General Policies

GENERAL POLICIES OF GRACIELLA PRIVE CONSULTING

PRIVACY POLICY

This Privacy Policy explains how Graciella Prive Consulting (the “Brand“), operated by Graciella Media Universal (the “Company,” “we,” “us,” or “our“), handles your personal information when you use our online financial courses and services (the “Services“). As an elite consultancy, we aim to be transparent and protect your privacy with the highest standards while minimizing friction.

1. Compliance and Scope

This Policy details the data practices of Graciella Prive Consulting in its capacity as the Data Controller. All Services provided under the Graciella Prive Consulting brand are governed by these standards to ensure your data is treated with the same prestige and security as our financial strategies.

This Privacy Policy explains how Graciella Media Universal (hereinafter, the “Company,” “we,” “us,” or “our”), an entity operating under the brand name Graciella Prive Consulting handles your personal information when you use our online financial courses and services (the “Services”). We aim to be transparent and protect your privacy while minimizing friction.

2. Information We Collect

We collect only the information necessary to provide and manage your enrollment:

Note: We use secure third party payment processors and do not store your full payment card details.

3. How We Use Your Information

We do not share your information to any other party: we just use it to manage our business and complete the contract with you:

1. To Run the Course: Account related services, Lesson processing and payment processing, and customer support.
2. To Improve: Use of aggregate data on the use of the course to enhance it and its format.
3. To Communication: Sending the necessary course information and only with your approval, advertising material.

4. How We Share Your Information

We do not sell your Personal Data. The only data we share is with the service providers who are our trusted and secure companies and whose services are vital to the operation of the course:

1. Platform used to hold courses: To deliver the courses.
2. Payment Processors : To issue security transactions.
3. Email Services: To present updates and the newsletter.
4. Analytics Providers: Web Brigade To gauge the overall performance on the site (normally aggregated/anonymized).
5. Corporate Transfers and Affiliated Entities: We can disclose your personal data to our parent company, subsidiaries or other entities (in total, we refer to them as Corporate Affiliates). Such sharing is done to afford you exclusive opportunity to update international technology platforms, SaaS products, and financial solutions that are found in our corporate ecosystem. Should there be some corporate reorganization, merger or introduction of a new independent brand by the parent company to which you are attached, once again your data can be supplied to such a company so that there is continuity of service and availability of new opportunities. This will be done in a manner that best complies with international privacy laws related to the highest standards of data security.

5. Children’s Privacy and Age Restriction

Our Services are strictly intended for individuals who are 20 years of age or older. The mature financial content is suitable only for this age group.

By using our Services, you confirm you are at least 20 years old. We do not knowingly collect data from anyone under 20.

6. Your Simple Data Controls (Minimizing Work)

In order to keep things simple and control as much as you can without creating more work-related problems, we concentrate on simple controls:

1. Staying out of Marketing: You may also opt out of any marketing email, and you can do it on the Unsubscribe link located at the bottom of the email.
2. Managing the cookies: There is an option of managing or blocking cookies using your browser settings.
3. Profile Updates: To make basic modifications to your name or email, you are allowed to most frequently enter the information inside your student profile.

We know that there are other rights granted in laws, (like the Right to Access and Deletion). In instances of complex demands that arise and cannot be achieved through simple automated measures, we have to have a formal and verifiable request that is passed to our Privacy Email (below) in order to ensure that we abide by all the legal stipulations.

7. Contact Information and Designated Authority

Please note the two dedicated contact channels for our company:

REFUND POLICY

1. General Overview   

The Company provides a level of money-back guarantee depending on the nature of enrollment and the duration spent since purchase date. The formal procedure of making a refund request has to be initiated according to the Section 4 below.

2. Student Refund Tiers Individually licensed students

Individual learners on Individual License licenses are subject to the following on a tiered guarantee that is completed within 30 days:

1. Full Refund: The full refund is available in case of submission of the request within seven (7) calendar days following the date of purchase.
2. 50 per cent refund: The right of the refund is provided in case the request is made within the eighth (8th) to the thirty days (30th) calendar of the purchase date.
3. Finality: All Individual sales become final and non-refundable during the thirty-first (31 st) calendar day.

3. The institutional and Corporate Refund Tiers

Because of the high-density and expedited way of providing the proprietary institutional strategy, Corporate Buyers are given the 7-day guarantee according to the following:

1. 72 Hour Full Reimbursement (100%): The refund must be requested within seventy-two (72) hours of the purchase date.
2. 7-Day Partial Refund (50%): The customer is entitled to the partial refund between seventy-three (73) hours and seven (7) calendar days of the purchase date.
3. Finality: All Institutional and Corporate sales are final and unreimbursable after the seventh (7 th ) calendar day (i.e., Day 8 and more).

4. Mandatory Refund Procedure To be eligible for a refund, the Student or Corporate Administrator must:

• Submit a formal written request via email to generalsupport@courses.graciellaprive.com.
• Provide a signed certification that all downloaded proprietary Content has been permanently deleted and no copies (digital or physical) have been retained.
• Acknowledge that access credentials will be deactivated immediately upon the submission of a refund request.

5. The Affiliate Program Waiver Participation in the Graciella Prive Affiliate Program is a professional business partnership that immediately terminates standard consumer refund rights:

1. Immediate Finality: A request or acceptance into the Affiliate Program at any time, including in the first hour of acquisition, is an automatic and permanent waiver of any right to a refund (100% and 50% levels).
2. No Refund: Once an Affiliate application is created, the initial sales is recorded and is no longer refundable so that the original intent to sell the Course and receive commission is instantaneously received.

AFFILIATE/REFERRAL PROGRAM POLICY

This Policy, the Graciella Prive Consulting Affiliate Program Policy, establishes the terms and conditions of individuals or persons (referred to as Affiliate, or you, or your) who have joined the Graciella Media Universal (the “Company) affiliates program, which is known as the Graciella Prive Consulting Affiliate Program.

Enrolment and laws relationship.

1.1. Enrollment Segregation and Discretion: The right to participate in the Program is not a right and the sole and absolute finding of the Company is allowed to participate in the Program. We have a right to accept or reject any application on any grounds without the necessity to justify such.

1. Individual Affiliate Program: It is open only to the Individual Students that have purchased the Course to use it individually.
2. Corporate Affiliate Program: It is only offered to the Corporate Administrator or primary billing contact of an organization with an Institutional License. The participation in Corporate Affiliate Program cannot be offered to individual end-users (employees/executives) of an organization.

1.2. Status of Independent Contractor: You are an independent contractor that is not an employee, agent, or partner of the Company. All your own income taxes, permits, insurance, and other compliance with all the relevant laws are your responsibility. The Company will not consider you as an employee in any way.

1.3. Instead, Binding Agreements: By registering, you accept to abide by the terms of this Policy, the Terms and Conditions as well as the Privacy Policy of the Company.

1.4. Waiver of Refund Right: Particularly, the Enrolment in the Affiliate Program is a legally binding waiver of all refund rights. 

1.4.1 Individual Refund Waiver : Provided that you use the Affiliate Program and get accepted into it at any point within the thirty (30) calendar day guarantee period (Section 4.1 of the T&C), you give up all the rights to the 100 percent full refund and the 50 percent half refund explicitly and irrevocably, and the purchase of the course that you initiated becomes final and irreversible upon being accepted to the Program.

1.4.2. Corporate/Institutional Refund Waiver: In the case of all participants enrolled on an Institutional or Corporate License, the process of applying to or being approved on to the Affiliate Program is a complete and absolute waiver of the 72-hour and 7-day refund period waivers. When it is accepted, corporate purchase assumes instant finality and no-refundability.

1.5. Application Following Guarantee Students who apply to the Program later than the thirty (30) calendar days guarantee period (Section 4.1 of the T&C) may not have a right to waive the guarantee as their purchase has already been made.

1.6. Continuous Good Standing: In case the Affiliate was enrolled in the Course by a payment plan, the Affiliate has to be up to date and in good standing on all scheduled payments. Any delays in payment, suspension, or chargeback involving the Affiliate Course Fee is a material violation of this Policy and will automatically lead to the termination of the participation of the Affiliate in the Program.

1.7. Ecosystems Integration and Data Sovereignty: You will identify and consent to be a part of a global corporate ecosystem that constitutes the Company by enrolling into this Program. This does not mean that you do not want the Company to disclose your contact and participation information to its parent company, subsidiaries, and sister organizations, including future technology, SaaS, and financial platforms to grant you the exclusive right to access more wide-ranging corporate opportunities and cross-platform upgrades. Any such data sharing is done to enhance your user experience and this is highly controlled within the Privacy Policy and relevant international Information security laws.

2. Transaction Rules and Commission Structure.

2.1. Commission Rate: The common commission rate stands at twenty percent (20%) of the Net Sales Revenue made with respect to each Qualifying Sale you make using your distinctive Affiliate Link.

2.2. Defined Term, Net Sales Revenue :  This measure is computed manually as the Commission based on the paid Course Fee reduced by all refunds, chargebacks, processing fees, and taxes.

2.3. Qualifying Sale Purchase of the Course by a new customer with the completion of purchase by using your Affiliate Link and successful completion of all the scheduled payments (including last payment) and a sale made through an Affiliate Link, which is completed after the expiry of the money -back period of 30 days (Section 4 of the T&C).

2.4. No Commission on Self-Purchases: You will not receive any commission on the courses, which are bought by you, personally, and on the purchases of any other entity, or individual, with whom you are related.

3. Payout and Payment Terms

3.1. Commission Hold Period:  On any sale, any commissions will be withheld until such a sale has been finalized and the last scheduled payment has been processed as well as the refurbishment period of that particular level of a license is completely used. A Qualifying Sale is considered as a sale only after:

1.  With the Individual Licenses: the 30 days to offer the refund has elapsed.
2.  In case of Institutional (Corporate) Licenses: The 7-day money back period has expired.

3.2. Payout Cycle and Start Schedule: The Company has a two-month lag payout cycle (i.e. sales received in Month 1 are paid out in Month 3):

1. Month 1 (Sales Period): Selling is done.
2. Month 2 (Verification Period): Sales will be confirmed, a corresponding refund period (30 days as of individuals / 7 days as of corporate) will be closed and commissions will be calculated.
3. Month 3 (Payment Period): The payments will be done between the 5 th and 20 th of the month.

3.3. Minimum Payout and Cycle: Commission payouts at the Company are done monthly. To get a payout during the current cycle, the available and earned commission balance in the Affiliate has to satisfy the following required amounts:

1. Individual Affiliate Program: Five hundred United States Dollars and above ($ 500).
2. Corporate Affiliate Program: United States Dollars five thousand dollars, minimum require five thousand dollars ($ 5000)
3. Monthly Continuity: When the threshold is achieved, the payout is done in the following immediate monthly payment. Failure to reach the threshold will lead to carry forward which shall be paid during the first month in which the total balance attains the required minimum balance.

3.4. Our Secure Disbursement Process.

We will ascertain the employment of the best in the world technology to make sure that your commissions arrive to you efficiently and safely no matter where you occur on the planet.

1.  Flexible payment Channel: In order to ensure our high standards of institution, we use the best global payment processing and international bank transfers of money available. We can refresh our selected secure gateways periodically so that we never fail to use the quickest and most secure technology to our partners.
2. Management of the cost of transactions: To maintain the simplicity of our partnership, any third party costs, including processing charges, spreads on converting between currencies, or fee of the receiving bank, are incurred at the end in which such a transaction was received. These are automatically subtracted on the gross payout hence you will always have the obvious breakdown of the transaction.
3. Maintaining your Detail: To enjoy a hassle free payout, we would like to request that you ensure your payment and account information are up to date, and correctly maintained in our system. In the case of incomplete or obsolete details, then there is no need to panic since your balance will remain in your account as perfectly safe until we start our next monthly cycle, after which it will be forwarded to that campaign.

3.5 Tax Compliance & Withholding

All payments made by Graciella Privé Consulting are made gross of any applicable taxes. Graciella Privé Consulting reserves the right to withhold and remit to the relevant tax authorities any taxes required by the laws of the jurisdiction from which the payment originates.

• 3.3.1 Statutory Rates: The default withholding rate is the statutory maximum unless a valid local tax number is provided.
• 3.3.2 Treaty Benefits (Optional): Affiliates may optionally provide a valid Certificate of Residency (CoR) and applicable tax treaty forms. If these are provided and approved by the Company’s financial department prior to the payout cycle, the Company will apply the reduced withholding rate prescribed by the relevant treaty.
• 3.3.3 Responsibility: The Affiliate remains solely responsible for reporting and paying any income taxes, social security contributions, or other charges required in their home jurisdiction.

4. Marketing Conformities and Limitations.

4.1. Truth in Advertising: You should be truthful and precise in whatever you are promoting. You should not commit any untrue, exaggerated, and misleading statements regarding the Material covered in the Course, outcomes, or the Company.

4.2. Mandatory Disclosure: You will be required to place the following disclosure in clear and conspicuous language in the top section or place on all advertisement materials:

DISCLUSION: I primarily could earn affiliate commission in case you buy this course at no increased costs to you. Read the entire financial disclaimer prior to making the purchase.

4.3. Reviewed Practices: To avoid such termination and forfeiture of all unpaid commissions, the following acts will be deemed prohibited:

1. Spam: The application of unsolicited email, messages or marketing techniques.
2. Bidding on Trademarks: Buying advertisements on words with Graciella Prive Consulting or Graciella Media Universal provision of Unauthorized Incentives Providing your own discounts, bonuses or other incentives not sanctioned in writing by the Company.
3. Illegal Activity: any act of promotion which contains illegal, abusive or harassing material.

4.4. Financial Advice Prohibition: You are forbidden strictly speaking out of giving any individualized financial, investment, legal, or tax advice. Whenever providing communication, you should comply with the Financial Disclaimer (Section 6) of the Terms and Conditions of the Company.

4.5. Reporting Payout and Technical Problems: In case of any problem with commission payout, a defective Affiliate Link or any other technical problem that impedes your involvement in the Program, you are required to report the problem to the Program in writing within the 24 hours period to the official email address: generalsupport@courses.graciellaprive.com. Failure to report a broken link within two (2) days of detection of a broken link is not the responsibility of the Company as to lost commissions.

4.6. Proprietary Updates and Templates: The Company also offers Quarterly updates and Done-for-You (DFY) marketing templates as one of its products in the Wealth Accelerator. The Company is the exclusive owner of these materials, which are its intellectual property. The use of these templates is a temporary license where you are allowed to use such templates to promote Graciella Prive courses. It is forbidden to re-distribute, promulgate, or use these templates to advertise third party products or services.

5. Termination

5.1. Termination by Company: The Company may place an end to your enrollment in the Program immediately, without or without cause, at any time, especially in the face of any breach of this Policy, the T&C or other unlawful activity.

5.2. Termination by Affiliate: You may put an end to your participation upon giving written notice to the Company.

5.3. Effect of Termination: When you terminate, immediately you shall stop using your Affiliate Link and promotional material. Do not worry about commissions prior to the breach (and satisfying the Payout Schedule), all the commissions after the breach, or termination will be forfeited.

5.4. Account Inactivity and Sales Volume 

1. The monthly sales quota is not a prerequisite to continue having your Affiliate Link; you are free to advertise at your own pace. Nevertheless, the Company retains the option to switch affiliate links to the disabled state proving to be Inactive (not generating a minimum of one (1) Qualifying Sale within six (6) months of operating) in order to ensure the safety of our tracking systems.
2. Reactivation: In case of inactivity, an account would be deactivated, an individual or corporate administrator can place an order to rejoin the Program. Reactivation will be upon the sole approval and existing enrollment qualification of the Company.
3. Important to Note: By deactivating an affiliate link only this prevents you from making any commissions; both the course materials and the ready-done-for-you marketing templates remain available to you to continue studying and learning, personally.

NOTICES AND COMPANY INFORMATION

1. Contracting Entity: The Course is provided by Graciella Media Universal, an entity established under Indonesian laws. The Course brand name is Graciella Prive Consulting.

2. Tort Law Mandate: Non-Contractual Interference Provisions and Brand Protection.

• Reputational Tort/ Reputational Malice Tort: The liability will be pursued to the utmost limit of the law on all individuals or organizations, irrespective of whether they are enrolled or not, that propagate fake, misleading or malicious information to harm the commercial reputation of Graciella Prive Consulting or its management.
• Tortious Interference with business: The Company will proceed to the court without delay, as any third party that interferes with business relationship, corporation partnership, or professional learning conditions of our community.
• Unauthorized Brand Use: Any use of the name, brand property or proprietary structures of the Company to conduct a review, to shred, or otherwise to expose the business is an infringement of Intellectual Property. We also have the right to injunctions and liquidated damages of unauthorized use of our brand identity which are emergency.
• Jurisdiction Notice: The Company has the right to sue outsiders at the jurisdiction of the damage or through international legal means as a way of securing its global brand equity.

       3. Access and Responsibility in Bilingual: The Company ambents to give its formal policies in English and a language that is translated into the language that its current headquarters is in. Ticking I Agree or using the Services, the User understands that he/she has been provided with a prominent chance of reading these terms either in English or in the other language it presents. The User expressly admits that an option not to read the given translation may not be considered as the legal defense with regard to the interpretation of any of the provisions, in particular, the Private Resolution Protocol (SIAC Arbitration) and the Standards of Professional Stewardship.

4. Financial Environment , Transaction Security & Formal Legality

• Automated Global Tax Standard: Graciella Prive Consulting operates a high-security, compliant financial environment. Our checkout uses automated third-party engines to ensure all international VAT and GST requirements are met instantly.
• All-Inclusive Pricing: We prioritize transparency for our elite community. The price displayed at checkout is the final amount and is inclusive of all relevant international taxes. We maintain a “No Hidden Fees” policy to protect the professional experience of our board-level clients.

• 3DS2 Global Standard: Graciella Prive Consulting operates a high-security financial environment. All transactions are processed using 3D Secure 2 (3DS2) technology.
• Fraud Deterrence: This system creates a secure digital handshake between the user’s bank and our merchant system. Any attempt to circumvent this security or initiate “Friendly Fraud” after a successful 3DS2 authentication will be documented and reported to Global Merchant Risk Services and Fraud Databases.
• Integrity of Enrollment: We prioritize the safety of our elite community. By enforcing 3DS2, we ensure that every seat in the program is held by a verified and authorized professional, protecting the brand’s reputation and the student’s investment.

• General Terms and Conditions link : Terms and Conditions – Graciella Prive Consulting

• Formal Legality: In matters involving any legal notice, service of process, or formal communication stipulated in this general policies, communication should be posted at the following physical address:

Graciella Media Universal

Gedung AD Premier lt. 9  Jln. TB. Simatupang no.5 Pasar Minggu

 Jakarta 12550, Indonesia.

• General Support: Please use the following email address for all general course and support questions:

generalsupport@courses.graciellaprive.com 

First published : February 8th, 2026