Privacy, Data Protection & Email Communications Policy

Wholesome Winning Performance, LLC

Including WWPLIFE and Adira Trading Academy

Last Updated: OCT, 30th 2026

1. Introduction

Wholesome Winning Performance, LLC ("WWP," "we," "our," or "us") is committed to respecting and protecting the personal information of our clients, athletes, students, website visitors, and prospective customers.

We provide professional services and educational programs through our business and related brands, including:

• WWPLIFE: Endurance sports coaching, nutrition education, performance consulting, wellness programs, and related services.

• Adira Trading Academy: Financial markets education, trading methodology instruction, student development, workshops, and related educational programs.

This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, and the choices and rights available to individuals.

It applies to our websites, online forms, applications, consultations, educational programs, email communications, and other services operated by Wholesome Winning Performance, LLC.

We are committed to transparency, responsible data management, and appropriate privacy safeguards.

2. Business Identity and Contact Information

Legal Entity: Wholesome Winning Performance, LLC

Business Brands: WWPLIFE and Adira Trading Academy

Website: https://www.wwplife.com

Educational Brand Website: https://www.adiratradingacademy.com 

Privacy Contact: services@wwplife.com

Business Mailing Address: 5760 Lindero Canyon Rd #1203, Westlake Village, CA 91362, USA

Wholesome Winning Performance, LLC is responsible for determining the purposes and methods of processing personal information collected through its services, unless another organization is separately identified as responsible.

For privacy-related questions or requests, please contact us at services@wwplife.com.

3. Information We Collect

Depending on your interaction with our services, we may collect the following information.

A. Contact and Identification Information

• Full name

• Email address

• Telephone number, when provided

• Country of residence and time zone

• Billing or contact information

• Other information you voluntarily provide when communicating with us

B. Coaching, Nutrition, and Wellness Information

When providing athletic coaching, performance consulting, nutrition education, or wellness services, we may collect information such as:

• Athletic background and training experience

• Training objectives, schedules, and performance metrics

• Exercise habits, recovery, and lifestyle information

• Nutrition habits and dietary preferences

• Relevant physical limitations, injuries, or health-related information voluntarily disclosed for the requested service

• Results from performance evaluations, assessments, or consultations

Some information in this category may qualify as sensitive personal data and may require additional safeguards and a specific legal basis for processing.

We will seek explicit consent where required for processing sensitive health-related information and will limit such processing to legitimate and clearly identified service purposes.

C. Adira Trading Academy Student Information

When individuals apply for, enroll in, or participate in Adira Trading Academy programs, we may collect:

• Previous financial markets or trading education experience

• Familiarity with trading platforms and tools

• Educational goals and learning preferences

• Preferred language of instruction

• Self-assessments of trading knowledge and competencies

• Responses to questionnaires, exercises, and educational evaluations

• Participation, progress, and feedback during educational programs

This information helps us determine program suitability, organize instructional groups, tailor the educational experience, and evaluate learning outcomes.

Adira Trading Academy does not require students to disclose brokerage account passwords, personal investment account credentials, or confidential financial account information as part of its standard educational intake.

Students should not include such information in questionnaires or exercises.

D. Payment and Transaction Information

When purchasing our services, payment information may be processed by third-party payment platforms.

We may receive information such as purchase details, payment status, transaction references, and billing records.

Payment card details are generally processed directly by the applicable payment provider rather than through our intake questionnaires.

E. Website and Technical Information

When visiting our websites or using online services, certain technical information may be collected automatically, including:

• IP address

• Browser and device information

• Pages visited and general website interactions

• Technical and security logs

• Cookie-related information, where applicable

The information collected depends on the technologies and service providers used by the website.

4. How We Use Personal Information

We use personal information for legitimate and clearly identified business purposes, including:

Providing Services

To deliver coaching, nutrition education, performance consulting, trading education, workshops, and other services requested by our customers.

Managing Applications and Enrollment

To review program applications, communicate with prospective participants, organize groups, and coordinate enrollment.

Personalizing Educational and Coaching Experiences

To understand individual learning objectives, athletic goals, and development needs.

Evaluating Educational Outcomes

To assess student progress, improve instructional materials, and determine the effectiveness of our educational programs.

Communicating with Customers and Students

To respond to inquiries, provide scheduling information, distribute educational materials, communicate service updates, and provide support.

Improving Our Services

To evaluate customer feedback, identify educational needs, develop new programs, and improve the quality of our services.

Where practical, we may use aggregated or de-identified information for internal evaluations and business planning.

Payment Processing and Administration

To process transactions, maintain accounting records, and comply with applicable administrative and legal obligations.

Security and Compliance

To protect our systems, prevent misuse, maintain operational security, and comply with applicable legal requirements.

5. Legal Bases for Processing Personal Data

Where the General Data Protection Regulation (GDPR) or similar privacy legislation applies, we process personal information on an appropriate legal basis.

Depending on the purpose, these may include:

• Contractual necessity: Providing services or taking steps requested by individuals before entering into a service agreement.

• Legitimate interests: Managing ordinary business operations, improving educational programs, responding to inquiries, and maintaining security, where these interests are not overridden by individual rights.

• Consent: Sending certain promotional communications, processing sensitive information where explicit consent is required, or using optional tracking technologies where consent is required.

• Legal obligations: Maintaining required financial, accounting, tax, or other legally mandated records.

Where we rely on legitimate interests, we consider the necessity of the processing and its potential impact on individuals.

Individuals may withdraw consent where processing is based on consent. Withdrawal does not affect processing already lawfully completed or information that must be retained under another valid legal basis.

6. Email Communications and Marketing

We collect and use email addresses for purposes including:

• Responding to inquiries

• Delivering purchased services

• Sending appointment confirmations and scheduling information

• Providing educational materials and program updates

• Managing student applications and enrollment

• Distributing newsletters, announcements, and promotional communications when permitted

Service-related communications and marketing communications are treated separately.

Providing an email address to inquire about coaching or apply to an Adira pilot program does not automatically mean that the individual has subscribed to promotional email marketing.

Where consent is required, we will request it separately.

Recipients of marketing communications may unsubscribe using the unsubscribe mechanism provided in those messages or by contacting: services@wwplife.com.

We do not sell or rent our email subscriber lists to outside parties.

7. Adira Trading Academy — Student Assessments and Pilot Programs

Adira Trading Academy may use intake questionnaires, learning assessments, and program feedback surveys to develop and evaluate its educational offerings.

Information collected may be used to:

• Identify participant experience levels

• Understand preferred learning topics

• Evaluate baseline educational competencies

• Assess program suitability and availability

• Measure progress between initial and final assessments

• Improve curriculum design and instructional methods

Admission decisions for the pilot are reviewed by the program team rather than determined solely through automated profiling.

Participation in an educational assessment does not authorize the use of a student's name, image, testimonial, or identifiable results in public marketing materials.

Separate permission will be requested before using identifiable student testimonials or success stories for promotional purposes.

Students may be invited to provide feedback voluntarily to support program development.

8. Sharing Information with Service Providers

We may use trusted third-party service providers to operate and deliver our services.

Depending on the service, these providers may include:

• Google Workspace, Google Forms, Google Sheets, and other Google services for communication, document management, and questionnaires

• Payment processing and billing services, including Stripe where used

• Training, coaching, and performance-management platforms where used

• Online meeting and educational delivery platforms

• Website hosting, booking, email distribution, and customer-support platforms

• Professional accounting, legal, or administrative service providers when necessary

We share personal information only as reasonably necessary to provide the relevant services, support legitimate business operations, or comply with applicable law.

Providers may process information under their own privacy policies or under agreements governing the processing they perform on our behalf.

We do not authorize service providers acting on our behalf to use personal information for unrelated purposes.

Information may also be disclosed where required by law or when reasonably necessary to protect legal rights and security.

9. International Data Processing and Transfers

Wholesome Winning Performance, LLC operates in an international environment, serving individuals in the United States, Europe, and other regions.

Personal information may be accessed or processed in countries other than the country in which it was originally collected, depending on service providers, business operations, and technical infrastructure.

Where applicable privacy laws require safeguards for international transfers, we will use appropriate transfer mechanisms.

Individuals may contact us for further information about applicable data transfer safeguards.

10. Data Retention

We retain personal information only for as long as necessary to provide our services, fulfill legitimate business purposes, and comply with applicable legal obligations.

Our retention practices include:

• Adira pilot applications: Unsuccessful or withdrawn applications may be retained for up to 12 months after the application process closes.

• Adira student records: Educational assessments, participation records, and related information may be retained for up to 24 months after the student's last educational activity.

• Coaching and consulting records: Retained during the service relationship and afterward as necessary for documented business purposes, legal obligations, or potential legal claims.

• Billing and financial records: Retained for the periods required by applicable tax, accounting, and commercial laws.

• Marketing subscription information: Subscription information is retained until an individual unsubscribes or the information is no longer needed. Limited records may be maintained to honor unsubscribe requests.

• Website, Technical and security records: Retained only as long as reasonably necessary for their documented operational and security purposes.

At the end of the applicable retention period, information will be deleted, anonymized, or otherwise handled in accordance with legal requirements.

11. Data Security

We take reasonable technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or loss.

Such measures may include access controls, account authentication, restricted sharing permissions, and the security features of our selected service providers.

Access to personal information is limited to authorized individuals who need the information to perform their responsibilities.

No electronic transmission or storage system can be guaranteed to be completely secure.

If you believe information you provided to us has been compromised, please contact services@wwplife.com.

12. Your Privacy Rights

Depending on your place of residence and applicable privacy legislation, you may have rights to:

• Request access to personal information held about you

• Request correction of inaccurate information

• Request deletion of personal information

• Request restriction of certain processing activities

• Object to certain processing, including direct marketing

• Request portability of qualifying personal data

• Withdraw consent where consent is the legal basis for processing

• Obtain information about applicable automated decision-making

We will evaluate and respond to requests in accordance with applicable law.

To submit a request, contact:

services@wwplife.com

We may request reasonable information to verify your identity before processing certain requests.

Individuals covered by the GDPR also have the right to lodge a complaint with a competent data protection supervisory authority.

13. Cookies and Website Technologies

Our websites may use cookies, embedded content, and similar technologies to support website functionality, security, and user experience.

Depending on the website configuration, certain technologies may also help us understand site usage or evaluate the effectiveness of communications.

Some third-party services embedded in our websites may use their own cookies or related technologies.

Where legally required, we will obtain consent before activating optional analytics, advertising, or other non-essential tracking technologies.

Visitors may also manage certain cookies through their browser settings and, where available, the website's cookie-preference controls.

Additional information about specific cookies and applicable choices will be provided where required.

14. Information Relating to Minors

Adira Trading Academy's standard pilot program is intended for participants who are at least 18 years old.

WWPLIFE may separately provide athletic coaching or educational services to minors where appropriate.

For services involving minors, we will apply additional safeguards and obtain parental or guardian involvement, permission, or consent where required.

We do not intentionally solicit unnecessary personal information from minors.

15. Educational Records, Confidentiality, and Testimonials

We respect the privacy of individual coaching and educational relationships.

Personal student assessments, individual athletic performance information, and private consultation records are not intended for public disclosure.

We may publish general educational insights, aggregated outcomes, or anonymized examples when individuals cannot reasonably be identified.

Identifiable testimonials, photographs, recorded student experiences, or individual achievements will be used for promotional purposes only with appropriate authorization.

If an educational session will be recorded, participants will be notified in advance and any legally required consent will be obtained.

16. Third-Party Websites and Services

Our websites and educational materials may contain links to third-party websites, brokers, training platforms, or educational resources.

We are not responsible for the privacy practices of independent third-party websites.

Individuals should review the applicable privacy policies before providing personal information directly to those organizations.

17. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, operating practices, technologies, or applicable legal requirements.

The latest version will be published on our website, together with the date of the most recent update.

Where required, we will provide additional notice or obtain consent before implementing material changes to how personal information is used.

18. Contact Us

For questions about this Privacy Policy, our data practices, or your personal information, please contact:

Wholesome Winning Performance, LLC

WWPLIFE | Adira Trading Academy

Email: services@wwplife.com

Website: https://www.wwplife.com

Mailing Address: 5760 Lindero Canyon Rd #1203, Westlake Village, CA 91362, USA

We welcome privacy-related questions and requests and are committed to handling them responsibly.