The Daily ONTRA Privacy Policy

Privacy Policy

Ilana Muhlstein, Inc.

Effective Date: July 7, 2026. This Privacy Policy is effective as of July 7, 2026 and supersedes all prior versions.

Ilana Muhlstein, Inc. (“Company,” “we,” “us,” or “our”), located in Los Angeles, California, operates thedailyontra.com, ilanamuhlstein.com and related sites, The Daily ONTRA membership and community, and our other programs, products, and services (collectively, the “Services”). This Privacy Policy explains what personal information we collect, how we use and share it, and the choices and rights you have. It is incorporated by reference into our Terms of Service.

By using the Services, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree, please do not use the Services.

Information We Collect

Information you provide to us.

•          Account and profile information: name, email address, username, password, phone number, birthday, and profile details you choose to add in our community.

•          Billing information: billing address and payment card details. Payment card numbers are collected and processed by our payment processors (such as Stripe and PayPal) and are not stored on our systems.

•          Community content: posts, comments, photos, videos, progress updates, testimonials, poll and survey responses, messages, and anything else you choose to share in our community or submit to us. This may include information about your eating habits, weight, body, fitness, or wellness goals that you voluntarily share — please share only what you are comfortable with, as community content is visible to other members.

•          Communications: emails, support requests, and text messages you exchange with us.

•          Promotions and events: information you provide when you enter a promotion, complete a quiz or survey, or register for a challenge, webinar, or event.

Information collected automatically. When you use the Services, we and our service providers automatically collect certain information using cookies, pixels, tags, software development kits, and similar technologies, including: IP address, device and browser type, operating system, pages viewed, links clicked, referring pages, approximate location derived from IP address, email open and click activity, video viewing activity, and dates and times of access.

Information from third parties. We may receive information about you from our service providers and partners, such as our community platform (currently Circle), our customer relationship management and marketing platform (currently GoHighLevel), payment processors, email and text messaging providers, analytics providers, and advertising platforms (such as Meta), as well as from social media platforms if you interact with our pages or advertisements there.

Health-Related Information

Our Services relate to nutrition and wellness. We do not require you to provide health information, and we do not collect medical records. However, information you voluntarily share — such as weight-loss progress, eating patterns, or wellness goals posted in the community or submitted in surveys and testimonials — may reveal information about your health. We treat such voluntarily shared information as part of your community content and use it only as described in this Privacy Policy. Some state laws treat health-related information as sensitive; where they apply, you have the additional rights described in the “Your Privacy Rights” sections below.

How We Use Your Information

We use personal information to:

•          Provide, operate, and personalize the Services, including your membership, community access, and program content;

•          Process payments, manage subscriptions and renewals, and send transactional messages (receipts, renewal reminders, trial-conversion notices, account and policy updates);

•          Communicate with you, respond to support requests, and administer challenges, events, and promotions;

•          Send marketing communications, including email and text messages, which you may opt out of at any time;

•          Advertise our Services, including measuring ad performance and showing you ads on other platforms (see “Cookies, Analytics, and Advertising” below);

•          Improve and develop the Services, including analyzing usage, testing features, and conducting research using aggregated or de-identified data;

•          Operate our community, including moderation, spam prevention, search, and enforcement of our Terms of Service and community guidelines;

•          Use content as permitted by the Media, Likeness, and Testimonial Release in our Terms of Service, including in marketing, subject to the opt-out described there;

•          Detect, prevent, and address fraud, security incidents, and technical issues;

•          Comply with legal obligations and enforce our rights.

Artificial intelligence. As described in our Terms of Service, we may use AI tools to support our operations, including drafting communications, generating or assisting with content, moderating community content, personalizing recommendations, and responding to member questions. Content you post may be processed by AI tools for purposes of operating the community, such as moderation, spam prevention, search, and support. We do not use your identifiable member content to train third-party generative artificial-intelligence models without your consent.

Cookies, Analytics, and Advertising

We and our service providers use cookies, pixels, and similar technologies to operate the Services, remember your preferences, understand how the Services are used, measure marketing performance, and deliver and measure advertising.

•          Essential technologies are required for the Services to function (for example, keeping you logged in and processing checkout).

•          Analytics technologies help us understand usage so we can improve the Services.

•          Advertising technologies, including pixels from advertising platforms such as Meta, allow us to show you ads for our Services on other websites and apps and to measure their effectiveness. This may involve the disclosure of identifiers and browsing activity to advertising platforms, which California law defines as “sharing” for cross-context behavioral advertising.

Your choices: You can control cookies through your browser settings; disabling cookies may limit some features. You can opt out of the “sharing” of your information for cross-context behavioral advertising through the “Do Not Sell or Share My Personal Information” link on our website, and we honor the Global Privacy Control (GPC) browser signal as an opt-out where required by law. You can also limit ad tracking through your device settings and through industry tools such as the Digital Advertising Alliance’s opt-out page at optout.aboutads.info.

How We Share Personal Information

We do not sell your personal information for money. We share personal information in the following circumstances:

•          Service providers: with companies that perform services on our behalf under contractual restrictions — including community platform hosting (currently Circle), customer relationship management and marketing automation (currently GoHighLevel), payment processing (such as Stripe and PayPal), email and text messaging delivery, analytics, video and event hosting, cloud storage, customer support, and AI tools used to operate the Services.

•          Advertising partners: with advertising platforms as described above, which may constitute “sharing” under California law. You may opt out as described in this Privacy Policy.

•          Within the community: content you post in the community is visible to other members. Your profile name and photo accompany your posts.

•          Marketing uses of your content: as permitted by the Media, Likeness, and Testimonial Release in our Terms of Service, subject to its opt-out.

•          Legal and safety: when required by law, subpoena, or legal process; to enforce our Terms of Service; to protect the rights, property, or safety of the Company, our members, or the public; or to detect and prevent fraud or security issues.

•          Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, in which case personal information may be transferred as a business asset, subject to this Privacy Policy or notice of a new one.

•          With your direction or consent: when you ask us to share information or otherwise consent to sharing.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you, and we will not attempt to re-identify de-identified data except as permitted by law.

Email and Text Message Marketing

With your consent or as otherwise permitted by law, we send marketing emails and, if you provide your phone number, text messages. Message and data rates may apply to texts. You can opt out of marketing emails using the unsubscribe link in any message and out of texts by replying “STOP.” Opting out of marketing does not stop transactional messages about your account, billing, or membership.

Community Content and Visibility

Our community is private to members, but anything you post is visible to other members and to our team and moderators. We cannot control what other members do with information you share. Please exercise judgment when posting personal information, photos, or health-related details. Content you post is also subject to the license and Media, Likeness, and Testimonial Release in our Terms of Service.

Data Retention

We retain personal information for as long as needed to provide the Services, comply with legal obligations (including tax and accounting requirements), resolve disputes, and enforce agreements. Retention periods vary by data type: for example, account and billing records are retained for the duration of your membership plus the period required by law, marketing data is retained until you opt out or it becomes inactive, and community content is retained while the community operates unless you delete it or request deletion. When retention is no longer necessary, we delete, de-identify, or securely archive the information.

Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information, and our payment processors are responsible for safeguarding payment card data in accordance with industry standards. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please protect your account credentials and notify us immediately of any suspected unauthorized access at thedailyontra@iminc.life.

Children

The Services are intended for adults eighteen (18) and older. We do not knowingly collect personal information from anyone under 18. If you believe someone under 18 has provided us personal information, contact us at info@iminc.life and we will delete it.

Your California Privacy Rights

This section applies to California residents and is provided pursuant to the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), to the extent the CCPA applies to our business.

Categories of personal information. In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email, phone, IP address); customer records (billing address, payment information processed by our processors); commercial information (purchase and subscription history); internet or network activity (usage data, email engagement, browsing interactions with our sites and ads); approximate geolocation (from IP address); audio and visual information (photos, videos, and recordings you provide or appear in); inferences (preferences derived from your activity); and, to the extent you voluntarily share it in community content or surveys, information that may reveal health-related details (which may be sensitive personal information under the CCPA). We collect these categories from the sources, for the purposes, and share them with the categories of recipients described in this Privacy Policy. We do not sell personal information for money; we may “share” identifiers and internet activity with advertising platforms for cross-context behavioral advertising.

Your rights. Subject to legal limits, you have the right to: (1) know and access the personal information we have collected about you; (2) delete personal information we have collected from you; (3) correct inaccurate personal information; (4) opt out of the sale or sharing of your personal information; (5) limit the use and disclosure of sensitive personal information to purposes permitted by law (we use sensitive information only for such purposes, including providing the Services you request); and (6) not receive discriminatory treatment for exercising your rights.

How to exercise your rights. Submit a request by emailing info@iminc.life with the subject line “Privacy Request,” or by using the “Do Not Sell or Share My Personal Information” link on our website for opt-out requests. We will verify your identity using information associated with your account, such as your email address, and may request additional verification for sensitive requests. You may designate an authorized agent to make a request on your behalf; we will require proof of authorization and may still verify your identity directly. We respond to verifiable requests within the timeframes required by law (generally 45 days, extendable once by 45 days with notice). We honor the Global Privacy Control signal as a valid opt-out of sale/sharing for the browser or device on which it is enabled.

California “Shine the Light.” California residents may request information about disclosure of personal information to third parties for their direct marketing purposes by emailing info@iminc.life.

Other U.S. State Privacy Rights

Residents of other states with comprehensive privacy laws (including Colorado, Connecticut, Virginia, Texas, Oregon, and others) may have similar rights to access, correct, delete, and obtain a copy of their personal information, and to opt out of targeted advertising, sale, and certain profiling, to the extent those laws apply to our business. You may exercise these rights, and appeal a refusal, by emailing info@iminc.life with the subject line “Privacy Request.” Where state law treats health-related information as consumer health data and applies to our business, we collect and share such data only with your consent or as necessary to provide services you request, and you may have additional rights to access, delete, and withdraw consent regarding that data.

Users Outside the United States

The Services are operated from the United States and intended for U.S. audiences. If you access the Services from outside the U.S., you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those of your jurisdiction. Where laws such as the EU/UK General Data Protection Regulation apply, we process personal data on the legal bases of contract performance, our legitimate interests in operating and marketing the Services, your consent where required, and legal compliance; and you may have rights to access, rectify, erase, restrict, port, and object to processing, and to lodge a complaint with your supervisory authority. Contact us at info@iminc.life to exercise these rights.

Do Not Track

Some browsers transmit “Do Not Track” signals. Because there is no industry standard for responding to them, we do not respond to Do Not Track signals; however, we do honor the Global Privacy Control as described above.

Third-Party Links and Platforms

The Services may contain links to third-party websites, and portions of the Services run on third-party platforms (such as Circle, social media platforms, and payment processors). This Privacy Policy does not apply to those third parties’ own practices. We encourage you to review the privacy policies of any third-party site or platform you use.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Effective Date” above reflects the latest version. If we make material changes, we will notify you by email or by prominent notice within the Services before the changes take effect. Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acceptance of it.

Contact Us

Ilana Muhlstein, Inc. 5665 W. Wilshire Blvd #1174 Los Angeles, CA 90036

General privacy questions and privacy rights requests: info@iminc.life (subject line “Privacy Request”) The Daily ONTRA membership questions: thedailyontra@iminc.life

If you have an unresolved privacy concern that we have not addressed satisfactorily, California residents may also contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834, or by telephone at (800) 952-5210.