may use OAuth tokens, API credentials, or similar access credentials to provide the connection. We do not intend to collect or store your Partner Company account password unless we clearly disclose that before you connect the account. You may disconnect the feature through the App where available or through our contact form. We may retain imported data as described in this Privacy Policy for achievement records, fraud prevention, support, legal, dispute, backup, or de-identified analytics purposes. We do not share connected-account data back to a Partner Company except as permitted by the integration, your authorization, applicable agreements, or law.

3. How we use information

We use personal information to:

• Provide, operate, personalize, and support the App.
• Register users, verify email addresses, manage sessions, and secure accounts.
• Enforce current Terms of Service and Privacy Policy acceptance.
• Complete onboarding and tailor training, coaching, and recommendations.
• Operate sponsor, upline, downline, organization, leaderboard, tracker, points, and achievement features.
• Verify achievement eligibility, including through a connected partner-company account if you enable that feature.
• Generate recognition images, slides, posts, badges, and internal reports.
• Send transactional, security, onboarding, sponsor, achievement, and service communications.
• Send progress reminders, nudges, and encouragement, based on your training activity and engagement (including watch-time), to help you start and complete courses and training.
• Surface progress and engagement insights, and suggested coaching actions, to your sponsor or eligible upline so they can help you progress and complete training.
• Deliver optional push notifications if you opt in.
• Analyze usage, diagnose issues, improve reliability, and develop product features.
• Monitor email deliverability and respond to bounces or failed communications.
• Prevent abuse, unauthorized access, fraud, scraping, and misuse.
• Comply with law, enforce our rights, and respond to legal requests.
• Create aggregated or de-identified insights and research about training, onboarding, user progress, and program effectiveness.

We do not sell personal information. If we later use advertising or tracking practices that count as a "sale" or "sharing" under applicable privacy laws, we will update this Privacy Policy and provide any required opt-out rights before doing so.

4. Research and aggregated insights

We may use aggregated or de-identified information to study what helps users learn, stay active, complete training, and progress through achievements. We may publish or share aggregated or de-identified findings, including academic, industry, or internal program insights, where the information does not reasonably identify you.

We do not use aggregated or de-identified research as a promise, prediction, or guarantee of income, rank, achievement, sales, or business success.

5. Recognition, publicity, and media use

The App includes recognition features. Recognition works in two ways:

• In-app recognition. Your name, avatar, country, achievements, badges, points, and leaderboard position may be visible inside the App to other users, your sponsor, and eligible upline as part of the App's core features. Some badges are awarded automatically for activity and are core App features.
• Major / public recognition and event media. Major recognition — such as recognition images, social media posts, presentations, event highlights, recordings, and marketing or training materials — is generally user-initiated or based on your participation in an event, training, call, recording, or recognition activity. When you request recognition, attend or participate in a recorded event, submit media, speak on a call, or provide statements for App or community use, you consent to that recognition or event-media use. Where recognition or event media would be used publicly or for marketing, you may ask us to stop future public use by contacting us through our contact form; we may be unable to remove materials already reasonably published or distributed.

6. How we share information

We may share personal information with:

• Your sponsor and eligible upline: to support organization, coaching, reporting, onboarding, and recognition features.
• Other users: where App features show leaderboard, achievement, recognition, sponsor, or organization information.
• Administrators and authorized team members: to operate the App, provide support, review achievements, manage content, review activity, and maintain safety and security.
• Service providers: hosting, infrastructure, database, storage, backup, analytics, email delivery, video hosting, error monitoring, image generation/rendering, and support providers that process information for us.
• A connected partner company or connected-account provider: only if we offer the optional connected-account feature, and only as described for that feature where permitted by the integration, your authorization, applicable agreements, or law.
• Professional advisers: lawyers, accountants, auditors, insurers, and security advisers.
• Legal and safety recipients: regulators, courts, law enforcement, or other parties where required by law or reasonably necessary to protect rights, safety, security, or the integrity of the App.
• Business transfer recipients: if we are involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, subject to appropriate confidentiality and legal protections.

7. Service providers and processing locations

We use third-party providers to operate the App. Current or planned providers may include:

Provider	Purpose	Location / notes
DigitalOcean	Primary hosting / infrastructure	Australia
AWS / S3	Backups, storage, recognition assets	Sydney, Australia (ap-southeast-2); other regions if added
Matomo	App analytics and usage reporting	Matomo Cloud, EU region
Mixpanel / native mobile-app analytics	Additional analytics (if used)	Future or optional analytics providers; regions to be confirmed before use
Mailtrap	Transactional email and email event tracking	Mailtrap cloud; regions where Mailtrap processes email data
Sentry	Error monitoring and diagnostics	Sentry cloud; United States or other regions where Sentry processes data
YouTube	Training video hosting and playback	Google, global
Mux	Video delivery and playback analytics	Mux cloud; global video delivery and processing
APNs / FCM	Push notifications	Apple, Google, or another push provider depending on your device and the notification service we make available
Connected-account provider	Connected partner-company account verification	Provider and region depend on the connection you choose or we make available

We may update providers over time. Material changes will be reflected in this Privacy Policy where required.

8. International transfers

We operate across multiple countries and EVADON LLC is organized in the United States. Your personal information may be collected, stored, accessed, or processed outside your country of residence, including in the United States, Australia, or other countries where we or our providers operate.

Where required, we use reasonable safeguards for cross-border transfers, such as vendor due diligence, contractual protections where available, security controls, and legally required transfer mechanisms.

9. Legal bases where applicable

Where GDPR, UK GDPR, or similar laws apply, our legal bases may include:

• Contract: to provide the App and connected features you request.
• Consent: for optional features, connected-account access, certain analytics/cookies, marketing communications, push notifications, or publicity/media use where consent is required.
• Legitimate interests: to secure, improve, operate, analyze, and administer the App, prevent abuse, provide support, and create de-identified or aggregated insights.
• Legal obligation: to comply with laws, enforce legal rights, and respond to valid legal requests.

10. Cookies, analytics, and similar technologies

We may use cookies, local storage, SDKs, pixels, or similar technologies to keep you signed in, remember preferences, secure sessions, measure App usage, and diagnose issues.

Our Cookie and Analytics Policy provides more detail about the categories of technologies we use, what is strictly necessary, what is optional analytics, and how you can manage choices.

Matomo Cloud uses cookies, IP anonymization, and account-linked user IDs for App analytics. Our Cookie and Analytics Policy lists current known cookie and storage categories.

11. Security

We use reasonable technical and organizational measures designed to protect personal information, including hashed passwords, access controls, encryption where appropriate, audit/activity logging, restricted administrative access, backup protections, and monitoring. No system is perfectly secure, and we cannot guarantee absolute security.

12. Retention

We keep personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Current intended approach:

• Account profile data: retained while your account is active, then deleted, anonymized, or archived after account deletion, subject to legal, security, backup, and dispute needs.
• Consent records: retained while your account is active and for a reasonable period afterward to evidence legal-document acceptance.
• Security, session, token, IP, and audit logs: retained for up to 24 months.
• Email delivery events: retained for up to 24 months.
• Search logs and analytics: analytics data is retained for up to 24 months; search logs are retained for up to 24 months or aggregated/de-identified.
• Feedback and support messages: retained for up to 24 months after the matter is resolved.
• Achievement, points, recognition, and organization records: retained for the life of your account as part of program history and for fraud prevention.
• Connected partner-company imported data: retained while the account is connected and for a reasonable period after disconnect/deletion unless de-identified or required for dispute, fraud, legal, or achievement-record purposes.
• Backups: backups are retained on a tapered schedule up to approximately 24 months and are then deleted under the backup schedule. Personal information may remain in backups until the relevant backup expires. Backups are encrypted at rest.
• Aggregated or de-identified data: may be retained indefinitely.

13. Your choices and rights

Depending on your location, you may have rights to access, correct, delete, restrict, object to, or port your personal information; withdraw consent; opt out of certain processing; limit use of sensitive information; or complain to a regulator.

You may also be able to:

• Update profile information in the App.
• Change or verify your login email through the App's email-change flow.
• Change your analytics consent choice in the App.
• Disable push notifications through your device settings.
• Disconnect a connected partner-company account if that feature is offered.
• Request deletion of your account, or ask any privacy question, through our contact form.

We may need to verify your identity before fulfilling a request. Some information may be retained where required or permitted by law, for security, dispute resolution, fraud prevention, backup retention, or legitimate business records.

14. California and US state privacy notice

The United States is our home country and a targeted market. Where the California Consumer Privacy Act (as amended by the CPRA) or another US state privacy law applies to our handling of your personal information, you may have rights to know, access, delete, and correct your personal information, to opt out of any sale or sharing, to limit the use of sensitive personal information, and not to be treated differently for exercising these rights. You can exercise these rights through our contact form. As our services and scale change, we will update this notice and provide any additional US state privacy disclosures or controls that become required.

We do not sell personal information or share it for cross-context behavioral advertising.

15. GDPR, UK GDPR, and non-target European users

Some users may access the App from the United Kingdom, the European Union, or other non-target locations. We do not currently target the EU or UK, maintain an establishment there, or offer localized EU/UK services. If our activities change so that EU GDPR, UK GDPR, or related ePrivacy rules apply, we will update this Privacy Policy and provide any required rights, notices, safeguards, or consent choices.

16. Australian and New Zealand users

Australia and New Zealand are targeted markets. For users in Australia, we handle personal information consistent with the Australian Privacy Principles under the Privacy Act 1988 — including transparency about how we collect, use, and disclose personal information, overseas disclosure, access and correction, data security, and complaints handling.

For New Zealand users, note that the Privacy Act 2020 includes notification obligations when personal information is collected directly from you and, from 1 May 2026, additional notification obligations for certain indirect collection. This is relevant to the optional connected partner-company account feature because connected partner-company account data may be collected from a source other than you.

If Australian or New Zealand privacy laws apply to us and to you, we handle personal information in line with applicable privacy principles, including principles relating to collection, notice, use, disclosure, access, correction, security, retention, and overseas disclosure.

You may contact us through our contact form. You may also have the right to contact the Office of the Australian Information Commissioner or the New Zealand Office of the Privacy Commissioner.

17. Other locations

The App is intended for users in the United States and Pacific countries and territories where we make it available. We may also receive incidental access from other regions. Except where this Privacy Policy says otherwise, we do not currently provide separate localized privacy notices for every country or territory where the App may be accessed.

If privacy or data-protection law in your location gives you additional rights or requires additional notices, restrictions, or safeguards, those requirements apply only to the extent required by that law. We may limit or disable features in a country or region if we believe continued availability creates legal, regulatory, privacy, security, or operational risk.

18. Pacific communities

Many of our users are Pacific peoples. We aim to handle information from Pacific communities with care, respect, transparency, and accountability. Where we use aggregated or de-identified insights to improve training, onboarding, recognition, or program effectiveness, we do not use those insights as a promise or prediction of income, rank, sales, or business success.

19. Children

The App is not intended for anyone under 18. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided personal information, contact us through our contact form.

20. Changes to this Privacy Policy

We may update this Privacy Policy. Material changes will be notified in the App, by email, or through another reasonable method. Where required, we will ask you to accept the updated Privacy Policy before continuing to use the App.

21. How you agree

When you create an account or when we publish a new version that requires acceptance, you are asked to affirmatively agree to this Privacy Policy and the Terms of Service. We record the document version, effective date, acceptance date, and user agent associated with your acceptance.

22. Contact

EVADON LLC
Reach us through our contact form.