LEGAL & PRIVACY

Privacy Policy

Effective date: August 22, 2026

This Privacy Policy explains how ONUL (“ONUL,” “we,” “us,” or “our”) collects, uses, discloses, and protects information when you visit onul.ai, submit information through our forms, communicate with us, use our services, or otherwise interact with us.

SECTION 1

Ownership and Corporate Relationship

ONUL is a brand and operating asset owned and controlled by The Whittaker Group LLC. References in this Privacy Policy to “Whittaker Group” include The Whittaker Group LLC and businesses, brands, subsidiaries, or affiliates that it owns or controls. We may share information within the Whittaker Group as described below when reasonably necessary to operate our businesses, respond to your request, provide or improve services, follow up with you, or identify products or services that may be relevant to your stated interests.

The Whittaker Group may operate multiple businesses and brands. This Privacy Policy does not require us to identify each affiliated business by name. Information shared within the Whittaker Group remains subject to applicable law and the privacy and security obligations described in this Policy.

SECTION 2

Information We May Collect

Depending on how you interact with us, we may collect the following categories of information:

  • Identifiers and contact information, such as your name, mailing address, email address, telephone number, business name, and similar information.
  • Information you provide in forms, questionnaires, surveys, applications, appointment requests, secure uploads, or communications with us.
  • Business and professional information, such as industry, company size, job role, current systems, business needs, service interests, or operational information.
  • Transaction and service information, including services requested, appointments, account activity, billing status, and communications history.
  • Internet and device information, such as IP address, browser type, device identifiers, pages viewed, referring URLs, approximate location derived from IP address, and website interaction data.
  • Communication preferences and marketing engagement, such as email opens, link clicks, form submissions, SMS preferences, and appointment responses.
  • Any other information you voluntarily provide to us.

Please do not submit highly sensitive personal information unless it is reasonably necessary for the service you are requesting and the collection method is intended for that purpose.

SECTION 3

How We Collect Information

  • Directly from you when you complete a form, request information, schedule an appointment, upload documents, make a purchase, communicate with us, or otherwise provide information.
  • Automatically through cookies, pixels, analytics tools, server logs, and similar technologies when you use the website.
  • From service providers, marketing platforms, referral sources, advertising platforms, publicly available sources, and other lawful sources.
  • From other businesses, brands, subsidiaries, or affiliates within the Whittaker Group when permitted by law and relevant to your interaction with us.

SECTION 4

How We Use Information

  • Respond to inquiries and provide requested information or services.
  • Create and manage customer, prospect, or business records.
  • Schedule and administer appointments and consultations.
  • Provide customer service and ongoing support.
  • Operate, maintain, secure, troubleshoot, and improve our websites, systems, services, and user experience.
  • Personalize communications and determine which services, educational resources, or offers may be relevant to you.
  • Send service-related communications and, where permitted, marketing communications.
  • Measure advertising and marketing effectiveness and understand how visitors use our website.
  • Prevent fraud, misuse, security incidents, and other harmful or unlawful activity.
  • Comply with legal, regulatory, licensing, recordkeeping, tax, accounting, or other lawful obligations.
  • Establish, exercise, or defend legal claims and protect our rights and the rights of others.

SECTION 5

Sharing Within The Whittaker Group

We may share personal information among businesses, brands, subsidiaries, and affiliates owned or controlled by The Whittaker Group LLC. This internal sharing may be used to respond to your request, coordinate services, provide customer support, conduct internal administration, perform marketing and follow-up, evaluate whether another Whittaker Group service may be relevant to your needs, or otherwise operate the Whittaker Group businesses.

For example, information submitted through one Whittaker Group brand may be made available to another Whittaker Group business when that business is better positioned to respond to the consumer’s request or provide a relevant service. We do not require consumers to know or select the specific Whittaker Group entity that may ultimately assist them at the time information is first submitted.

SECTION 6

Other Disclosures of Information

We may also disclose information to the following categories of recipients when appropriate:

  • Service providers and vendors that support hosting, CRM, communications, scheduling, payment processing, document storage, analytics, advertising, cybersecurity, customer support, automation, and other business functions.
  • Professional advisors, such as attorneys, accountants, auditors, compliance professionals, consultants, or insurers.
  • Government agencies, regulators, courts, law enforcement, or other parties when disclosure is required or permitted by law.
  • A buyer, successor, lender, investor, or other party involved in an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, subject to applicable confidentiality and legal requirements.
  • Other parties when you direct us to share information or provide consent.

SECTION 7

We Do Not Sell Personal Information for Money

We do not sell personal information to third parties for monetary consideration. We also do not rent lists of personal information to unrelated third parties for their independent marketing use.

Some state privacy laws define “sale,” “sharing,” or “targeted advertising” more broadly than an ordinary sale for money. For example, certain disclosures involving advertising, analytics, cookies, or pixels may be treated as a regulated sale or sharing even when no money is exchanged. Where applicable law gives you the right to opt out of these activities, we will provide and honor the legally required opt-out method.

SECTION 8

Cookies, Analytics, and Advertising Technologies

We and our service providers may use cookies, pixels, tags, analytics tools, local storage, and similar technologies to operate the website, remember preferences, understand website usage, measure campaign performance, detect fraud, improve services, and support advertising. You may be able to control certain technologies through your browser settings, cookie controls, advertising-platform settings, or legally required privacy-choice mechanisms.

SECTION 9

Communications, Email, SMS, and Telephone

If you provide contact information, we may use it to respond to your inquiry and communicate about requested services. Where permitted by law and consistent with any consent you provide, we may also send promotional or informational communications by email, text message, or telephone. You may opt out of marketing emails by using the unsubscribe mechanism in the message. You may opt out of marketing text messages by following the opt-out instructions provided in the message. Message and data rates may apply.

Consent to receive marketing communications is governed by the specific consent language presented at the point of collection and applicable law. This Privacy Policy itself does not create or replace any separate consent required for automated calls, text messages, or marketing communications.

SECTION 10

Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including providing services, maintaining business and customer records, complying with legal or regulatory obligations, resolving disputes, enforcing agreements, preventing fraud, and protecting our rights. Retention periods vary depending on the type of information and the context in which it was collected.

SECTION 11

Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No website, transmission method, or storage system can be guaranteed to be completely secure, and we cannot guarantee absolute security.

SECTION 12

Your Privacy Rights

Depending on where you live and applicable law, you may have rights concerning your personal information. These may include rights to request access to or confirmation of personal information we process, request correction or deletion, obtain a portable copy, opt out of certain targeted advertising, sale, or sharing activities, limit certain uses of sensitive personal information, appeal certain privacy-request decisions, or receive equal service without unlawful discrimination for exercising privacy rights.

To submit a privacy request, use the Contact page on onul.ai and identify the request as a “Privacy Request.” You may also submit your request through the Contact page on onul.ai and identify it as a “Privacy Request.â€� We may need to verify your identity before completing certain requests. Authorized agents may submit requests where permitted by law, subject to appropriate verification.

SECTION 13

State-Specific Privacy Choices

If applicable state law requires an opt-out mechanism for targeted advertising, sale, or sharing of personal information, we will make the required privacy-choice method available. Where applicable law requires recognition of legally valid browser-based opt-out preference signals, we will process such signals as required.

Because state privacy laws and applicability thresholds vary, a right described in this section may not apply to every visitor or every type of information. We will evaluate requests under the law that applies to the requester and the information at issue.

SECTION 14

Children’s Privacy

This website is intended for adults and business users and is not directed to children under 13. We do not knowingly collect personal information from children under 13 through this website. If you believe a child has provided personal information to us, please contact us so we can evaluate and address the matter.

SECTION 15

Third-Party Websites and Services

Our website may link to third-party websites, platforms, payment providers, scheduling services, social networks, or other services. Their privacy practices are governed by their own policies, and we are not responsible for their privacy practices except as required by law.

SECTION 16

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, services, or legal requirements. The “Effective date” above indicates when this version became effective. Material changes will be communicated as required by applicable law.

SECTION 17

Contact Us

For questions about this Privacy Policy or to submit a privacy request, use the Contact page at onul.ai and identify your message as a “Privacy Request,”