Privacy Policy

Last Updated: September 12, 2026



White Passage is operated by Minieri & Company LLC (“White Passage,” “we,” “us,” or “our”).

This Privacy Policy explains how we may collect, use, disclose, and protect information when you visit WhitePassage.com, communicate with us, purchase products or services, subscribe to communications, complete forms or assessments, participate in programs, or otherwise interact with White Passage (collectively, the “Services”).

By using the Services, you acknowledge the practices described in this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use the Services.


1. INFORMATION WE COLLECT

We may collect information that you provide directly to us, information collected automatically when you use the website, and information necessary to provide products or services you request.

Information You Provide

Depending on how you interact with White Passage, you may provide information such as:

  • Name
  • Email address
  • Telephone number
  • Mailing or billing address
  • Business or professional information
  • Communication preferences
  • Information submitted through forms, questionnaires, assessments, applications, or contact requests
  • Information you provide when communicating with us
  • Purchase and transaction information
  • Testimonials, feedback, or other content you voluntarily submit

Personal Information You Choose to Share

White Passage addresses topics involving significant life disruption, including betrayal, trauma, career collapse, identity crisis, faith, purpose, relationships, health-related disruption, and other difficult personal experiences.

As a result, you may voluntarily provide information of a personal or sensitive nature when completing forms or communicating with us.

We ask that you only provide information that is reasonably necessary for the purpose of your communication.

When you voluntarily provide sensitive information, we will use it only as reasonably necessary to respond to your request, provide the Services you requested, maintain appropriate records, comply with legal obligations, or for another purpose disclosed to you at the time of collection.

Payment Information

If you purchase a product or service, payment information may be processed by third-party payment processors such as Stripe.

We generally do not store complete credit card numbers or payment security codes on our own systems.

Payment processors handle payment information according to their own privacy policies and security practices.

Information Collected Automatically

When you visit WhitePassage.com, certain technical information may be collected automatically, including:

  • Internet Protocol (IP) address
  • Browser type
  • Device type
  • Operating system
  • Referring website or source
  • Pages viewed
  • Dates and times of visits
  • Website interactions
  • General geographic location derived from IP address
  • Diagnostic, performance, and usage information

This information may be used to operate the website, understand usage, maintain security, troubleshoot problems, and improve our Services.


2. COOKIES AND SIMILAR TECHNOLOGIES

WhitePassage.com may use cookies, pixels, analytics tools, and similar technologies to operate the website, remember preferences, understand how visitors use the website, measure marketing effectiveness, and improve our Services.

Your browser may allow you to block or delete cookies. Doing so may affect certain website features.

Where applicable law requires consent or provides additional rights regarding cookies or advertising technologies, we will provide appropriate choices.


3. HOW WE USE INFORMATION

We may use personal information to:

  • Provide White Passage products, services, resources, or programs
  • Respond to questions and requests
  • Process registrations, purchases, and payments
  • Deliver purchased or requested materials
  • Communicate with customers and prospective customers
  • Send administrative or service-related communications
  • Send newsletters, educational material, marketing, or promotional communications
  • Personalize or improve the user experience
  • Evaluate how our website and Services are being used
  • Improve our content, products, programs, and website
  • Maintain security and prevent fraud or misuse
  • Maintain business and financial records
  • Enforce our agreements and policies
  • Protect our rights and the rights of others
  • Comply with applicable laws and legal obligations

We may also use information for another purpose with your consent.


4. EMAIL AND MARKETING COMMUNICATIONS

If you subscribe to White Passage emails or otherwise request communications from us, we may send you educational material, articles, announcements, offers, resources, and other information related to White Passage or services offered by Minieri & Company LLC.

You may unsubscribe from marketing emails at any time by using the unsubscribe link included in the message.

Even if you unsubscribe from marketing communications, we may still send transactional or administrative communications when necessary, such as purchase confirmations, account information, requested materials, or communications relating to an existing service relationship.


5. HOW WE DISCLOSE INFORMATION

We do not disclose personal information simply because someone requests it.

We may disclose information when reasonably necessary to operate our business or provide the Services.

This may include disclosures to:

Service Providers

We may use third-party companies to perform services on our behalf, including:

  • Website hosting
  • Email delivery
  • Customer relationship management
  • Payment processing
  • Scheduling
  • Analytics
  • Advertising and marketing technology
  • Data storage
  • Technical support
  • Professional services

These providers may receive information necessary to perform their services.

Legal and Safety Reasons

We may disclose information if we reasonably believe disclosure is necessary to:

  • Comply with applicable law
  • Respond to a lawful subpoena, court order, or governmental request
  • Protect the rights, property, or safety of Minieri & Company LLC, White Passage, our users, or others
  • Investigate suspected fraud, abuse, security threats, or illegal activity
  • Enforce agreements or policies

Business Transfers

Information may be transferred as part of a merger, acquisition, financing transaction, sale of assets, restructuring, or similar business transaction involving Minieri & Company LLC or White Passage.

Professional Advisors

Information may be disclosed when reasonably necessary to attorneys, accountants, insurers, consultants, or other professional advisors.


6. SALE OF PERSONAL INFORMATION

We do not sell personal information for money in the ordinary course of our business.

Certain privacy laws may define terms such as “sale,” “sharing,” or targeted advertising more broadly than ordinary usage.

If applicable law gives you the right to opt out of particular uses or disclosures of your information, we will honor those rights as required by law.


7. HOW LONG WE KEEP INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing Services, maintaining appropriate business records, resolving disputes, enforcing agreements, and complying with legal, accounting, tax, and regulatory obligations.

Retention periods may vary depending on the type of information and the reason it was collected.

When information is no longer reasonably necessary, we may delete, anonymize, or securely archive it as appropriate.


8. HOW WE PROTECT INFORMATION

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information.

However, no method of transmitting information over the Internet or storing information electronically can be guaranteed to be completely secure.

You provide information through online services at your own risk.


9. CHILDREN'S PRIVACY

White Passage is intended for adults and is not directed toward children under the age of 18.

We do not knowingly solicit or collect personal information from children under 18.

If we learn that we have collected personal information from a child under 18 without appropriate authorization, we will take reasonable steps to delete it.


10. YOUR PRIVACY RIGHTS

Depending on where you live, applicable privacy laws may give you certain rights regarding your personal information.

These rights may include the ability to:

  • Request access to personal information we maintain about you
  • Request correction of inaccurate information
  • Request deletion of certain personal information
  • Request information regarding how personal information has been used or disclosed
  • Withdraw consent where processing depends upon consent
  • Opt out of certain marketing communications
  • Opt out of certain forms of targeted advertising, sale, or sharing where applicable
  • Obtain a portable copy of certain information
  • Appeal certain privacy-rights decisions where applicable

These rights are not absolute and may be subject to legal exceptions.

We may need to verify your identity before fulfilling a request.

We will not unlawfully discriminate against you for exercising applicable privacy rights.


11. UNITED STATES PRIVACY RIGHTS

Residents of certain U.S. states may have additional rights under state privacy laws.

Depending on how you use the Services, categories of information we may collect can include:

Identifiers, such as name, email address, telephone number, mailing address, account information, or IP address.

Commercial information, such as purchases, transactions, products, or services requested.

Internet or network activity, such as website usage, pages viewed, interactions, browser information, and referring sources.

Geolocation information, generally consisting of approximate location derived from IP address rather than precise GPS location unless a particular service specifically requires it.

Professional or employment-related information, when voluntarily submitted.

Communications and submitted content, including information contained in forms, emails, questionnaires, assessments, or other correspondence.

Sensitive personal information, when voluntarily provided by a user in connection with a request or White Passage service.

We use these categories for the purposes described in this Privacy Policy.


12. DO-NOT-TRACK AND PRIVACY PREFERENCE SIGNALS

Some browsers offer “Do Not Track” settings. Because there is not currently a single universally accepted standard governing how websites must respond to all Do Not Track signals, our website may not respond to those signals in every circumstance.

Where applicable law requires recognition of legally recognized browser-based privacy preference signals, we will respond as required.


13. THIRD-PARTY WEBSITES AND SERVICES

WhitePassage.com may contain links to websites, platforms, payment processors, scheduling systems, social media services, or other third-party services that we do not control.

This Privacy Policy does not govern those third parties.

We encourage you to review the privacy policies of any third-party service you choose to use.


14. INTERNATIONAL VISITORS

White Passage and Minieri & Company LLC are operated from the United States.

If you access the Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or other jurisdictions where our service providers operate.

Privacy and data protection laws in those jurisdictions may differ from the laws where you live.


15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our Services, business practices, technology, or legal requirements.

When we make changes, we will update the “Last Updated” date at the top of this page.

Material changes may also be communicated through the website or by another appropriate method.


16. CONTACT US

White Passage is operated by:

Minieri & Company LLC
1150 Hungryneck Blvd, Suite C122
Mt. Pleasant, SC 29464
United States

Privacy inquiries may be sent to:

support@minieri.com


17. REQUESTING ACCESS, CORRECTION, OR DELETION

To request access to, correction of, or deletion of personal information we maintain about you, or to exercise another privacy right available under applicable law, contact us using the information above.

Please provide enough information for us to understand and reasonably verify your request.