Last Updated: March 26, 2026
True Offers USA, LLC d/b/a Empowered Homefront ("Empowered Homefront," "Company," "we," "us," and "our") respects your privacy and is committed to protecting it through compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.empoweredhomefront.com, use our platforms and tools (including the Deal Boss CRM), participate in our educational programs, access our online communities, or otherwise use our services as described in our Terms of Service.
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use our services. By accessing or using our services, you agree and consent to this Privacy Policy.
Empowered Homefront may change this Privacy Policy at any time, at its discretion. Your continued use of our services after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.
This Privacy Policy is subject to and governed by the Empowered Homefront Terms of Service. Our services include our educational programs, CRM platform, community platforms, digital products, subscription services, and related tools described in the Terms of Service.
This Privacy Policy applies to all products, services, websites, applications, and brands operated under the Empowered Homefront ecosystem, including but not limited to:
Empowered Homefront may collect two types of information from you: Personal Information and Non-Personal Information (collectively "Information").
"Personal Information" refers to data by which you may be personally identified, such as name, email address, phone number, billing address, business information, and payment details.
"Non-Personal Information" means data that is about you but does not identify you specifically, such as browser type, device information, and aggregated usage statistics.
Account Registration and Profile Information:
Educational Program Participation:
CRM and Platform Usage:
Community and Social Platform Usage:
Customer Support Communications:
Platform Usage Data:
Device and Technical Information:
Communication and Marketing Data:
Third-Party Platform Integrations:
Business Partners and Data Providers:
Data Verification Services:
Personal Information in AI Interactions: When you interact with our AI systems, we may process personal and business information you provide to generate educational responses.
No AI Training Use: We do NOT use your personal information, business details, or AI interaction data to train general AI models or improve AI systems for other users.
AI Response Storage: AI interactions may be stored for quality assurance and to improve your individual educational experience.
Third-Party AI Services: Our AI systems may utilize third-party AI services. Your interactions are subject to our privacy practices, not those of AI service providers.
We use Personal Information that we collect about you or that you provide to us for the following purposes:
For users in the European Economic Area and United Kingdom, our legal basis for processing includes:
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.
Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests.
Empowered Homefront is the Data Controller of all Personal Information collected through our platforms in the EEA and the United Kingdom, except with respect to services where Empowered Homefront acts as the Data Processor, or where a supplemental Privacy Policy says otherwise.
Our services rely on several third-party platforms to provide functionality. By using our services, you acknowledge and agree to the data practices of these platforms:
Go High Level / LeadConnector:
Twilio (Communications):
Google API Services: Our platform's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
YouTube API Services: If you connect your YouTube account, the Google Privacy Policy (https://policies.google.com/privacy) applies. You may revoke our access via Google security settings (https://security.google.com/settings/security/permissions).
Stripe:
Google Analytics:
Skool: We use Skool as a community platform. When you join our Skool communities, your data is also subject to Skool's privacy practices. Please review Skool's privacy policy at https://www.skool.com/legal.
We share Personal Information in the following circumstances:
We may share information with other parties when you provide explicit consent for such sharing.
Important: We do NOT sell your Personal Information for monetary compensation. We do NOT share your phone number or SMS opt-in consent with third parties without your express written consent.
We retain Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including:
Upon Account Cancellation: Most personal data is deleted within a reasonable timeframe, though some information may be retained for legal, security, or business continuity purposes as permitted by applicable law.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see "Your Privacy Rights" below for further information. And in some circumstances we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
True Offers USA, LLC d/b/a Empowered Homefront complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
We have certified our adherence to the DPF Principles regarding the processing of personal data received from the European Union, United Kingdom, and Switzerland. If there is any conflict between this privacy policy and the DPF Principles, the Principles shall govern.
To learn more about the DPF program and view our certification, visit: https://www.dataprivacyframework.gov/
When we transfer Personal Information internationally, we ensure appropriate safeguards are in place, including:
Empowered Homefront is a U.S.-based company. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries. We may also transfer your Personal Information to our third-party service providers, who may be located in a different country to you.
Empowered Homefront transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.
The Federal Trade Commission has jurisdiction over Empowered Homefront's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. Empowered Homefront may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Empowered Homefront is liable in cases of onward transfers to third parties.
California (CCPA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA):
Residents of these states have additional rights including:
To Exercise Your Rights: Contact us at [email protected] or use our privacy request portal.
EEA/UK/Swiss Residents have additional rights:
You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. You can exercise these rights by making a written request using the contact details provided in the "Contact Information" section below.
Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.
If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, contact your local data protection authority. Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you. Under certain conditions, you may invoke binding arbitration.
Complaints: You may file complaints with your local data protection authority.
We implement comprehensive security measures to protect your Personal Information:
Technical Safeguards:
Administrative Safeguards:
Physical Safeguards:
Vendor Management:
No technology, data transmission or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any Empowered Homefront account has been compromised), please immediately notify us by contacting us using the instructions in the "Contact Information" section below.
Our services are not directed to children under 13. We do not knowingly collect Personal Information from children under 13 without verifiable parental consent, as required by the Children's Online Privacy Protection Act ("COPPA").
Empowered Homeschool and Family Programs: Certain educational programs (including Empowered Homeschool) are designed for use by families with minor children. For these programs:
If we learn that we have collected Personal Information from a child under 13 without verifiable parental consent, we will delete it promptly. If you believe a child has provided us with Personal Information without proper consent, please contact us at [email protected].
We use cookies and similar technologies to:
Cookie Consent: When you first visit our website, a cookie consent notice will be presented allowing you to accept or manage your cookie preferences. You may adjust your preferences at any time. For visitors in jurisdictions requiring prior opt-in consent (such as the European Economic Area), non-essential cookies will not be placed until you provide consent.
Cookie Management: You can also control cookies through your browser settings, though disabling cookies may affect platform functionality. You may opt out of certain third-party cookies through industry opt-out tools such as the Network Advertising Initiative (optout.networkadvertising.org) or the Digital Advertising Alliance (optout.aboutads.info).
Advertising Pixels: Our websites may use tracking pixels from advertising platforms including Meta (Facebook/Instagram), Google Ads, and TikTok to measure the effectiveness of our advertising campaigns. These pixels may collect information about your browsing activity to serve targeted advertisements. You can opt out of this tracking through the cookie consent notice on our website or the opt-out tools listed above.
Technologies similar to cookies, such as pixel tags, are also used in connection with our platforms. For more information on our use of cookies, please see our Cookie Policy.
Email Communications:
SMS Communications:
Phone Communications:
Please note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or services, such as information about a security update, service issue, or product delivery.
This section is addressed to California residents only and provides more information about your rights under the California Consumer Privacy Act or "CCPA" (California Civil Code Section 1798.100 et seq.), as amended.
Subject to certain exceptions, the CCPA grants to California residents the rights to: be notified about the collection, use, disclosure, sale or sharing of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the "sale" or "sharing" of Personal Information (where such information is sold or shared); limit the use or disclosure of Sensitive Personal Information (as defined under CCPA); and to not be discriminated against for exercising such rights.
| Category | Collected | Business Purposes | Disclosed To |
|---|---|---|---|
| Identifiers (name, email, phone, IP address) | Yes | Account management, service provision, marketing | Service providers, affiliates, advertising partners |
| Customer Records (billing info, payment data) | Yes | Payment processing, account management | Payment processors, service providers |
| Commercial Information (purchase history, preferences) | Yes | Service improvement, marketing, analytics | Service providers, analytics partners |
| Internet Activity (browsing, platform usage) | Yes | Platform optimization, security, analytics | Service providers, analytics partners |
| Geolocation Data | Yes | Service personalization, security | Service providers |
| Audio/Visual (call recordings, uploaded content) | Yes | Service provision, quality assurance | Service providers |
| Professional Information (business details, industry) | Yes | Service customization, marketing | Service providers, affiliates |
| Inferences (preferences, characteristics) | Yes | Personalization, marketing, service improvement | Service providers, advertising partners |
Empowered Homefront does not sell your Personal Information for monetary compensation. If you wish to exercise your right to opt-out of Empowered Homefront using your Personal Information for cross-contextual targeted advertising purposes (called "sharing" under the CCPA), you may do so by using the details in the "Contact Information" section below.
You can request access to, correction of or deletion of your Personal Information by using the details in the "Contact Information" section. If you request a deletion of your Personal Information, please note that Empowered Homefront may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CCPA.
You can designate an authorized agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, Empowered Homefront may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CCPA.
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:
Your continued use of our services after changes become effective constitutes acceptance of the updated Privacy Policy.
For Privacy Questions and Requests:
General Inquiries:
True Offers USA, LLC d/b/a Empowered Homefront
ATTN: Legal & Compliance Department
931-E South Main St STE 246
Kernersville, NC 27284
Email: [email protected]
Customer Support:
[email protected]
For DPF-Related Complaints:
If you have complaints regarding our handling of personal data under the Data Privacy Framework, contact us first at [email protected]. For unresolved complaints, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) for free dispute resolution. Under certain conditions, binding arbitration may be available.
Virginia residents have the right to:
Appeals Process: If we decline your request, you may appeal by contacting [email protected] within a reasonable time after receiving our response.
Colorado residents have similar rights to Virginia residents, plus:
Appeals: Contact [email protected] if we decline your request.
Connecticut residents have the same rights as Virginia and Colorado residents.
Appeals: Available for declined requests through [email protected].
Utah residents have rights to:
We collect data about your learning progress, course completions, and educational preferences across all Empowered Homefront micro suites to provide personalized learning experiences and track certification requirements.
Customer Data: Information you upload about your customers is processed to provide CRM functionality, automation services, and analytics.
Communication Tracking: We track email opens, SMS delivery, call connections, and other communication metrics to provide service analytics.
TCPA Compliance: You are responsible for ensuring compliance with all applicable laws when using our communication tools.
When you participate in our Skool communities or other community platforms, your posts, comments, and interactions may be visible to other community members. We collect community engagement data to improve the experience and moderate content.
We collect and process payment information, subscription preferences, and usage data to manage your memberships and provide access to premium content and services.
AI Content Generation: Our platform may use AI to help generate marketing content, educational materials, and communication templates. You retain ownership of content you create using these tools.
No Automated Decisions: We do not use automated decision-making that produces legal or similarly significant effects without human involvement.
AI Training: We do NOT use your Personal Information to develop, improve, or train generalized AI or machine learning models.
Transparency: When AI tools are used, we provide clear indication of their involvement in content generation.
We do not collect, store, or process biometric information such as fingerprints, facial recognition data, or voice prints.
We limit our collection and use of sensitive Personal Information to:
Categories of Sensitive Information We May Collect:
Transfer Mechanisms:
Safeguards: All international transfers include appropriate technical and organizational measures to protect your Personal Information.
Our Commitment: We will notify affected individuals and relevant authorities of data breaches as required by applicable law.
Notification Timeline:
Information Provided: Nature of breach, categories of data involved, likely consequences, and measures taken to address the breach.
Due Diligence: We conduct security and privacy assessments of vendors who process Personal Information.
Contractual Requirements: Vendors must agree to appropriate data protection terms and security measures.
Monitoring: We regularly review vendor compliance with our data protection requirements.
Incident Response: Vendors must notify us immediately of any security incidents involving our data.
Documentation: We maintain records of our data processing activities as required by applicable privacy laws.
Regular Reviews: We conduct periodic assessments of our privacy practices and update procedures as needed.
Training: Our employees receive regular training on data protection requirements and best practices.
Compliance Monitoring: We monitor compliance with this Privacy Policy and applicable laws through regular audits and assessments.
Some browsers incorporate a "Do Not Track" ("DNT") feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, our platforms do not respond to DNT signals.
We are not responsible for the practices employed by websites or services linked to or from our platforms, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on Empowered Homefront's behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which our platforms link — the inclusion of a link on our platforms does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer — including any Personal Information you disclose to other organizations through or in connection with our platforms or other services.