Counsel Engagement Note

Blue Book, Core Legal Package, Part A

Plain summary (for Emperor Livingstone)

This file tells 이성재 when to hire a real lawyer, which two tracks to buy, what to send, what to ask, and what leftover risk remains if the Practice launches on these drafts alone. The stop rule on ads and collection is still on. This stop rule may be lifted only when counsel is actually hired, or Napoleon or Emperor Livingstone signs a dated note that they accept the leftover risk after seeing a written quote. Korean counsel comes first because the operator lives in Seoul. US counsel is required before any US person is marketed to or sold to. UK and EU stay out. This Note is not a retainer and not licensed legal advice. A verbal "we will get a lawyer later" is not enough.

1. Purpose

1.1. This Note tells the founder when a licensed lawyer is required, which two tracks to buy, what to send, what to ask, how to choose (without naming a firm), how to sequence spend on a small budget, and what leftover risk remains if the Practice launches on domain drafts alone.

1.2. Do not collect client data and do not advertise until an engagement exists on the required track(s), or until Napoleon/Emperor Livingstone accepts the leftover risk in a dated writing after a written counsel quote. Document 01 (Sign-off Certificate) stays in force. Collection is under a stop rule. Do not collect names, emails, or sleep answers.

1.3. This Note is not a retainer. It is not a conflict check. It does not create an attorney-client relationship.

2. Why two counsel tracks are required before real-world use

2.1. The operator lives in Seoul. The offer is English-only and fully online. Clients may be anywhere the Practice does not exclude. That split creates two legal surfaces, not one.

2.2. Track 1. Korean counsel (operator-location track). Required before any real-world use, because the natural person who would act, speak, advertise, and hold data is in the Republic of Korea.

2.3. Track 2. United States counsel (claims-and-audience track). Required before any marketing to or sale to a US person, and strongly advised before any English-language health-adjacent page is reachable from the United States (which an open web page is, unless geo-blocked).

2.4. Other countries are not a third "do it yourself" track. UK and EU remain default-excluded until a GDPR + CAP (or equivalent) claims set exists. If a later market is opened, add a track. Do not treat "English-only" as worldwide clearance.

2.5. One bilingual lawyer can cover both tracks only if that person is actually licensed (or formally collaborating with licensed counsel) in each relevant system. A Korean lawyer commenting on FTC practice (the US Federal Trade Commission, which polices unfair or deceptive ads), or a US lawyer commenting on 의료법, is not a substitute unless they say in writing that they are qualified or are bringing in local counsel.

3. Track 1. Korean counsel (required first)

3.1. Why this track is first

The founder is a Seoul resident. He has a separate Korean sole proprietorship named Intelligent Solutions for software development and AI consulting. Sleep coaching must not use that registration. Default operating assumption is 이성재 as a natural person until a separate, correctly coded sleep registration exists. Korean regulators and tax authorities look at the person and the place of management, not at the language of the sales page.

3.2. Scope to buy (minimum)

1. Medical Service Act (의료법, the Korean law on who may practice and advertise medicine). Unlicensed medical practice. Unlicensed medical advertising. Whether Behavioral Sleep Improvement Coaching, as scoped in document 04, stays on the coaching/education side of the line. White-coat, "clinical," "treatment," "patient," and diagnostic-tool risk.
2. Personal Information Protection Act (PIPA / 개인정보 보호법, the Korean personal-information law). The Practice, if it later collects, will be a controller located in Seoul. Sleep-symptom and red-flag answers are sensitive information (health-related). Separate consent design. Cross-border transfer if any US or other vendor is used. Retention and deletion. No collection until this track is honest.
3. Act on Fair Labeling and Advertising (표시·광고의 공정화에 관한 법률, the Korean truth-in-ads law) and Monopoly Regulation and Fair Trade Act as KFTC backdrop (Korea's competition and unfair-trade law). Outcome claims, before/after, scarcity, testimonials, "guaranteed sleep."
4. Act on Consumer Protection in Electronic Commerce (전자상거래법, Korea's online-consumer law). Residual: this Act may still apply to English-only, fully online sales by a Seoul operator. Cooling-off, required disclosures, and withdrawal rights must be asked, not assumed away.
5. Tax. Individual worldwide income if the founder remains a Korean tax resident. VAT if and when registration thresholds or foreign supplies arise. Interaction with any later US LLC (document 03).

3.3. What Korean counsel is not being asked to do in the first engagement

• Pick a brand name.
• Decide an incorporation venue or form a new business without a dated Emperor writing (forbidden; see document 03). Do not put sleep on the Intelligent Solutions registration.
• Draft US FTC copy as if they were US counsel.
• Approve a HIPAA program (HIPAA is the main US health-privacy law; the Practice is not a covered entity by default).

4. Track 2. United States counsel (required before US persons are in scope)

4.1. Why this track exists

English-language health-adjacent coaching sold on the open web is, in practice, visible to US persons. FTC Act §5 unfair/deceptive practice authority does not need a US entity. State unlicensed practice of medicine (UPL) varies by state and is fact-specific. Some states also regulate "health coaches" or similar titles.

4.2. Scope to buy (minimum)

1. FTC Act §5. Deceptive or unfair acts. Net impression of the sales page, ads, and calls, not the footer.
2. FTC Health Products Compliance Guidance and advertising substantiation. Competent and reliable scientific evidence for health-related claims. The Practice may make lifestyle and process claims only if they are true and not implied medical claims.
3. FTC Endorsement Guides. Testimonials, "results," typical-results language, material connections, and employee/affiliate disclosure.
4. Consumer Review Fairness Act. No contract clause that bans honest reviews.
5. State unlicensed practice of medicine (varies). Coaching versus practice of medicine. Do not claim a uniform fifty-state clearance.
6. Possible state coaching statutes or registration. Ask counsel whether any target state requires a coaching registration, a health-coach title rule, or a telehealth-adjacent rule.

4.3. HIPAA instruction to US counsel

Ask counsel to confirm, in writing, whether the Practice is a covered entity or business associate on the facts. Default position of this Blue Book: no. Do not sell "HIPAA compliant coaching." If a future BAA with a US covered entity appears, reopen.

5. What to send counsel (the briefing pack)

Send the same pack to both tracks. Do not send a marketing-only summary. Counsel needs the constraints, not the dream.

5.1. Required attachments

1. This Blue Book, Part A (documents 01 through 06), watermarked DOMAIN-DRAFT.
2. Sibling files 07 through 25 when they exist. If they do not exist, say so.
3. This Note, with the scoping questions in clause 7 answered as far as facts allow.
4. A one-page fact sheet that does not invent a brand name:

The Practice is the Coaching Practice operated by 이성재, a natural person in Seoul, Republic of Korea. Intelligent Solutions is a separate software and AI consulting registration and is not this Practice. Business: Behavioral Sleep Improvement Coaching only. Three allowed actions: (1) verified, research-backed sleep information; (2) a program that fits lifestyle and needs; (3) daily-habit accountability. Fully online. English only. Solo/small. Limited money. No audience yet. High-ticket or hybrid. Client-paid. Adults 18+ only. No diagnosis, treatment, or cure claims. Red-flag screen, stop-sale, refer to a somnologist or licensed physician. No named-hospital kickback. Process/effort guarantees only. Honest scarcity only. PIPA-first. Default-exclude UK/EU. A Korean company, a US LLC, and a new sleep-coded registration are not chosen.

1. Any Hormozi-derived offer, ad, guarantee, scarcity, or testimonial draft that other teams have already written. Counsel must see the aggressive version, not a cleaned version.
2. A list of tools the Practice might use later (payment, calendar, email, video, analytics). Mark each as NOT IN USE if collection is still under a stop rule.
3. Geo intent: countries the founder wants to sell into in the first twelve months, and the default UK/EU exclusion.

5.2. How to label the pack

Subject or cover: "Domain drafts for mark-up. Not a request to bless a live launch. Collection and ads remain under a stop rule."

6. How to select counsel (do not name a firm)

6.1. Do not treat a generalist startup lawyer, a friend's corporate lawyer, or an incorporation mill as sufficient. Health-adjacent advertising plus privacy is a specialty pair.

6.2. Korean track selection criteria

1. Demonstrated work on Medical Service Act advertising or unlicensed-practice questions, or a written plan to involve a colleague who has that work.
2. Demonstrated PIPA work for a controller that handles health-adjacent or other sensitive information.
3. Comfort with KFTC fair labeling and online consumer rules, including the e-commerce residual.
4. Ability to read the English Blue Book and advise in a language the founder can use for decisions (Korean, English, or both).
5. Korean-speaking or dual-qualified counsel is preferred for this track. Preference is not a requirement if competence is otherwise clear.
6. Written engagement letter. Hourly or capped first memo. No equity, no "advisory shares," no coach-for-legal-fees barter.

6.3. US track selection criteria

1. Demonstrated FTC advertising work, preferably health, supplement, coaching, or telehealth-adjacent (not only SaaS privacy).
2. Familiarity with Endorsement Guides and typical-results problems.
3. Ability to spot state UPL/medicine risk without pretending to opinion every state on a small budget.
4. If the founder later forms a US LLC, ability to coordinate (or refuse and refer) on Form 5472 / proforma 1120 and PE/ECI residual. Tax may be a separate CPA. Do not assume the advertising lawyer is the tax lawyer.
5. Written engagement letter. Same barter ban.

6.4. Disqualifiers

• Counsel who offers to "guarantee FTC-proof copy."
• Counsel who recommends a free sleep-diagnosis quiz as a lead magnet.
• Counsel who wants a named-hospital affiliate fee.
• Counsel who says English-only pages cannot be reached by Korean or US law.
• Counsel who treats a US LLC as "the" structure without writing the Korean-resident worldwide-tax and 5472 residuals (document 03).

6.5. How to find, without this Note naming anyone

Use bar-association referral, existing trusted introducers, and published enforcement-defense or advertising-compliance work. Get two quotes on the Korean track before leftover-risk acceptance. Get at least one US quote before any US-person marketing. Record quotes in clause 11.

7. Engagement scoping questions (send these)

Ask both tracks the questions that match their system. Ask every question in 7.1 of Korean counsel. Ask every question in 7.2 of US counsel. Ask 7.3 of both.

7.1. Questions for Korean counsel (Track 1)

1. On the facts in document 04, does the described coaching model, if followed, stay outside unlicensed medical practice under the Medical Service Act, and where does it cross the line?
2. Which words, images, and tools (including STOP-BANG, ISI, AHI estimators, wearable "diagnosis," white-coat imagery, "clinical," "patient," "treatment plan") create medical-advertising or unlicensed-practice risk?
3. Is a yes/no red-flag screen that never scores a disorder, used only to stop-sale and refer, acceptable, and what must not be recorded?
4. As a Seoul controller, what is the minimum lawful basis and separate consent design under PIPA before any sleep-symptom or red-flag data is collected? What is banned until then?
5. Which processors (video, calendar, email, payment, analytics) create cross-border transfer issues, and what instruments are required?
6. Does the Act on Consumer Protection in Electronic Commerce apply to English-only, fully online, client-paid coaching sold by a Seoul-resident operator? If yes, which disclosures and withdrawal rules attach?
7. What fair-labeling and KFTC issues arise from process/effort guarantees, honest-capacity scarcity, and lifestyle testimonials?
8. For a later KR 개인사업자 versus 법인, what is the advertising, consumer, and tax difference that should change the contract party?
9. If a US LLC is later formed and owned by the Korean-resident founder, what Korean tax and PE reporting still applies to worldwide income and to the foreign entity?
10. What is the recommended first-memo scope and fee cap for a solo operator with limited money?

7.2. Questions for US counsel (Track 2)

1. Which statements in documents 04 and 06, and in any attached sales copy, are health claims that need competent and reliable scientific evidence under FTC substantiation principles?
2. Are process/effort guarantees (keep coaching / refund unused sessions if work was done) acceptable, and which physiological outcome guarantees must stay banned?
3. What typical-results, testimonial, and "I used to have insomnia" language is usable if the Practice never confirms a diagnosis?
4. Does an open English page, without geo-block, put US persons in scope even if the Practice "does not target" the US?
5. For a first-year target list of [STATES OR "UNDECIDED"], what is the practical UPL/medicine and coaching-statute residual? Do not ask for a fifty-state survey on a starter budget unless quoting it separately.
6. Is the Practice a HIPAA covered entity or business associate on these facts?
7. If a US LLC is formed and owned by a Korean resident, with services delivered from Seoul, what PE / effectively connected income residual should advertising counsel flag for tax counsel?
8. What is the recommended first-memo scope and fee cap?

7.3. Questions for both tracks

1. May the Practice use Hormozi-style value-equation copy, honest-capacity scarcity, and action-based (not outcome-based) guarantees without creating a medical-result net impression?
2. Is "somnologist or licensed physician" generic referral language acceptable, and is any named facility or paid inducement forbidden?
3. What age-gate evidence is enough for an 18+ rule on a fully online offer?
4. What must be true before the UK/EU geo-exclusion stop rule can be lifted (GDPR + CAP or equivalent)?
5. What written leftover-risk-acceptance language would you want the founder to sign if the founder cannot afford the full recommended scope this year?

8. Budget note and sequence (solo / small / limited money)

8.1. The Practice has no audience yet and limited money. Counsel is still a launch condition, not a growth luxury.

8.2. Sequence (mandatory unless leftover risk is accepted in writing after a quote):

1. Korean MSA / PIPA first. Operator location. Unlicensed-practice and sensitive-data risk sit here. No collection and no ads before this track is honest.
2. Korean KFTC / fair labeling and e-commerce residual in the same first memo if the fee cap allows. If not, they are the first add-on, not a "later year" item, because the first public sentence is advertising.
3. US FTC / endorsements / UPL before any US person is marketed to or sold to, and before any unpaid US testimonial is solicited.
4. Tax (KR CPA, and US CPA if a US entity or US-source facts appear) before incorporation, not after. Document 03 forbids treating venue as decided in this draft set.
5. UK/EU / GDPR / CAP only if the geo-exclusion stop rule will be lifted. Default is exclude.

8.3. What to buy on a small check. A capped written memo that marks up Part A and answers clause 7, not a full "outside general counsel" retainer. Ask for a red-line of documents 04, 05, and 06 first. Those three are the speech and safety core.

8.4. What not to buy first. Trademark fireworks, a US LLC mill package, a multi-state entity stack, or a "HIPAA compliance certification."

8.5. If the quote exceeds cash. Do not launch. Either wait, narrow the offer to private unpaid conversations with no collection (still no ads), or use document 25 (sibling) / the leftover-risk block in document 01 only after a written quote exists. Leftover-risk acceptance without a quote is not honest.

9. Residual risks if the founder launches on domain drafts alone

The following are the leftovers this domain can already see. They are not a complete risk register.

9.1. Domain drafts lower improvisation risk. They do not lower enforcement risk to zero. They are not insurance.

10. "Do not collect / do not advertise" remains in force

10.1. Until Track 1 engagement exists or a written leftover-risk note is accepted after a Track 1 quote, the Practice may not:

• collect personal information or sensitive information;
• run pixels or identifying analytics;
• run paid ads;
• launch lead magnets, intake forms, or community join forms;
• take payment.

The stop rule is still on. This stop rule may be lifted only when counsel is actually hired, or a dated leftover-risk note is accepted after a quote.

10.2. Until Track 2 engagement exists or a written leftover-risk note is accepted after a Track 2 quote, the Practice may not market to or sell to US persons, and should not leave an open health-adjacent offer page reachable by US persons without geo-control plus leftover-risk acceptance.

10.3. Internal writing against the Blue Book remains allowed (document 01, clause 4).

10.4. Same-day stop power in document 01, clause 6, applies to any breach of this clause 10. Legal can stop ads, collection, and launch the same day.

11. Engagement and quote log (blank, for the founder)

11.1. Do not fill firm names into the Blue Book narrative. Put them only in this log when they are real.

12. Leftover-risk-acceptance block (use only after a written quote)

I, 이성재 (and, if applicable, Napoleon/Emperor Livingstone), have received a written quote for the counsel track(s) checked below, have read document 01 clause 11 and this document 02 clause 9, and accept the leftover risk of proceeding without retaining that track at this time.

• [ ] Track 1 (Korean MSA / PIPA / KFTC / e-commerce / tax) quote received. Leftover risk accepted for a delay of engagement only. Collection and ads remain under a stop rule unless a separate writing says otherwise, which this domain recommends against.
• [ ] Track 2 (US FTC / endorsements / UPL) quote received. Leftover risk accepted. US-person marketing remains under a stop rule unless a separate writing says otherwise.

Signature: [FOUNDER SIGNATURE] Date (KST): [DATE]

Napoleon/Emperor Livingstone: [NAME] Signature: [SIGNATURE] Date (KST): [DATE]

Note: This domain's default recommendation is do not accept leftover risk on Track 1 for collection or ads. The block exists so that any overrule is written and dated, not whispered.

13. Operational checklist (founder)

• [ ] Part A (01 through 06) assembled as the briefing pack.
• [ ] Sibling-file status listed honestly (many will be "not yet drafted").
• [ ] Two Korean-track quotes requested, or one quote plus a written reason for a single source.
• [ ] US-track quote requested before any US-person plan.
• [ ] No collection, no pixel, no paid ad, no public intake while this Note's clause 10 holds.
• [ ] No law firm named in public materials as "our attorney" without that firm's written consent.
• [ ] Document 03 still undecided (no one incorporated "because counsel said pick something" without a recorded decision).

14. Evidence status / Confidence / Residual uncertainty

Evidence status. Commonly accepted statute and guidance names only: Medical Service Act (의료법); PIPA (개인정보 보호법); Act on Fair Labeling and Advertising; Act on Consumer Protection in Electronic Commerce; Monopoly Regulation and Fair Trade Act (KFTC backdrop); FTC Act §5; FTC Health Products Compliance Guidance; FTC Endorsement Guides; Consumer Review Fairness Act; state unlicensed practice of medicine (varies). No counsel letter, no enforcement file, no quoted fee sits under this Note as of 20 August 2026 (KST).

Confidence. High that two tracks are the conservative structure and that Korean MSA/PIPA should be bought first. High that collection and ads must stay under a stop rule. Medium on the exact attachment of the E-commerce Act to English-only sales. Medium on which US states would be the first UPL residual if the page is open. Low that a single dual-qualified individual will be found on a starter budget.

Residual uncertainty.

1. Korea E-commerce Act (전자상거래법) may still apply to English-only sales by a Seoul operator. Counsel must answer. This Note does not decide.
2. Whether an open English page, without a US geo-target, is enough for practical FTC and state exposure is a counsel question. This domain treats it as in-scope until geo-control plus advice exists.
3. Form 5472 / 5471 and PE/ECI issues appear only if a US entity or US-source fact pattern is created. They are flagged so that an LLC mill cannot hide them. They are not a present filing duty of a natural person who has not formed anything.
4. This Note is not licensed legal advice and is not a substitute for Korean MSA/PIPA/KFTC counsel and US FTC/health-coaching counsel.

Entity and Tax Decision Record

Blue Book, Core Legal Package, Part A

Plain summary (for Emperor Livingstone)

Intelligent Solutions is the Emperor's other Korean sole proprietorship, registered for software development and AI consulting. Keep that name. Sleep coaching must not operate under that registration. Sleep contracting party, invoices, privacy controller, and insurance stay 이성재 as a natural person until a new registration with coaching-appropriate codes exists, or counsel says otherwise. Mixing sleep coaching into the software and AI registration is refused. Do not form a new business without a dated Emperor writing. A Korean company and a US LLC are still not chosen. The stop rule on ads and collection is still on. This Record is not licensed legal or tax advice.

1. Purpose and status

1.1. This Record lists options for later changes (a Korean company, a US LLC, or a later sleep-coded sole proprietorship) and records two present facts: the founder already has a Korean sole proprietorship named Intelligent Solutions for software and AI consulting; that registration is not the sleep Practice. It is a decision log, not a formation package.

1.2. A Korean company and a US LLC are still not chosen. Sleep coaching must not use the Intelligent Solutions registration. No team may pick a venue because a blog or an LLC mill said so. See clause 2.1.2.

1.3. Escalation item. If anyone (including the founder in a moment of shipping pressure) attempts to treat venue as decided in a public contract, a payment-rail application, or a sibling Blue Book file without a dated row in clause 10 of this Record, Legal Compliance and Privacy will halt that act under document 01, clause 6 (Legal can stop ads, collection, and launch the same day), and escalate to Napoleon/Emperor Livingstone.

1.4. This Record is not tax advice, not a Form 5472 opinion, not a PE/ECI opinion, and not a VAT registration opinion.

2. Shared facts that constrain the options (do not relitigate)

2.1. Founder/operator: 이성재, based in Seoul, Republic of Korea. Treat as a Korean tax resident until a contrary professional determination exists.

2.1.1. English display name (Napoleon dated exception, 20 August 2026 KST). The founder's English display name is Livingstone. Do not mass-rewrite Blue Book legal-party lines from 이성재 to Livingstone. Later public copy in English first person may say Livingstone. That copy does not change the legal party.

2.1.2. Other Korean sole proprietorship (Emperor correction, 20 August 2026 KST). He is registered as a sole proprietorship in South Korea under the name Intelligent Solutions, linked to legal name 이성재, for software development and AI consulting. Keep that name. It is not a company (법인) and not a US entity. Sleep coaching must not go on that registration. Mixing sleep coaching into that software and AI registration is refused. Leftover uncertainty: we do not have the registration number, tax ID (사업자등록번호), or a copy of the certificate in hand. Do not invent those numbers. Do not treat the paper as a filed exhibit for this Practice.

2.2. Business: Behavioral Sleep Improvement Coaching only. Three allowed actions. Fully online. English only. Solo/small. Limited money. No audience yet. High-ticket or hybrid. Client-paid.

2.3. No client data collection and no paid ads until document 01 remains in force and a counsel-engagement residual is honest (document 02). A counsel-engagement residual means a real lawyer is hired, or Napoleon/Emperor Livingstone signs a dated leftover-risk note after seeing a written quote.

2.4. English-only sales do not strip Korean consumer or e-commerce duties. The Act on Consumer Protection in Electronic Commerce (전자상거래법, Korea's online-consumer law) may still apply.

2.5. PIPA-first. PIPA is the Personal Information Protection Act (개인정보 보호법), the Korean personal-information law. If collection begins, the controller identity must match the real decision-maker. A foreign shell does not move the Seoul mind out of Seoul.

2.6. Default-exclude UK/EU until a GDPR + CAP claims set exists.

3. Recommendation posture (read before the option table)

3.1. Do not incorporate until a first paid-client path is designed. Path means: who is the buyer, in which geo, at what price, on which payment rail, under which contract, after which red-flag screen. A legal person with no path is a filing hobby.

3.2. Working recommendation for sleep papers. CSA, invoices, privacy controller, and insurance read 이성재, a natural person in Seoul. Do not print Intelligent Solutions on those sleep papers. Do not print only Livingstone. A later registration with coaching-appropriate codes requires a dated Emperor writing, or a counsel writing that names a different path. Keep an assignment clause if that later registration or a company is formed.

3.3. Sibling drafters (files 07, 08, 09, 11, 13, 23) use 이성재 as the working draft party. They must not print Intelligent Solutions as the sleep party. They must not print "[US LLC NAME]". They must not invent a registration number.

3.4. The Intelligent Solutions 개인사업자 is present and reserved to the other business. It is not the sleep venue. A sleep-coded 개인사업자, a Korean company, and a US LLC remain later options only. Do not form a new business without a dated Emperor writing.

3.5. A US LLC is a discussed internet-coach pattern, not a recommendation. See leftovers in clause 7. It is often sold as "simple." For a Korean-resident owner delivering from Seoul, it is not simple.

4. Comparison snapshot

Qualitative cost bands (not quotes): Low = ordinary solo filings and a registered agent or simple bookkeeping. Mid = counsel plus accountant plus annual reports in two systems. High = two-country corporate maintenance, transfer-pricing adjacent questions, or PE defense.

5. Option A. Korean sole proprietor (개인사업자)

5.1. What it is

이성재 registers a sole proprietorship in Korea. There is no separate legal person in the corporate sense. The human and the business share liability.

5.2. Formation cost band (qualitative)

Low. Registration, a Korean business-bank account, and bookkeeping. Not free. Not a reason to delay counsel on MSA/PIPA.

5.3. Ongoing compliance

• Korean bookkeeping and individual/business tax filings as advised by a Korean CPA.
• VAT analysis if and when supplies and thresholds require it.
• PIPA controller duties if collection begins (sibling files 11 through 15).
• Fair labeling, e-commerce residual, and Medical Service Act (의료법, the Korean law on who may practice and advertise medicine) advertising constraints still apply to the human.
• Insurance bind remains a condition subsequent (document 01, CS-5). Policy: [POLICY NUMBER IF BOUND].

5.4. Client-contracting party

The registered 개인사업자 name, which will still point at 이성재. Draft contracts may say "이성재, to be assigned to a registered 개인사업자."

5.5. Privacy controller identity

이성재 / the sole proprietorship, located in Seoul. This is the cleanest match to the real facts.

5.6. Consumer-law attachment

Korean consumer and advertising law can attach. The e-commerce residual remains open (clause 8.4). English-only does not remove it.

5.7. Banking and payment rails

Korean bank account in the business registration. Payment processors that accept Korean sole proprietors. Global processors may still be usable later. Do not open a processor that requires a decided US entity just to "look future-proof."

5.8. Advantages relative to this Practice

Matches solo/small. Cheap to reverse if the offer dies. Honest controller identity. No Form 5472 story.

5.9. Disadvantages

Unlimited personal liability. Some foreign processors and B2B buyers prefer a company. Does not, by itself, create US limited liability.

5.10. Residual specific to Option A

Personal liability for refunds, claims, and regulatory fines. Insurance is not optional as a risk story even if cash is tight. Still need document 02 counsel before collection and ads.

6. Option B. Korean corporation (유한회사 or 주식회사)

6.1. What it is

A Korean company becomes the contracting party. 이성재 is typically the director/shareholder. Two common forms discussed in ordinary Korean small-business practice are 유한회사 and 주식회사. This Record does not choose between them.

6.2. Formation cost band (qualitative)

Mid. Counsel or judicial-scrivener work, capital, registration, corporate bank, seal/admin, and accounting that is heavier than a sole shop.

6.3. Ongoing compliance

• Corporate tax, payroll if the founder is paid, shareholder records.
• Minutes and maintenance appropriate to the form.
• PIPA controller is the company. The human in Seoul still makes the decisions. Vendors and consent forms must name the company correctly.
• Same MSA / fair-labeling / e-commerce residuals as Option A, now in the company's name, with possible director exposure remaining.

6.4. Client-contracting party

The company. Assignment from the founder's pre-entity drafts must be done in writing after formation, with client notice if required by the contract or by counsel.

6.5. Privacy controller identity

The company, Seoul-managed. Do not list a US vendor as controller.

6.6. Consumer-law attachment

Korean attachment remains the base case. A Korean company selling English-only online services does not become a foreign seller for Korean purposes merely by using English.

6.7. Banking and payment rails

Korean corporate account. Possibly cleaner vendor contracts. Still not a US-processor magic key.

6.8. Advantages

Separate legal person. Some counterparties prefer it. May be a later home for hiring. Limited liability is real only if corporate formalities and undercapitalization rules are respected. Counsel must explain those limits.

6.9. Disadvantages

Cost and admin for a business with no audience yet. Does not remove Korean tax on amounts the founder takes out. Does not clear FTC (the US Federal Trade Commission, which polices unfair or deceptive ads) or MSA speech rules.

6.10. Residual specific to Option B

Premature incorporation spend. Director/officer duties. Possible need to migrate contracts and PIPA notices. Still no venue decision.

7. Option C. US LLC (typically WY / DE / NM in internet-coach patterns) owned by a Korean resident

7.1. What people mean, and what this Record does not do

US-based internet-coach commentary often names Wyoming, Delaware, or New Mexico LLCs as cheap, private, or "simple." This Record records that pattern as an option people will raise. It does not recommend a state. It does not treat a US LLC as decided.

7.2. Formation cost band (qualitative)

Formation fees look Low. Honest operation is Mid to High: registered agent, US CPA for foreign-owned LLC filings, Korean CPA for worldwide income, possible sales-tax/economic-nexus review, possible PE/ECI review, and extra KYC when the beneficial owner is a Korean resident delivering from Seoul.

7.3. Ongoing compliance (must appear)

1. Registered-agent cost every year in the formation state, plus state annual report or equivalent if applicable.
2. Form 5472 / proforma 1120 risk for a foreign-owned US disregarded LLC (and related information-return risk). Penalties for missing 5472 are commonly described as severe. This is a must-ask to a US CPA before any formation. This Record is not a filing instruction.
3. Form 5471-adjacent residual if the structure is later changed so that a foreign corporation owns a US entity, or if other controlled-foreign-company facts appear. Flag it. Do not DIY the form choice.
4. Sales-tax / economic nexus if US clients are invoiced and if the supply is treated as a taxable service in a nexus state. Coaching treatment varies. Ask, do not assume "digital services are exempt."
5. Korean tax on worldwide income still applies to 이성재 as a Seoul-resident individual. Distributions, disregarded-entity pass-through, or "the LLC kept the money" stories do not erase Korean-resident taxation.
6. Permanent establishment / effectively connected income residual if the LLC is a shell and the operations (coaching, sales, management) are performed in Korea by the owner. A US mailbox is not a US trade. It can still create a messy two-country fact pattern.
7. PIPA controller residual. A US LLC name on a privacy notice does not move the Seoul decision-maker out of PIPA. Cross-border transfer instruments may be needed if US processors are used.

7.4. Client-contracting party

On paper, the LLC. In a dispute, a claimant and a regulator will also look at the human in Seoul. Drafting as if the LLC were a full liability wall is a false comfort.

7.5. Privacy controller identity

Do not print "controller = [US LLC NAME]" as a settled fact. Record: unresolved; likely Korean-located controller residual plus US-entity named party. Counsel on both tracks must speak.

7.6. Consumer-law attachment

• US: FTC Act §5 and state consumer law can attach to English-language health-adjacent offers that reach US persons, entity or no entity.
• Korea: e-commerce and fair-labeling residuals can still attach to the Seoul operator.
• English-only does not strip either.

7.7. Banking and payment rails

US fintech and merchant accounts often require a US responsible person, SSN/ITIN, or enhanced KYC for foreign owners. Chargebacks, card-scheme health-claim reviews, and frozen reserves still hit the operator. A US LLC does not make apnea-cure copy acceptable to a processor.

7.8. Advantages people cite (recorded, not endorsed)

Perceived US limited liability. Some payment rails. Familiarity for US B2B buyers. Cheap formation screenshots.

7.9. Disadvantages for this founder

Two-country compliance for a solo coach with no audience. 5472 / proforma 1120 risk. PE/ECI risk if Korean-managed. Korean worldwide tax remains. Privacy story becomes harder, not easier. Temptation to treat venue as decided.

7.10. Residuals that MUST appear whenever Option C is discussed

Copy this box into any sibling file or chat that starts to "just form a Wyoming LLC":

STOP. A US LLC is not chosen. A US LLC owned by a Korean resident does not remove Korean tax on worldwide income. It creates Form 5472 / proforma 1120 risk (and possibly later 5471-adjacent work). It creates registered-agent cost. It can create US sales-tax / economic-nexus questions if US clients appear. It can create PE / ECI risk if the LLC is a shell with Korean-managed operations. PIPA controller identity may still sit in Seoul. English-only does not strip Korean e-commerce duties. Do not form this on an LLC-mill package without Korean tax counsel and a US CPA.

8. Residuals that apply to EVERY option (must appear)

8.1. Korean tax on worldwide income. A Seoul-resident individual is the base case for Korean tax on worldwide income, regardless of a US entity. Entity choice changes mechanics. It does not create a "foreign income is invisible" rule.

8.2. VAT / GST later. If the Practice later sells into other countries, VAT, GST, or equivalent registration and collection duties may attach even when the buyer is a consumer paying in USD or KRW. UK/EU are default-excluded, which also avoids a first-wave VAT/GST design, but exclusion must be technically real (age/geo SOP, sibling file 19), not a sentence in the footer.

8.3. Permanent establishment / ECI. Even without a US LLC, heavy and regular US-directed activity can raise questions. With a US LLC shell and Korean delivery, the question is louder. Flag for counsel. This Record does not decide.

8.4. English-only does not strip Korean consumer / e-commerce duties. Residual uncertainty: the Act on Consumer Protection in Electronic Commerce (전자상거래법, Korea's online-consumer law) may still apply to English-only sales by a Seoul operator. Withdrawal rights, required business-identity disclosures, and time limits must be asked of Korean counsel (document 02, question 7.1.6) before the first paid close.

8.5. Speech law is entity-independent. Medical Service Act advertising rules, KFTC fair labeling, and FTC substantiation apply to the words and the net impression. Forming a company does not legalize "fall asleep in 7 days or your money back."

8.6. PIPA sensitive-information rules are entity-independent. Health/sleep-symptom data requires a lawful design and separate consent (sibling file 12). No collection until the stop rules in document 01 lift. Collection is under a stop rule. Do not collect names, emails, or sleep answers.

8.7. Insurance is not an entity. [INSURER], [POLICY NUMBER IF BOUND], [LIMITS] remain blank. Bind is a condition subsequent, not a substitute for scope-of-practice control.

9. Drafting rules for sibling files (until a decision is logged)

9.1. Working party line: 이성재, natural person, Seoul, Republic of Korea, operating the Practice. Not Intelligent Solutions.

9.2. Optional doing-business line: "the Coaching Practice operated by 이성재." Do not use Intelligent Solutions. Do not use Livingstone as the legal party.

9.3. Include an assignment clause substantially as follows (counsel may mark up):

이성재 may assign this agreement to a sole proprietorship, company, or other entity that 이성재 controls and that continues the Practice. Assignment does not change scope of practice, the red-flag screen, or the ban on medical claims. The assignee becomes the contracting party after written notice to the client.

9.4. Payment clause may say "account designated by 이성재" and must not require a named US LLC.

9.5. Privacy notice drafts (sibling 09 and 11) treat the controller as 이성재, a Seoul natural person, unless clause 10 later names a separate sleep-coded entity.

9.6. If a payment processor application demands a decided entity type, stop and log a decision. Do not let the processor's dropdown become the Blue Book.

10. Decision log (blank rows for Napoleon / Emperor Livingstone)

Status of each row: leave blank until a real decision. Forged certainty is a halt.

10.1. A row that treats venue as decided is valid only if it cites a counsel or CPA writing, or a dated leftover-risk acceptance that names the residuals in clauses 7.10 and 8.

10.2. Napoleon/Emperor Livingstone may refuse to treat venue as decided. That refusal should be written in this table.

11. Operational checklist (before anyone files anything)

• [ ] First paid-client path designed (buyer, geo, price, rail, contract, red-flag screen).
• [ ] Document 02 Track 1 quote exists. Track 2 quote exists if US persons are in the path.
• [ ] Korean CPA asked about worldwide-income mechanics for the option on the table.
• [ ] If Option C is on the table: US CPA asked about Form 5472 / proforma 1120, sales-tax/economic nexus, and PE/ECI; Korean counsel asked about foreign-entity reporting.
• [ ] Controller identity for PIPA written in one sentence that matches real management location.
• [ ] Assignment clause present in draft client agreement.
• [ ] No brand name invented to make an LLC application look finished.
• [ ] This table (clause 10) updated the same day as any filing.
• [ ] Insurance broker conversation scheduled if a paid close is actually near. Policy still [POLICY NUMBER IF BOUND].

12. What this Record is not

12.1. Not articles of organization or a 사업자등록 package.

12.2. Not a choice of Wyoming, Delaware, New Mexico, Seoul, or any other filing office.

12.3. Not a representation that limited liability will hold against 의료법 or FTC speech claims.

12.4. Not permission to collect data or run ads. The stop rule on ads and collection is still on.

12.5. Not a substitute for licensed Korean MSA/PIPA/KFTC/tax counsel or US FTC/tax counsel.

13. Evidence status / Confidence / Residual uncertainty

Evidence status. Options are described from commonly discussed small-business patterns and commonly accepted filing names (개인사업자; 유한회사; 주식회사; US LLC; Form 5472; proforma 1120; Form 5471 as a related residual). No formation quote, no CPA memo, and no counsel letter is attached. State-by-state US LLC statutes are not surveyed. Korean National Tax Service circulars are not cited by number.

Confidence. High that Intelligent Solutions is the other business (software + AI) and that sleep must not use that registration. High that the sleep party is 이성재 as a natural person until a separate, correctly coded registration exists. High that a new business must not be formed without a dated Emperor writing. High that a Korean company and a US LLC are still not chosen. High that Korean-resident worldwide tax survives a US LLC. High that Form 5472 / proforma 1120 is a real residual to send to a US CPA if a foreign-owned disregarded LLC is formed. Medium on which Korean form (유한회사 vs 주식회사) would later be better. Medium on processor KYC outcomes. Low on PE/ECI without facts about US travel, US agents, and contract-conclusion location.

Residual uncertainty.

1. We do not have the Intelligent Solutions registration number, tax ID, or a copy of the certificate. Do not invent them. Sleep must not use that registration in any case.
2. Korea E-commerce Act (전자상거래법) may still apply to English-only sales by a Seoul operator, under every option. Identity-disclosure rules may later require a sleep-coded registration number on invoices and the site, if one later exists.
3. Whether a US LLC with Korean-managed coaching is a PE or produces ECI is fact-specific and not decided here.
4. Form 5471 versus 5472 depends on later ownership geometry. Both are flagged as residuals, not as present forms the founder must file today.
5. VAT/GST attachment depends on later geos. UK/EU default-exclusion reduces near-term design, if the exclusion is real.
6. This Record is not licensed legal or tax advice and is not a substitute for Korean MSA/PIPA/KFTC/tax counsel and US FTC/tax counsel.

Scope of Practice and Banned Conduct

Blue Book, Core Legal Package, Part A

Plain summary (for Emperor Livingstone)

This file says what the Practice is, what it may say, and what it must never do. It is Behavioral Sleep Improvement Coaching only: it does not diagnose, treat, or claim to cure any condition. Adults 18+ only. Guarantees, if any, are about process and effort (sessions delivered, unused sessions refunded if stated work was done), never about hours slept or a symptom disappearing. Scarcity must be real calendar capacity, there is no paid doctor kickback, UK and EU stay out, and official ISI, STOP-Bang, IRLS, ESS, and CSD forms are not used. The stop rule on ads and collection is still on. This stop rule may be lifted only when counsel is actually hired, or Napoleon or Emperor Livingstone signs a dated leftover-risk note after a written quote. This document is not licensed legal advice and is not a medical-practice privilege.

1. Purpose

1.1. This document defines what the Practice is, what it may say, and what it must never do. It is the speech-and-conduct constitution for every other team (offer, sales, content, ads, fulfillment).

1.2. The Practice is Behavioral Sleep Improvement Coaching only. It does not diagnose, treat, or claim to cure any condition.

1.3. Breach of a banned-conduct rule is a stop-sale and, if a session is underway, a session abort. See clause 11 and document 05.

1.4. Licensed Korean MSA counsel and US FTC/health-coaching counsel must mark this up before real-world use (documents 01 and 02). Until then, this text governs internal drafts only.

2. Defined terms

2.1. "the Practice" means the Coaching Practice operated by 이성재.

2.2. "Behavioral Sleep Improvement Coaching" means the three allowed actions in clause 4, and nothing else.

2.3. "Client" means an adult (18+) who has passed the red-flag screen (document 05) and has been accepted into a paid or formally reserved program. Until then, the person is a Prospect.

2.4. "Prospect" means an adult who has not yet been accepted. Minors are not Prospects. They are rejected.

2.5. "Medical conduct" means any act or speech that a reasonable person would take as diagnosis, treatment, prescription, interpretation of a clinical test, or a promise to cure.

2.6. "Self-label" means a Prospect or Client's own words that name a disorder or diagnosis (for example, "I have insomnia," "I have apnea").

2.7. "Process/effort guarantee" means a promise about the Practice's service (sessions delivered, coaching continued, unused-session refund if stated work was done). It is never a promise about hours slept, latency, AHI, or symptom disappearance.

2.8. "Physiological outcome guarantee" means any promise, refund trigger, or "win your money back" mechanic tied to a body result. Banned.

2.9. "Hormozi stack" means offer, lead, money-model, and LTV methods that other teams will use. They are allowed only inside this document's constraints.

2.10. "Conduct-over-label" means the Practice is judged by what it does and what a reasonable person hears, not by the word "coach" on a page.

2.11. "Somnologist" means a physician specializing in sleep medicine. Used only as a generic referral class. Never a named person or hospital in a paid or implied kickback.

3. What the Practice is not

3.1. Not a medical clinic, hospital, or telehealth practice.

3.2. Not the practice of medicine under the Medical Service Act (의료법, the Korean law on who may practice and advertise medicine), and not a substitute for that practice.

3.3. Not licensed psychotherapy, psychiatry, or counseling as a regulated mental-health profession.

3.4. Not nutrition therapy, dietetics, or supplement prescription, unless a later Blue Book amendment scopes a licensed or separately advised nutrition offering. Default: out of scope.

3.5. Not a pharmacy, device clinic, or CPAP provider.

3.6. Not a HIPAA covered entity by default. HIPAA is the main US health-privacy law. Do not claim HIPAA.

3.7. Not a diagnostic laboratory and not an interpreter of sleep studies, wearables, or consumer "sleep scores."

4. Defined scope (the only three allowed actions)

The Practice may do only the following.

4.1. Allowed action 1. Verified, research-backed sleep information

The Practice may teach generally accepted, cited sleep-hygiene and behavioral-sleep education (for example, light, schedule regularity, caffeine timing, wind-down, bedroom environment) framed as education, with sources the operator has actually read.

Rules:

1. Cite the type of source (peer-reviewed paper, consensus statement, textbook chapter). Do not invent citations.
2. Do not imply that education is individualized medical advice.
3. Do not present a research finding as a guarantee that the Client will get the same result.
4. If research is about a clinical treatment (for example, CBT-I as a medical or psychological treatment for insomnia disorder), the Practice may describe it as public knowledge and must say: the Practice is not delivering clinical CBT-I as treatment. Habit coaching that is CBT-I-adjacent is education and habit design only (clause 5.2).

4.2. Allowed action 2. A program that fits lifestyle and needs

The Practice may design a behavioral program that fits the adult Client's schedule, travel, work pattern, and stated preferences (bed/wake window targets, wind-down sequence, environment changes, accountability cadence).

Rules:

1. "Fits needs" means lifestyle and logistical fit, not a medical needs assessment.
2. The program has behavioral goals (for example, "lights out attempt at a chosen time," "no caffeine after a chosen hour"). It does not have clinical goals (for example, "AHI under 5," "insomnia disorder in remission").
3. The program is withdrawn or never sold if document 05 stop-sale triggers fire.

4.3. Allowed action 3. Daily-habit accountability

The Practice may check whether the Client did the agreed behavioral actions, help the Client restart after a miss, and adjust the behavioral plan.

Rules:

1. Accountability is about actions taken, not about a wearable's "sleep score" as truth.
2. Wearable numbers, if the Client volunteers them, are self-reported lifestyle data, not a diagnosis and not a basis for the Practice to interpret a disorder.
3. Missed habits are coaching data. They are not non-compliance with medical treatment.

4.4. Nothing else is in scope

If an action is not one of the three, it is out of scope until this document is amended after counsel. Examples of out-of-scope: interpreting a polysomnogram, adjusting a CPAP prescription, recommending a prescription hypnotic, scoring STOP-BANG as a diagnosis, selling a supplement as treatment, coaching a minor.

5. Allowed speech (white list)

The following speech is allowed in internal drafts and, after a counsel leftover-risk note and placement of document 06, in public use. Allowed is not the same as "recommended for ads."

5.1. Sleep-hygiene education citing research

Permitted examples (adapt, do not treat as magic words):

• "I teach research-backed sleep-hygiene information and help you build a program that fits your life, then I hold you accountable to daily habits."
• "Light, schedule, caffeine timing, and bedroom environment are common behavioral points discussed in sleep-education literature. Individual results vary. This is not medical advice."

5.2. Stimulus control and CBT-I-adjacent habit coaching, framed as education not treatment

Permitted posture:

• The Practice may teach well-known behavioral ideas (regular schedule, using the bed for sleep and intimacy rather than work, getting up if unable to sleep after a personal threshold, winding down off-screens) as education and habit design.
• The Practice must not say "I provide CBT-I," "I treat insomnia with CBT-I," or "this is clinical CBT-I."
• The Practice must not present itself as a substitute for a licensed clinician delivering CBT-I.

Required nearby sentence when CBT-I is mentioned:

CBT-I is a clinical treatment delivered by qualified clinicians. The Practice does not diagnose insomnia and does not provide clinical CBT-I. Any habit work here is educational coaching only.

5.3. Schedule design

Permitted: collaborative choice of target sleep and wake windows for an adult lifestyle (shift-adjacent patterns, travel, parenting of the Client's own children). Not permitted: prescribing a sleep window as treatment for a named disorder.

5.4. Environment

Permitted: light, noise, temperature, and device-in-bedroom habit discussion as lifestyle. Not permitted: selling or endorsing a medical device as treatment.

5.5. Caffeine and alcohol timing as lifestyle, not prescription

Permitted: "Many people find caffeine late in the day makes it harder to wind down. We can pick a cutoff time as a habit."

Not permitted: "Stop all alcohol, I am treating your sleep apnea," or any dosing instruction presented as medical.

5.6. Process and effort statements

Permitted: "If you do the agreed check-ins and habit logs, I will deliver the sessions you bought. If I fail to deliver, unused sessions are refunded as stated in the service terms."

Not permitted: any sentence in clause 7.

5.7. Honest scarcity

Permitted: real cohort size, real 1:1 calendar capacity, real "I take [N] clients this month because that is all I can coach well."

Not permitted: fake "only 3 spots" when the calendar is empty, exploding "medical window" urgency, or scarcity tied to a disease getting worse.

6. Banned medical conduct and banned speech (black list)

The following are banned in public copy, sales calls, DMs, session talk, testimonials the Practice republishes, and internal drafts that could leak.

6.1. Diagnose

Ban: stating or implying that a Prospect or Client has insomnia disorder, obstructive sleep apnea, restless legs syndrome, narcolepsy, depression, anxiety disorder, or any other condition.

Ban: confirming or denying a Prospect's self-label as a diagnosis (clause 9).

Ban: using STOP-BANG, ISI, ESS, AHI, RDI, or any scoring tool as diagnosis. Ban on using them at all in the Practice's hands. Official ISI, STOP-Bang, IRLS, ESS, or CSD forms are not embedded. See document 05. Screen-to-refer, never screen-to-label.

6.2. Treat

Ban: "treatment," "treatment plan," "therapeutic protocol," "I will treat your insomnia," "coaching as treatment for apnea."

Ban: presenting the program as an alternative to CPAP, oral appliance, surgery, or physician-directed care.

6.3. Cure

Ban: "cure," "cured insomnia," "eliminate apnea," "fix your disease," "never need a doctor again."

6.4. Prescribe

Ban: recommending or stopping prescription medicines, dosing melatonin as if the Practice were a prescriber, or directing use of a prescription device.

6.5. Interpret sleep studies or clinical tests

Ban: reading a polysomnogram, HSAT, MSLT, or physician letter and telling the Client what it "really means." The Client may be told: "Take that document back to the ordering physician. I do not interpret studies."

6.6. Score STOP-BANG, ISI, AHI, or similar as diagnosis

Ban: administering or scoring these tools. Ban: "your ISI is 18, that is clinical insomnia." Ban: wearable-as-diagnosis. Ban: free sleep-diagnosis quiz. Ban: online AHI estimators.

6.7. White-coat imagery and "Dr." implication

Ban: white coat, caduceus, stethoscope, clinic backdrop, "Dr. 이성재" if not a licensed physician using that title lawfully, "medical director" theater, stock photos of ICUs.

If the founder later earns or already holds a non-medical doctorate, do not use "Dr." in sleep-offer copy. The net impression is medical.

6.8. "Clinical," "patient," "treatment plan," "therapy" as medical

Ban those words in the Practice's mouth when they would sound medical.

Allowed substitute words: client, program, habit plan, coaching session, education, accountability.

"Therapy" is banned as a description of the Practice's service. If a Client says "this is my therapy," redirect: "I provide coaching and education, not therapy."

6.9. Supplements and devices as treatment

Ban: stacking mattresses, pills, mouthguards, or gadgets as "the treatment included in your offer." Partner bonuses of that kind are banned (Hormozi value-stack collision).

A Client's own already-purchased consumer product may be discussed as environment (clause 5.4) without endorsement as medical treatment.

6.10. Apnea coaching as a substitute for CPAP

Ban: "you may not need CPAP if you coach with me," "ditch your machine," "I reverse apnea."

If a Client is on CPAP, the Practice does not adjust pressure, masks, or compliance as a clinician. Habit coaching may continue only after document 05 re-entry rules if red flags remain under care.

6.11. Physiological outcome guarantees (express ban list)

Ban, including close paraphrases:

1. "Fall asleep in [X] minutes."
2. "Asleep by [clock time] or your money back."
3. "Cured insomnia or refund."
4. "Win your money back if you sleep [Y] hours."
5. "AHI / sleep-study score improved or free."
6. "Guaranteed deep sleep."
7. Unconditional medical-result guarantees of any kind.
8. Attract offers that a reasonable person would hear as "pay to get insomnia cured or it is free."

Process/effort guarantees only. Anti-guarantee is allowed: the Practice does not take Clients who need a medical promise to start.

6.12. Dishonest scarcity and disease urgency

Ban: fake remaining spots. Ban: "your apnea will become dangerous if you do not buy tonight" as a sales close. Red-flag danger is a referral, not a close (document 05).

6.13. Testimonials that claim treatment or cure

Ban republishing: "this treated my apnea," before/after medical claims, implied diagnosis, disease-cure stories. Lifestyle/habit and client-reported rest may be usable later under sibling file 17 and FTC Endorsement Guides (FTC is the US Federal Trade Commission, which polices unfair or deceptive ads), with consent and typical-results language. Not before a counsel leftover-risk note is honest.

6.14. Minors

Ban: any program, magnet, or community for people under 18. Age gate is mandatory. A parent buying "for my 16-year-old" is an auto-reject.

6.15. UK/EU default

Ban: targeting or knowingly selling into the UK or EU until a GDPR + CAP claims set exists. See sibling file 19.

6.16. Data and ads while the stop rule is still on

Ban: collection, pixels, paid ads, public intake, and lead magnets that collect contact data, until document 01 remains in force and a counsel-engagement residual is honest (document 02). A counsel-engagement residual means a real lawyer is hired, or Napoleon/Emperor Livingstone signs a dated leftover-risk note after seeing a written quote. Collection is under a stop rule. Do not collect names, emails, or sleep answers.

7. Conduct-over-label rule

7.1. Calling the work "coaching," "education," or "accountability" does not save conduct that a reasonable person would experience as medical practice or medical advertising.

7.2. Tests (any one "yes" means the act is banned even if the page says "coach"):

1. Would a reasonable adult think the Practice decided what disease they have?
2. Would a reasonable adult think the program replaces a physician or CPAP?
3. Would a reasonable adult think a refund depends on their body changing?
4. Would a regulator reading only the headline and the testimonial, ignoring the footer, see a health-outcome claim without substantiation?
5. Would a Korean officer reading the Korean-language impression of a translated ad see unlicensed medical advertising?

7.3. If a test is unclear, do not ship. Same-day stop power (document 01, clause 6) applies. Legal can stop ads, collection, and launch the same day.

7.4. Translation and screenshots count. An English page that is screen-captured into Korean ads is still the Practice's speech.

8. Interaction with the Hormozi stack (binding constraints)

Other teams will use Hormozi methods. The following collisions are pre-resolved. Do not reopen them in offer design.

8.1. Offer naming may use container words (intensive, system, reset) but must not use "clinic," "protocol as treatment," "diagnosis," or a disease + deadline.

8.2. Sales one-liners must not be price-compared to medical care. Do not say "cheaper than a sleep lab" as a reason to skip a physician.

9. When a Client or Prospect self-labels ("I have insomnia")

9.1. Do not confirm. Do not deny. The Practice is not a second opinion and not a rebuttal.

9.2. Required redirect (live or written):

I do not diagnose and I do not confirm or deny medical labels. If you have a diagnosis, that belongs with your physician or a somnologist. I can only work on behavioral habits, and only if a safety screen is clear. If anything in the screen is a yes, I will not enroll you. I will ask you to see a somnologist or licensed physician.

9.3. If the red-flag screen is clear, the Practice may continue on behavioral goals only ("we will work on a wind-down sequence and a consistent get-up time"). The self-label is not accepted into the file as a diagnosis.

9.4. If the red-flag screen is not clear, stop-sale. Document 05.

9.5. Session notes (sibling 20) may quote the self-label as the person's words. They may not convert it into the Practice's impression ("Client has insomnia").

10. Allowed session moves vs abort moves (operational)

10.1. Keep going (if screen is clear)

• Teach a hygiene topic with a citation posture.
• Design tomorrow's wind-down.
• Review whether the habit happened.
• Discuss caffeine/alcohol timing as lifestyle.
• Reset a travel-week schedule.

10.2. Abort the session and refer (any one)

• New red-flag symptom (document 05).
• Request for diagnosis, study interpretation, or medication advice.
• Request to "get me off CPAP."
• Suicidality, psychiatric crisis, or withdrawal (emergency services, not a sleep coach).
• Discovery that the person is under 18.
• Discovery that the person is in a default-excluded geo and the geo stop rule is still on.

10.3. Written referral language (generic only)

Use document 05, clause 8. No named hospital. No paid inducement. No paid doctor kickback.

11. Enforcement

11.1. Stop-sale. Sales must not take payment when a banned-conduct trigger or a document 05 trigger fires.

11.2. Session abort. The coach ends the session, states the reason in non-diagnostic words ("this is outside coaching and I need you to speak with a physician"), and follows document 05 documentation rules.

11.3. Written referral. Generic somnologist or licensed physician. Emergency services if clause 10.2 crisis flags fire.

11.4. Copy halt. Legal Compliance and Privacy may kill a page, ad, or script under document 01, clause 6. Legal can stop ads, collection, and launch the same day.

11.5. Repeat breach. A second intentional breach by the operator is a launch stop-rule event. Record it. Do not "coach through" a medical ask to save a high-ticket close.

11.6. No paid workaround. Do not offer a "medical-results tier" or a side-consult that does the banned thing for more money.

12. Public and sales language bank (copy-paste, still DRAFT)

Use with document 06. Do not strip the not-medicine sentences.

12.1. One-sentence scope

The Practice, operated by 이성재, provides Behavioral Sleep Improvement Coaching only: research-backed sleep information, a program that fits your lifestyle, and daily-habit accountability. It does not diagnose, treat, or cure.

12.2. Call open

Before we talk about a program, I need to be clear. I am a coach, not a physician and not a somnologist. I do not diagnose or treat. If safety flags appear, I will not sell. I will refer you to a somnologist or licensed physician.

12.3. Close (process only)

If you enroll, you are buying coaching time, a behavioral program, and accountability. You are not buying a medical result. Results vary. No hours-slept or symptom outcome is promised.

12.4. Self-label reply

Use clause 9.2.

13. Pre-publication checklist (speech)

• [ ] Every health-adjacent claim has document 06 language next to it, not footer-only.
• [ ] No diagnose / treat / cure / prescribe verb.
• [ ] No scoring tool and no diagnosis quiz.
• [ ] No white coat, caduceus, "Dr.," "clinical," "patient," "treatment plan."
• [ ] Guarantee, if any, is process/effort only. Physiological outcome guarantees absent.
• [ ] Scarcity is real capacity, written as a number the operator can defend that day.
• [ ] Testimonials, if any, have consent and no disease-cure claim (and a counsel leftover-risk note is honest).
• [ ] 18+ stated. UK/EU not targeted.
• [ ] No "cheaper than a sleep lab" close.
• [ ] CBT-I, if mentioned, has the clause 5.2 sentence.
• [ ] Conduct-over-label tests in 7.2 are all "no."

14. Evidence status / Confidence / Residual uncertainty

Evidence status. Scope is a domain control, not a regulator ruling. Statute names used as commonly accepted: Medical Service Act (의료법) for unlicensed practice and medical advertising; Act on Fair Labeling and Advertising (the Korean truth-in-ads law) and KFTC backdrop for claims; FTC Act §5, FTC Health Products Compliance Guidance, and FTC Endorsement Guides for US-facing speech; state unlicensed practice of medicine (varies). No counsel memo is attached. CBT-I is described in public literature as a clinical treatment. This draft treats clinical CBT-I as outside scope without citing a specific paper as a legal authority.

Confidence. High that diagnose / treat / cure / prescribe must be banned for this model. High that process/effort guarantees are the only guarantee class this domain will allow to be discussed. High that conduct-over-label is the conservative test. Medium that every CBT-I-adjacent habit phrase will survive Korean MSA advertising review. That is why counsel mark-up is a launch condition.

Residual uncertainty.

1. Korean enforcement posture on English-language coaching by a Seoul operator is not a decided case in this file.
2. State UPL lines in the United States vary. This document cannot pre-clear fifty states.
3. Whether a particular wearable screenshot in a sales page is an implied diagnostic claim is fact-specific. Default: do not use it as proof of a disorder or a cure.
4. Nutrition, supplements, and devices remain out of scope. A future expansion needs a new draft and counsel, not a quiet SKU.
5. This document is not licensed legal advice and is not a substitute for Korean MSA/PIPA/KFTC counsel and US FTC/health-coaching counsel. PIPA is the Personal Information Protection Act (개인정보 보호법), the Korean personal-information law.

CLIENT SERVICE AGREEMENT

The Practice - Behavioral Sleep Improvement Coaching

Document: 07-Client-Service-Agreement Version: Blue Book v0.1-DOMAIN-DRAFT Effective date: 20 August 2026 (KST) Status: Domain draft for counsel residual. The public-use stop rule is still on until sign-off. Do not use this at live checkout. Schedule A / Section 9 rewrite: 20 August 2026 (KST). Carries Protocol Completion Guarantee v1 (Monash). The client-binding instrument is this CSA. Offer architecture is the commercial source. Consumer Law sits above both. Contracting party (until a separate, correctly coded registration exists): 이성재, a natural person resident in Seoul, Republic of Korea (the "Coach"). Intelligent Solutions is the other business and is not the Coach. Service name: the Practice.

Plain summary (for Emperor Livingstone)

This is the paid coaching contract. The contracting party is 이성재, a natural person in Seoul. Intelligent Solutions is the other business and is not this contract. Display name Livingstone is not a legal-name change. The work is coaching, not medicine, and no sleep-hour or "cured" result is promised. You get the stated live Sessions, two named diary replies each week (about 15 minutes each), a 24-hour weekday reply rule, and extra notes rolled to the next weekly Zoom. The only product money path is Protocol Completion Guarantee v1: four effort conditions, then either two extra 45-minute Sessions or a refund of unused Sessions if you leave after Week 2 and before Week 6, split across 9 cash touchpoints. After Week 6 that path is extra Sessions only. Adults 18 and over, no UK, EU, EEA, or Switzerland, and tax invoice words stay options only. The public-use stop rule is still on.

This Client Service Agreement (this "Agreement") is a legally binding contract. Read it before you pay, book, or attend any Session. If you do not agree, do not purchase and do not attend.

1. Parties

1.1 Coach. 이성재, a natural person, operating the Practice from Seoul, Republic of Korea, at [ADDRESS], email [EMAIL], telephone [PHONE] (the "Coach"). The Coach is the contracting party until a successor legal entity is formed and this Agreement is assigned under Section 22.

1.2 Client. The adult individual whose name, date of birth, and contact details appear in the signature block or electronic checkout record (the "Client").

1.3 The Practice. The Coach's Behavioral Sleep Improvement Coaching service, delivered fully online in English. "The Practice" is a service name, not a closed corporate name and not a representation that a company has been incorporated.

1.4 The Coach is 이성재 as a natural person. Intelligent Solutions is the Coach's other business and is not a party to this Agreement. Formation of a later, separately coded sleep registration, a company, or a US entity remains open and requires a dated writing from the Coach. See Section 21 (Governing Law Options) and Section 22 (Assignment).

2. Defined Terms

In this Agreement:

"Accountability" means the Coach's follow-up on the Client's agreed daily habits, including check-ins, reminders, and review of submitted logs. It is not clinical monitoring, not a safety-net, and not emergency care.

"Allowed Countries" means the United States, Canada, Australia, New Zealand, Singapore, and Korea (English-language delivery only). The United Kingdom, the European Union, the European Economic Area, and Switzerland are excluded until Legal lifts the GDPR-and-CAP stop rule. That lift is the only way those places may be added. Adding UK/EU is an escalation to Napoleon.

"CSA" means this Client Service Agreement.

"Confidential Information" means non-public information either party discloses in connection with the Program, including coaching notes, habit logs, and personal circumstances. It does not include information that is public other than by breach, independently developed, or required to be disclosed by law.

"Consumer Law" means any mandatory, non-waivable right of a consumer under the law of the Republic of Korea (including the Act on Consumer Protection in Electronic Commerce, Etc. and the Framework Act on Consumers, to the extent they apply) or under any other law that cannot lawfully be contracted away.

"Fees" means the Program price and any stated taxes or processor charges described in Section 8 and on the applicable checkout page.

"Fit Work" means matching Program habits and schedules to the Client's stated lifestyle, work pattern, and constraints. It is not a medical assessment and not a diagnosis of fitness for any activity.

"Homework" means the written or logged tasks the Coach assigns for a Session interval (for example, wind-down logs, agreed habit checklists, or reflection notes). Homework is effort evidence. It is not a clinical record.

"Information Work" means the Coach providing research-backed, general sleep-related educational information. It is not medical advice, not a diagnosis, and not a treatment plan.

"Program" means the named coaching container purchased by the Client, described on the checkout page or in Schedule A, including the stated Session count, delivery method, and term.

"Red Flag" means any fact, statement, or screening answer that, under the Practice's stop-sale rules, means coaching must not start or must stop, including suspected medical emergency, sleep apnea or other untreated medical sleep disorder indicators that require physician care, active suicidality, or any condition the Coach is not competent or licensed to address.

"Session" means a scheduled live coaching meeting delivered by video, of the duration stated in Schedule A or the checkout page.

"Sensitive Personal Information" has the meaning given under the Personal Information Protection Act of the Republic of Korea ("PIPA") and, for this Program, includes health-related and sleep-symptom information. Collection requires a separate signed consent (document 11) and is not authorized by this Agreement alone.

"Website" means [WEBSITE URL] and any successor site operated by the Coach for the Practice.

3. Recitals

A. The Client wants structured help with sleep-related daily habits. That help is information, lifestyle fit, and accountability. It is not medical care.

B. The Coach does three things only: (1) research-backed sleep information; (2) fitting the program to the Client's lifestyle; and (3) following up on daily habits. The Coach does not examine, diagnose, treat, prescribe, or practice medicine.

C. The Client states that the Client is 18 or older, is in an Allowed Country at purchase and for the whole Program, and will keep a treating physician (or equivalent licensed clinician) for any health concern.

D. This Agreement covers the paid coaching relationship only. Reading the Website does not make you a client. Buying the Program does not make the Coach your physician, therapist, or other licensed clinician.

E. These recitals are part of the Agreement.

4. Nature of the Service (Coaching, Not Medicine)

4.1 Scope. The Coach will deliver the Program as behavioral coaching. The only in-scope actions are Information Work, Fit Work, and Accountability.

4.2 Out of scope. The Coach will not: diagnose any sleep disorder or other condition; interpret sleep studies, wearable clinical scores, or laboratory results as a clinician; prescribe or recommend prescription drugs, controlled substances, or specific medical devices as treatment; claim to treat, cure, or manage insomnia disorder, sleep apnea, narcolepsy, restless legs, parasomnias, depression, anxiety, or any disease; provide emergency, crisis, or on-call medical or psychiatric care; or hold out the Program as a substitute for physician, dentist, psychologist, or other licensed care.

4.3 Not a covered entity. The Practice is not a HIPAA covered entity and does not claim to be "HIPAA-compliant." Do not send the Coach medical records expecting hospital-grade or HIPAA-covered handling.

4.4 Disclaimer document. The medical and advertising disclaimers published on the Website and in the Blue Book disclaimer pack are incorporated by reference. If those documents and this Agreement conflict on a health claim, the stricter "no medical advice / no outcome guarantee" reading controls.

4.5 No results promise. The Coach does not warrant that the Client will fall asleep faster, sleep a stated number of hours, improve any wearable score, or experience any physiological change. Sleep is biological and individual. Coaching is process and effort.

5. Term, Sessions, and Delivery

5.1 Term. This Agreement starts on the later of (a) the Client's electronic acceptance and (b) the Coach's confirmation of payment, and ends on the earlier of (i) completion of the last scheduled Session plus any stated wrap-up period in Schedule A, (ii) termination under Section 12 or 13, or (iii) [PROGRAM END DATE / DURATION, e.g. 8 weeks from first Session].

5.2 Session count. The Program includes [SESSION COUNT] live Sessions, each approximately [SESSION LENGTH] minutes, unless Schedule A states otherwise.

5.3 Delivery. Sessions are delivered online by video using [VIDEO PLATFORM: Zoom / Google Meet or successor]. The Client is responsible for a working device, camera, microphone, and internet connection. The Coach is not liable for the Client's local connectivity failures.

5.4 Language. The Program is delivered in English only. The Coach is not obliged to provide Korean-language Sessions or Korean-language versions of Program materials, except where Consumer Law requires a particular notice in Korean.

5.5 Scheduling. The parties will book Sessions inside the Coach's published calendar windows. The Client should book the first Session within [BOOKING WINDOW, e.g. 14 days] of purchase. Unused Sessions remaining solely because the Client did not book inside the Term expire, except where Section 9 (Process Guarantee) or Consumer Law requires otherwise.

5.6 Rescheduling. The Client may reschedule a Session with at least 24 hours notice. Late cancels or no-shows count as a delivered Session unless the Coach, in discretion, offers a make-up. The Coach will give at least 24 hours notice of Coach-initiated cancels except for emergency, illness, or force majeure.

5.7 Recording. Sessions are not recorded by default. If either party wants a recording, both must consent in writing (email is enough) before the Session starts. The Client may not publish a recording.

5.8 Between-Session contact. Asynchronous Accountability is two (2) named diary replies per week, about 15 minutes each, in the shared doc. Reply SLA (this number does not change): 24 hours on weekdays (Monday-Friday, excluding Korean public holidays), measured in the Coach's published hours (Asia/Seoul) converted to the Client's time zone. Messages received on a weekend or holiday are answered the next weekday. This is not an emergency line and not 24/7 access. Extra Client notes overflow to the next weekly Zoom Session. They are not a third or fourth diary reply. A five-notes-per-week cap is withdrawn as of this dated rewrite (20 August 2026 KST, Napoleon stop rule). That stop rule keeps the two-reply week and does not bring back a five-note week.

6. Client Duties

6.1 Attendance. The Client will attend booked Sessions on time, or reschedule under Section 5.6.

6.2 Logging. The Client will submit agreed Homework and habit logs by the stated deadline. Logs are for Accountability and Fit Work only.

6.3 Honesty. The Client will answer screening and coaching questions honestly, including Red Flag questions. Material concealment that would have triggered a stop-sale is a breach and a basis for termination without a results-based refund.

6.4 Physician care. The Client will maintain an appropriate licensed clinician for health concerns and will not treat the Coach as a substitute. The Client will seek emergency care for chest pain, severe breathlessness, thoughts of self-harm, sudden neurological change, or any other emergency.

6.5 No self-experiment that the Coach did not assign. The Client will not start, stop, or change prescription medication, CPAP or other prescribed device use, or medical treatment because of something said in a Session. Lifestyle-habit experiments stay inside what the Client and the Client's clinician consider safe.

6.6 Location and age. The Client warrants the facts in Section 14 (Age) and Section 16.3 (Geo).

6.7 Respectful conduct. The Client will not harass, record secretly, scrape Program materials for a competing product, or use Sessions to obtain a medical opinion the Coach is not giving.

6.8 Sensitive data. The Client will not send sleep-symptom or other health information until the Client has signed the standalone Sensitive Personal Information Consent Form (document 11) and the Coach has confirmed in writing that the collection stop rule is off for this Client (that written confirmation is the only way collection may start). Until then, screening is limited to the non-sensitive items the Coach specifies.

7. Coach Duties

7.1 The Coach will: deliver the stated Sessions and Accountability with reasonable professional care for a coach (not the standard of a physician); prepare using the Client's submitted logs when those logs arrive on time; keep Confidential Information under Section 17; apply Red Flag / stop-sale rules even if that means refusing or ending a sale; and avoid physiological outcome promises in Sessions, messages, and marketing.

7.2 The Coach may use contractors (for example, a scheduler or a payment processor) but remains responsible to the Client for the coaching obligations in this Agreement, subject to Section 19.

7.3 The Coach does not guarantee personal availability outside published hours.

8. Fees, Taxes, and Payment

8.1 Price. The Client will pay [PRICE] [CURRENCY] for the Program (the "Fees"), as shown at checkout on [CHECKOUT DATE / INVOICE NUMBER].

8.2 When due. Fees are due in full before the first Session, unless a written payment plan in Schedule A states otherwise. A payment plan is a timing accommodation, not an outcome guarantee and not a "pay only if you sleep well" arrangement.

8.3 Processor. Payment is collected by [PAYMENT PROCESSOR, e.g. Stripe] or a successor processor. The Client's card or wallet agreement with the processor also applies. The Coach does not store full card numbers.

8.4 Taxes (options only; do not invent invoice copy). Whether Korean VAT attaches to a USD invoice issued by a Seoul-resident natural person, and whether any price is VAT-inclusive or VAT-exclusive, is not a closed decision. Options for later counsel or a CPA: (A) no Korean VAT line pending written advice; (B) VAT exclusive, shown as a separate line if required; (C) VAT inclusive, only if counsel or a CPA writes the rate and the invoice words. Do not print a VAT sentence on an invoice, checkout page, or Schedule A until that advice exists. The Client is responsible for tax the Client's home jurisdiction imposes, except where the Coach is legally required to collect it.

8.5 Chargebacks. The Client agrees to contact [EMAIL] and use Section 9 and document 13 before filing a chargeback for a covered coaching dispute. This sentence does not waive any non-waivable chargeback or Consumer Law right. Fraudulent or bad-faith chargebacks (for example, claiming non-receipt after attending Sessions) may be contested with Session logs and this Agreement.

8.6 No hidden add-on medical products. The Fees do not include supplements, mattresses, devices, clinic referrals for a fee, or pharmacy arrangements. The Coach will not upsell a product as if it were part of a treatment plan.

8.7 Honest scarcity. Any "limited seats" or cohort language is true calendar or capacity scarcity only. If a scarcity statement later proves operationally false, the Client may ask for the remedy in document 13. Fake countdown scarcity is not used.

9. Process and Effort Guarantee (Only)

Dated rewrite: 20 August 2026 (KST). This Section now carries Protocol Completion Guarantee v1 from the offer architecture. The prior coach-miss / coach-cannot-continue frame is kept and is not the only path.

9.1 What this guarantee is. This Section is a service-and-effort guarantee. It is the only guarantee in this Agreement. It is not a sleep-result guarantee, not a money-back-if-still-tired guarantee, and not a "win your money back when you sleep X hours" offer.

9.2 Coach-miss remedy. If the Coach cancels a booked Session and does not offer a make-up inside 14 days, the Client may choose one of the following for that missed Session:

(a) a refund of the unused prepaid portion allocated to that Session under the 9.4 allocation; or (b) one extra Accountability Session of the same length, booked in good faith.

9.3 Coach-cannot-continue. If the Program ends early solely because the Coach cannot continue (illness of extended duration, assignment failure, or Coach-initiated discontinuation other than a Client breach or Red Flag stop), the Client is entitled to a pro-rata refund of unused prepaid Sessions under the 9.4 allocation. The Homework condition does not apply to a Coach-initiated convenience stop (Section 13.2).

9.4 Protocol Completion Guarantee v1 (client-exit, effort-gated). For The Night Protocol Intensive (and any Program whose Schedule A says "Protocol Completion Guarantee v1"), the following applies. All four effort conditions must be true:

(a) the Client attended every scheduled Session or rescheduled with 24 hours notice; (b) the Client logged the diary at least 6 of 7 nights each week of the Term then elapsed; (c) the Client ran the written protocol as assigned; and (d) the Client still believes the container was not delivered as described.

Remedy (choose ONE), claimed within 14 days of the last held Session:

1. two extra 45-minute Sessions in the following 30 days; or
2. a refund of unused remaining Sessions if the Client exits after Week 2 and before Week 6.

Unused means Sessions not yet held. Week 0 and held weekly Sessions are earned. Offboarding is earned work. It is not in the unused-session fraction.

Allocation key (core Intensive). Cash allocation touchpoints = 9 (Week 0 + 8 weekly Sessions). Example: exit after the Week 3 Session has been held: 4 earned (Week 0, 1, 2, 3), 5 unused; unused cash = 5/9 of Fees actually paid for the core. High-Stakes Week Add-On, if purchased, is allocated separately and is not inside this 9-part fraction.

After Week 6: no cash refund under this 9.4 path. Extra Sessions only, and only if the four effort conditions were met.

If effort conditions were not met: no extra Sessions and no 9.4 refund. The Coach will send a written recap of the missed conditions.

9.5 What is never a refund trigger. The following are not defects, not breaches, and not refund events under this Agreement:

(a) the Client still does not sleep a stated number of hours; (b) the Client still feels unrested, still wakes at night, or still has a "bad" wearable or sleep-app score; (c) insomnia, apnea, or any other condition is not "cured," "treated," or "gone"; (d) a third-party clinician disagrees with a lifestyle habit the Coach discussed; (e) the Client expected a medical result from coaching.

9.6 Banned guarantee language (operative). The Coach does not offer, and the Client acknowledges that the Client has not been promised, any of the following: unconditional or conditional refunds tied to hours slept; "service until you fall asleep" or "service until a sleep metric moves"; "cured insomnia or refund"; win-your-money-back on a physiological result; sleep-latency, sleep-efficiency, or WASO guarantees; or any medical-result warranty. If marketing copy ever conflicts with this Section, this Section controls as between the parties, and the Client should report the copy to [EMAIL].

9.7 Testimonials are never a refund condition. The Client is not required to leave a review, film a testimonial, post on social media, or permit use of the Client's name in order to receive any refund, credit, or make-up that this Agreement or Consumer Law provides. See Section 15.

9.8 How to claim. Email [EMAIL] with the Session dates, the path claimed (9.2, 9.3, or 9.4), and the effort evidence for 9.4. The Coach will respond within 10 business days. Approved refunds are returned to the original payment method when the processor allows, or otherwise by a mutually agreed method.

9.9 Goodwill (do not advertise). The Coach may issue a goodwill refund outside 9.2 to 9.4. A goodwill payment is not a new product feature, not a sleep-result warranty, and must not appear on the Site, a fit call, or an ad. Each goodwill payment is logged for Operations and Legal.

9.10 Anti-guarantee overlay. The Practice does not enroll a person who needs a medical or sleep-outcome promise to start. That refusal is a successful screen. It is not a refund event.

9.11 Which instrument wins. For a live Client: (1) mandatory Consumer Law, including Korean e-commerce withdrawal if that Act applies; (2) this Section 9 and Schedule A of this CSA; (3) document 13; (4) offer architecture / checkout; (5) marketing. Offer architecture is the commercial source of v1. This dated CSA is the client-binding rewrite. Marketing loses.

10. Consumer-Mandatory Savings Clause

10.1 Nothing in this Agreement, the Website Terms of Use, any guarantee, any "all sales final" sentence, or any other Practice document limits, waives, or asks the Client to waive a mandatory right the Client has under Korean Consumer Law, the Act on Consumer Protection in Electronic Commerce, Etc. (if that Act applies to this sale), or any other non-waivable law of a competent jurisdiction.

10.2 Residual uncertainty is expressly reserved: an English-only, fully online sale by a Seoul-resident natural person may still be an electronic-commerce transaction under Korean law. The Coach will not pretend that the English-only character of the sale creates an exemption. If a cooling-off or withdrawal right applies to the Program as a digital service, the Coach will honor that right for eligible transactions on the terms the statute requires. Operational detail sits in document 13.

10.3 If a court or agency holds a clause unenforceable because it conflicts with Consumer Law, that clause is modified to the minimum extent needed, or severed, and the rest of this Agreement continues.

10.4 Where Consumer Law gives a more favorable remedy than Section 9, the Client receives the statutory remedy. Section 9 is an additional process guarantee, not a substitute that cuts down a mandatory right.

11. Red Flag, Stop-Sale, and Referral Cooperation

11.1 The Coach may refuse to enroll, or may suspend or end the Program, if a Red Flag is present or reasonably appears to be present. Examples include: the Client describes symptoms that indicate a need for urgent medical or psychiatric care; the Client seeks a diagnosis or a treatment plan; the Client is under 18; the Client is in a non-Allowed Country; the Client wants a physiological guarantee as a condition of purchase; or the Client will not keep physician care for a disclosed serious condition.

11.2 A stop-sale or stop-program decision is a safety and scope decision. It is not a medical diagnosis. The Coach may say "this is outside coaching and you should speak with a clinician" without naming a disease as a concluded diagnosis.

11.3 If the Coach stops the Program under this Section before any Session, Fees actually received will be refunded in full, minus any non-refundable processor cost only if Consumer Law allows that deduction. If Sessions have already occurred, unused prepaid Sessions are refunded on the Section 9.3 allocation, without any requirement that the Client produce a testimonial.

11.4 Referral cooperation. The Coach may provide a generic suggestion that the Client contact a licensed physician, sleep clinic, or crisis line. The Coach does not receive a fee for such a suggestion, does not endorse a named clinic unless a separately lawyered protocol exists, and does not arrange treatment. The Client is responsible for choosing and paying any clinician.

11.5 The Client agrees to cooperate with a stop-sale: to stop sending Sensitive Personal Information after termination, and not to characterize the stop as the Coach "refusing to treat" a disease.

12. Termination by the Client

12.1 The Client may stop attending at any time. Stopping attendance is not, by itself, a refund event except under Section 9 (including Protocol Completion Guarantee v1) or Consumer Law.

12.2 A request to terminate should be sent to [EMAIL]. The Coach will confirm the end date, any unused-Session calculation, and any statutory cooling-off analysis that applies.

13. Termination by the Coach

13.1 The Coach may terminate immediately for: material breach of Section 6 or 16; a Red Flag under Section 11; abusive conduct; non-payment; or legal or regulatory risk that makes continued coaching unreasonable.

13.2 For convenience, the Coach may terminate with [CONVENIENCE NOTICE, e.g. 7 days] written notice and a pro-rata refund of unused prepaid Sessions (Homework condition in 9.3 does not apply to a convenience termination initiated by the Coach).

14. Age Warranty (Adults 18+ Only)

14.1 The Client warrants that the Client is 18 years of age or older on the date of purchase and on each Session date.

14.2 The Practice does not coach minors. Parental or guardian consent does not create an exception. This is a scope decision, not a comment on any particular minor's maturity.

14.3 The Client will complete the age gate (self-attestation and date of birth) before email capture, booking, or purchase. Social-login age claims are not accepted as a substitute.

14.4 If the warranty is false, the Coach will terminate, delete personal information as required by the Age Gate and Minors Policy (document 12) and the Privacy Notice, and will not retain the person for marketing. Fees for unused Sessions will be returned except to the extent Consumer Law or fraud law requires a different handling.

15. Testimonials (Optional; Never a Refund Condition)

15.1 The Coach may invite a testimonial after the Program. The invitation is optional. Refusal has no effect on refunds, make-up Sessions, or future eligibility.

15.2 Any testimonial, if given, must be the Client's honest experience, must not claim that the Program diagnosed, treated, or cured a condition, and requires a separate written consent before public use.

15.3 The Coach will not require a public post, review, or video as a condition of any guarantee, credit, or "win-back."

16. Client Representations

16.1 The Client has read this Agreement and the Privacy Notice, and (if Sensitive Personal Information will be provided) the Sensitive Personal Information Consent Form.

16.2 The Client is buying coaching for the Client's own personal use, not to resell the Program or to train a competing coach on the Practice's materials.

16.3 The Client is physically located in an Allowed Country at purchase and will not attend Sessions from the United Kingdom, the European Union, the European Economic Area, or Switzerland unless and until the Coach has published a written lift of the GDPR-and-CAP stop rule. The Client will tell the Coach if the Client relocates into a restricted geography.

16.4 The Client is not purchasing on behalf of a minor.

17. Confidentiality and Data

17.1 Each party will use the other's Confidential Information only to perform this Agreement and will not disclose it except to personnel and processors who need it, or as required by law.

17.2 The Privacy Notice (document 09) describes personal-information handling. This Agreement does not itself authorize collection of Sensitive Personal Information.

17.3 The Coach may disclose information if required by law, court order, or to prevent reasonably apparent serious harm, and will limit the disclosure to what is required.

17.4 Coaching notes belong to the Coach as business records, subject to the Client's access and deletion rights under PIPA and the Privacy Notice.

18. Intellectual Property

18.1 The Coach retains all intellectual property in Program materials, frameworks, worksheets, recordings (if any), and the "the Practice" name as used for this service. The Client receives a personal, non-transferable, non-sublicensable license to use those materials for the Client's own habit work during the Term and thereafter for personal, non-commercial use.

18.2 The Client shall not copy the Program for a course, book, or competing coaching offer, or scrape or republish Session content.

18.3 User content the Client submits (logs, comments) may be used by the Coach to deliver the Program. Public use of identifiable Client content requires the Section 15 consent.

19. Limitation of Liability

19.1 Coaching context. The Program is educational coaching. The Client, not the Coach, decides whether to adopt a habit and whether that habit is safe for the Client's body.

19.2 Cap. Subject to Section 19.4 and Section 10, the Coach's aggregate liability arising out of this Agreement is limited to the Fees actually paid by the Client for the Program that gives rise to the claim.

19.3 Excluded categories. Subject to Section 19.4 and Section 10, the Coach is not liable for indirect, incidental, special, or consequential loss; lost profits or lost business opportunity; or loss arising from the Client's failure to obtain medical care, from a wearable or app score, or from a physiological result the Client hoped for.

19.4 What this cap does not do. This Section does not exclude or limit liability for death or personal injury to the extent a governing law forbids that exclusion; for fraud or fraudulent misrepresentation; for gross negligence or willful misconduct to the extent non-waivable; or for any liability that Consumer Law or other mandatory law does not allow to be limited. This Section does not ask the Client to waive bodily-injury claims where that waiver is forbidden.

19.5 No HIPAA badge; no clinical standard. The Coach is not to be judged against a physician's, psychologist's, or sleep-specialist's standard of care. The relevant standard is that of a reasonably careful behavioral coach delivering Information Work, Fit Work, and Accountability.

19.6 Time to claim. To the extent permitted by law, any claim must be notified to [EMAIL] within [CLAIM PERIOD, e.g. 12 months] after the facts giving rise to it were known or reasonably knowable, without shortening a longer mandatory limitation period.

20. Indemnity

The Client will indemnify the Coach against third-party claims arising from the Client's republication of Program materials as if they were medical advice, the Client's breach of the age or geo warranties, or the Client's misuse of a Session recording, except to the extent caused by the Coach's willful misconduct. This indemnity does not reduce Section 10.

21. Governing Law Options (Still an Open Business Choice)

21.1 Purpose of this Section. Venue and governing-law choice will be revisited when (and if) a legal entity is formed. This draft does not close incorporation and does not close a long-term venue strategy.

21.2 Option A (default text of this draft). This Agreement is governed by the laws of the Republic of Korea, without regard to conflict-of-law rules that would choose another law. Subject to Section 10 and to any non-waivable consumer-forum right, the courts of Seoul, Republic of Korea, have jurisdiction. Option A is the operative text until a signed amendment or a successor-entity assignment states otherwise. Using Option A in this draft is a temporary default. It is not a final business decision that Seoul is the permanent exclusive venue.

21.3 Option B (reserved, not operative). If the Coach later assigns this Agreement to a formed entity under Section 22, the parties may amend governing law to the law of the entity's state or country of organization, and may amend venue to courts of that place, still subject to Section 10 and to any mandatory consumer forum. Option B has no effect until a written amendment or assignment instrument activates it.

21.4 The Coach will not use a later entity to strip a mandatory consumer right that attached to the original sale.

21.5 Informal resolution: the parties will try a good-faith written discussion for at least [DISPUTE WINDOW, e.g. 14 days] before filing, except for injunctive relief or where delay would cause serious harm. This is not a mandatory arbitration clause.

22. Assignment to a Successor Entity

22.1 The Coach may assign this Agreement, in whole or in part, to a company, limited-liability entity, or other vehicle that 이성재 organizes or causes to be organized to operate the Practice (a "Successor Entity"). The Client consents in advance to that assignment. The Coach will give notice to [the Client's email on file] stating the Successor Entity's legal name, [ADDRESS], and the effective date.

22.2 After assignment, the Successor Entity assumes the Coach's obligations that remain to be performed. 이성재 may remain a performer (the same human coach) without remaining the contracting party.

22.3 The Client may not assign this Agreement without the Coach's prior written consent, except to the extent Consumer Law requires a different rule.

22.4 Assignment does not itself change Fees, Session count, or the process-only character of Section 9.

23. Electronic Signatures and Formation

23.1 This Agreement may be accepted by electronic signature, typed name, checkbox-plus-date at checkout, or any other electronic method that identifies the Client and shows intent to be bound.

23.2 A checkout record, payment confirmation, and stored acceptance timestamp are evidence of formation. A wet-ink counterpart is not required.

23.3 The Client consents to receive notices under this Agreement by email to the address the Client provides. Notice to the Coach is effective when received at [EMAIL].

24. General

24.1 Entire agreement. This Agreement, Schedule A (if issued), the Privacy Notice as it applies to Program data, the Sensitive Personal Information Consent Form if signed, and any written amendment, are the entire agreement for the Program. Website marketing copy does not add a physiological guarantee.

24.2 Amendments. Changes must be in writing (email is enough) and accepted by both parties, except that the Coach may update operational details (platform name, hours) by notice if they do not reduce the Client's Sessions or enlarge Fees.

24.3 Severability. If a provision is held invalid, the remainder stays in force, and Section 10 applies.

24.4 Waiver. A failure to enforce a provision is not a waiver of future enforcement.

24.5 Force majeure. Neither party is liable for delay caused by events beyond reasonable control (including outage of the video platform, war, epidemic, or government action), provided they give prompt notice and resume when feasible. Fees already earned for delivered Sessions stay earned; unused prepaid Sessions remain subject to Section 9.

24.6 No third-party beneficiaries. Except a Successor Entity after assignment, no third party may enforce this Agreement.

24.7 Relationship. The parties are independent contracting parties. This Agreement does not create a partnership, employment, or joint venture.

24.8 Counterparts. Electronic counterparts are originals.

24.9 Order of documents. For a conflict about a refund or guarantee, the order is: (1) Consumer Law; (2) Section 9 and Schedule A of this Agreement; (3) Section 10; (4) document 13; (5) offer architecture and checkout page; (6) marketing copy. Marketing copy loses. Offer architecture does not outrank this dated CSA.

24.10 Language. The English text controls, except where a mandatory Korean-language notice is required. If a Korean translation is later supplied, the mandatory Korean notice prevails for that notice only.

25. Acknowledgment of No Medical Advice

By signing, the Client acknowledges:

(a) the Practice provides coaching, not medicine; (b) the Client will not use Sessions as a substitute for licensed care; (c) no sleep-hour, sleep-score, or "cure" result has been promised; (d) testimonials, if any, are optional and are not a price of any refund; and (e) the Client is 18 or older.

Schedule A - Program Particulars (The Night Protocol Intensive default)

Rewrite dated 20 August 2026 (KST). This Schedule carries Protocol Completion Guarantee v1. Per-sale checkout may copy these values. It may not add a physiological guarantee.

Schedule A may be generated by the checkout system. If a field is blank, the corresponding body clause or the checkout page captured at purchase supplies the value. A checkout page may not invent tax copy or an outcome guarantee.

Signature Block

Coach

Name: 이성재 Capacity: Natural person operating the Practice; assignable to a Successor Entity Address: [ADDRESS] Email: [EMAIL] Signature: _ Date: _ (KST)

Client

Legal name: [CLIENT LEGAL NAME] Date of birth (YYYY-MM-DD): [CLIENT DOB] (must show age 18+) Country of location at purchase: [CLIENT COUNTRY] Email: [CLIENT EMAIL] I am 18 or older: [ ] Yes I have read Sections 4, 9, 10, 11, and 14: [ ] Yes I understand this is coaching, not medical care, and that no physiological outcome is guaranteed: [ ] Yes Signature (typed name is enough if this is an electronic acceptance): _ Date: _ (KST)

Electronic-acceptance substitute: a checkout checkbox that displays the above acknowledgments, plus a stored timestamp, IP or device record, and payment reference, binds the Client as a signature.

Evidence status / Confidence / Residual uncertainty

Evidence status. This instrument is a Blue Book v0.1-DOMAIN-DRAFT complete contract text. It is not counsel-signed, not court-tested, and the live-checkout stop rule is still on. Facts used: founder 이성재 as natural-person contractor in Seoul; English-only online coaching; three-action scope; 18+; process/effort guarantee only; PIPA-sensitive data carved out to document 11; Consumer Law savings clause included because Korean e-commerce residual applies.

Confidence. Medium as a working draft that a Korean-qualified lawyer can mark up. Low as a "ready to take payment" document. Governing-law Option A is a draft default only.

Residual uncertainty. (1) Whether the Act on Consumer Protection in Electronic Commerce, Etc. applies to English-only digital coaching sold by a Seoul natural person, including cooling-off and confirmation-document duties. This draft assumes it may apply and refuses an English-only exemption story. (2) Whether any destination-country consumer law also attaches if the Client is abroad (Allowed Countries list still open). (3) VAT/tax on USD invoices from a Seoul natural person is options-only (Section 8.4). Do not invent copy. Processor not yet chosen. (4) Video-platform data processing addenda not yet executed. (5) Successor-entity assignment should be re-papered at formation, including whether Option B should activate. (6) Whether any Session recording consent needs a separate Korean-language notice. (7) Limitation-of-liability enforceability against consumers is jurisdiction-specific; Section 19.4 and Section 10 are the residual, not a guarantee of the cap. Counsel residual required before first paid enrollment.

PRIVACY NOTICE

The Practice - Behavioral Sleep Improvement Coaching

Document: 09-Privacy-Notice Version: Blue Book v0.1-DOMAIN-DRAFT Effective / last updated: 20 August 2026 (KST) Status: DORMANT AS TO COLLECTION. This notice is drafted so the Practice can be clear when the collection stop rule is later lifted. It does not itself lift that stop rule. No personal information (other than strictly necessary technical transmission that a web server cannot avoid) will be collected for leads, coaching, analytics, or advertising until (a) domain sign-off, (b) counsel residual, (c) the Cookie and Tracking Decision Record allows the relevant technology, and (d) for Sensitive Personal Information, the standalone consent in document 11 is signed after enrollment. The collection stop rule is still on. Controller (until a separate, correctly coded registration exists): 이성재, a natural person, Seoul, Republic of Korea. Intelligent Solutions is the other business and is not the controller. Privacy officer (solo): 이성재 Contact: [EMAIL] | [ADDRESS] | [PHONE] Website: [WEBSITE URL]

Plain summary (for Emperor Livingstone)

This notice explains how personal information would be handled later. It does not start collection. The collection stop rule is still on. The controller is 이성재, a natural person in Seoul. Intelligent Solutions is the other business. Display name Livingstone is not a legal-name change. Korean privacy law comes first, and GDPR or California wording is readiness only, not an offer to the UK, EU, or EEA, and not a sale of data. Health and sleep-symptom data need a separate form (document 11). No advertising pixels, no analytics until document 10 says the cookie stop rule has ended, no automated diagnosis, and no HIPAA badge. Do not send symptom stories or sleep-study files until the collection stop rule is off and document 11 is signed.

PIPA-first. GDPR-ready language is included for a later lift of the UK/EU/EEA stop rule and does not mean the Practice currently offers services to the UK, EU, or EEA. CCPA-ready language is included for California residents if and when they are in the Allowed Country list and the collection stop rule is off. The Practice does not sell personal information.

1. Who Controls Personal Information

1.1 The controller (PIPA: personal information controller) is 이성재, resident in Seoul, Republic of Korea, operating the Practice as a natural person until a Successor Entity is formed and this notice is updated. Intelligent Solutions is a separate software and AI consulting registration and is not the controller for this Practice.

1.2 A Korean company, a US LLC, and a new sleep-coded registration are still not chosen. If a Successor Entity is later formed for this Practice, that entity is expected to become the controller. You will be notified as required by PIPA (and, if then applicable, GDPR).

1.3 The privacy officer is 이성재 at [EMAIL]. This is a solo practice. There is no separate Data Protection Officer appointment at this version. If volume, geography, or law later requires a formal DPO, this notice will be updated.

1.4 This notice covers the Website, booking and checkout (when the collection stop rule is off), email, video Sessions, and coaching administration. It does not cover third-party sites we link to.

2. Dormancy and Stop Authority

2.1 Until the collection stop rule is lifted, do not submit email addresses, dates of birth, health information, or payment details expecting a live Program. Any form that appears on a draft domain should be treated as closed. The collection stop rule is still on.

2.2 The founder can stop collection of any category at once. This notice will be revised or the relevant form taken down.

2.3 Strictly necessary technical data that a host writes to complete an HTTPS request (for example, a short-lived session cookie described in document 10) may exist before marketing collection starts. That is not a license to add pixels or analytics.

3. Categories of Personal Information

When the collection stop rule is lifted, the Practice may process the following categories. Fields in [BRACKETS] are not yet configured.

3.1 We do not seek racial or ethnic origin, political opinions, religion, sex life, or biometric templates. If you volunteer such data, we will delete it unless a legal duty requires a short retention of the incoming message.

3.2 We do not operate a public "sleep disorder quiz." Symptom data is collected only after enrollment, only with document 11, only on a channel we specify.

3.3 Wearable exports or sleep-study PDFs are not requested as a standard intake. If a Client later uploads one despite that rule, it is Sensitive Personal Information and is handled under document 11 or deleted.

4. Purposes and Legal Bases (Mapped)

The following table states why we would process each category after the collection stop rule is lifted, and the legal basis we expect to rely on. PIPA is the primary regime. GDPR Articles 6 and 9 are listed for readiness only. They are not an offer of EU/UK services. CCPA column: we do not sell or share for cross-context behavioral advertising.

4.1 "Legitimate interests analogue" under PIPA is used here as a plain-English label for processing that Korean law allows without a fresh consent when it is reasonably related to a contracted service or to security, or where a statutory basis exists. Where PIPA still requires consent, we will obtain it. This table is not a substitute for counsel's PIPA article-by-article mapping.

4.2 GDPR columns become operative only after a GDPR-and-CAP set is signed off and UK/EU/EEA geo-blocks are lifted. Until then, we do not rely on GDPR to justify targeting those regions.

4.3 CCPA / California: we do not sell personal information and we do not share it for cross-context behavioral advertising. We do not offer a "Do Not Sell or Share" toggle at this version because we do not sell or share. If that changes, a toggle and a 12-month lookback disclosure will be added before any sale or share.

5. Sensitive Personal Information (Health / Sleep Symptoms)

5.1 Under PIPA, health information is Sensitive Personal Information (민감정보). Sleep-symptom descriptions, Red Flag answers, medications, diagnoses you mention, and habit logs that reveal health conditions are treated as sensitive.

5.2 Separate consent is mandatory. The Client Service Agreement and this Privacy Notice are not that consent. The standalone Sensitive Personal Information Consent Form (document 11) is that consent.

5.3 Collection rules:

(a) only after enrollment is accepted (or as the last step of accepted enrollment, after age and geo gates); (b) only on the channel named in document 11; (c) never through a public quiz, lead magnet "diagnosis," comment box, or ad form; (d) only after counsel residual and founder sign-off that the collection stop rule is off; (e) minimum necessary for safety screen, program-fit (non-diagnostic), and Accountability.

5.4 No diagnostic use. We do not use sensitive data to name a disorder as a concluded diagnosis, to interpret a sleep study as a clinician, or to automate a clinical decision.

5.5 Refusal: you may refuse sensitive collection. Browsing public pages remains available. We cannot enroll you in the Program without a safety screen. That is a scope and safety rule, not a punishment.

5.6 Sensitive data is not used for advertising, lookalike audiences, sale, or sharing for cross-context ads.

6. How We Collect

6.1 Directly from you: age gate, checkout, emails, Sessions, assigned logs.

6.2 Automatically: strictly necessary session cookies and server logs, as document 10 allows. No fingerprinting. No advertising pixels. No analytics until the cookie stop rule for analytics ends.

6.3 From processors: payment success/failure tokens from [PAYMENT PROCESSOR]; meeting-join metadata from [VIDEO PLATFORM].

6.4 We do not buy marketing lists at this version. We do not scrape social profiles for health data.

7. Processors and Disclosures

7.1 We do not sell personal information.

7.2 We may disclose personal information to:

7.3 Each processor will be bound by a written arrangement appropriate to PIPA (and, if GDPR later applies, Art. 28). Until those contracts exist, the collection stop rule is still on.

7.4 We do not disclose Client files to other Clients. Group or cohort features, if ever offered, will get their own notice before launch.

8. Overseas Transfers (PIPA Cross-Border Language)

8.1 The Practice is run from the Republic of Korea. Some processors are, or are likely to be, located in or able to access data from other countries, including the United States.

8.2 Likely overseas (or overseas-accessible) processors:

• [PAYMENT PROCESSOR, e.g. Stripe] - payment. Location: [PROCESSOR COUNTRY, often United States and others].
• [VIDEO PLATFORM, e.g. Zoom or Google Meet] - Session audio/video and chat. Location: [VIDEO COUNTRY].
• [EMAIL PROVIDER] - mailbox and files. Location: [EMAIL COUNTRY].
• [HOSTING PROVIDER] - Site and logs. Location: [HOST COUNTRY].

8.3 PIPA overseas-transfer consent (to be presented as a distinct consent when the collection stop rule is lifted). When the collection stop rule is lifted, we will ask you to consent, separately from general privacy acceptance where PIPA requires it, to the transfer of your personal information to the processors and countries named above (as then finalized) for the purposes named in Section 4. You may refuse. Refusal of a transfer that is necessary to pay or to attend video Sessions means we cannot enroll you, because we have no Korea-only payment-and-video stack at this version. Browsing public pages does not require that consent.

8.4 Items we will state at the moment of that consent (PIPA-style): recipient name, recipient contact if required, destination country, purpose, items transferred, retention by the recipient, and the fact that you may refuse.

8.5 GDPR-ready note (dormant): if UK/EU/EEA services are later offered, we will add transfer tools (for example, standard contractual clauses) and a transfer register. Those tools are not in force for this version because those regions are geo-excluded.

8.6 We will not send Sensitive Personal Information to an advertising platform. Video and email processors may incidentally process Session content; we will configure recording to off by default (see Client Service Agreement).

9. Retention

9.1 We keep personal information only as long as needed for the purpose, then delete or irreversibly de-identify it, unless a longer legal period applies.

9.2 Withdrawal of sensitive-data consent means we stop new collection and delete or de-identify the sensitive items unless a statutory exception (for example, an ongoing refund dispute) requires a limited hold. Withdrawal does not automatically delete invoices required for tax law.

9.3 Marketing lists: we do not build one at this version. If we ever do, unused leads will not be kept indefinitely; a period will be stated before that program starts.

10. Your Rights (How to Exercise)

10.1 Korean / PIPA data-subject rights (primary). Subject to statutory exceptions, you may request:

(a) access to whether we process your personal information and to the record; (b) correction or deletion of inaccurate information; (c) suspension of processing; (d) withdrawal of consent; (e) explanation of automated decisions (we make none for diagnosis; see Section 13); (f) any other right PIPA then grants, including transmission / data portability if and when that right applies to this controller.

10.2 GDPR-ready rights (dormant, for a later lift of the UK/EU/EEA stop rule): access, rectification, erasure, restriction, portability, objection, and withdrawal of consent, plus the right to complain to a supervisory authority. These are not offered as an EEA/UK service promise at this version.

10.3 CCPA/CPRA-ready rights (if you are a California resident and we then meet applicability thresholds or we choose to honor them): know, delete, correct, and opt out of sale or sharing (we do not sell or share). We will not discriminate against you for exercising a privacy right. We do not use sensitive personal information for inferring characteristics for advertising.

10.4 How to exercise. Email [EMAIL] from the address we have on file, with the subject line "Privacy request," stating the right you want to use and enough information for us to find your record. We may need to verify identity (for example, confirming a purchase reference or date of birth we already hold). We will not demand a testimonial or extra data as a condition of honoring a right.

10.5 Timing. We aim to respond within the PIPA statutory period as then in force (treat [PIPA RESPONSE DAYS, e.g. 10 days / the statutory period] as the working target) and, if a later GDPR regime applies, within one month (extendable as that law allows). If we refuse, we will state the legal reason we rely on.

10.6 Complaints. You may also complain to the Personal Information Protection Commission (PIPC) of the Republic of Korea, or to any other authority that has jurisdiction. This notice does not require you to complain to us first, but we ask that you write to [EMAIL] so we can fix an error quickly.

10.7 Authorized agents (CCPA-ready): we will accept an agent request if the agent provides written authorization and we can still verify you, when that regime applies.

11. Children

11.1 The Practice is for adults 18 years of age or older. We do not knowingly collect personal information from anyone under 18.

11.2 We do not coach minors even with parental consent. Parental consent is not an on-ramp.

11.3 If we learn that a minor's information was collected, we will follow document 12: terminate any process, delete the personal information, and not retain it for marketing. If a parent or guardian contacts [EMAIL], we will treat that as a deletion request after identity checks.

11.4 Date of birth is collected at the age gate to enforce this rule, not to profile children.

12. Cookies and Tracking

12.1 See document 10 for the operative decision. Summary: strictly necessary cookies only; no advertising pixels; no Meta / Google Ads / TikTok pixels; no analytics until every condition in that record for ending the analytics stop rule is met; fingerprinting banned.

12.2 This Privacy Notice does not authorize a later pixel. A revised notice plus document 10 plus, if non-essential cookies are introduced, a cookie banner and consent log would be required first.

13. Automated Decision-Making (Diagnosis Ban)

13.1 We do not use automated decision-making to diagnose a sleep disorder or any other condition. That use is banned.

13.2 Age-gate and geo-gate may use simple rule checks (for example, "date of birth shows age under 18" or "IP country is in a blocked list"). Those are access-control rules, not medical decisions, and a human (이성재) can override an obvious error if you email [EMAIL].

13.3 We do not assign a "sleep score" that determines enrollment. Stop-sale / Red Flag decisions are human decisions.

13.4 We do not feed Client symptom narratives into a public generative-AI service. If a future private tool is considered, this notice will be updated before use, and diagnostic use will remain banned.

14. Security

14.1 We use reasonable administrative and technical measures appropriate to a solo online coaching practice: HTTPS on the Site, access limited to the founder, processor accounts with unique credentials, and no full card storage.

14.2 No method is perfectly secure. The Practice does not claim hospital-grade security and does not claim to be HIPAA-compliant.

14.3 If a personal-information breach occurs that PIPA (or any then-applicable law) requires us to notify, we will notify you and the relevant authority as those rules require.

15. Testimonials and Public Content

Optional testimonials are processed only with a separate consent. They are never a condition of a refund or of exercising a privacy right. You may withdraw publicity consent; we will stop new uses and, where feasible, remove the quote from the Site. Copies already in printed or third-party caches may take time to disappear.

16. Do Not Send Unsolicited Health Records

Until document 11 is signed and the collection stop rule is off, do not email sleep-study PDFs, medication lists, or symptom diaries. If you do, we may delete the attachment unread beyond what is needed to see that it should be deleted, and we will tell you not to resend.

17. Changes to This Notice

17.1 We may update this notice. The "Last updated" date will change. Material changes will be posted on the Site and, for Clients, emailed.

17.2 A change will not retroactively authorize a pixel, a sale of personal information, or diagnostic automated processing.

17.3 If a Successor Entity becomes controller, Section 1 will be rewritten with the entity's legal name and [ADDRESS].

18. International Visitors Outside Allowed Countries

If you browse from a geo-restricted region, do not submit forms. We do not want your personal information. Server logs may still record an IP. See documents 08 and 10.

19. Contact

Privacy officer: 이성재 (solo) Email: [EMAIL] Postal: [ADDRESS], Seoul, Republic of Korea Telephone: [PHONE]

Identity verification may be required before we discuss your file.

20. Short recap

• Controller today: 이성재, Seoul, natural person.
• PIPA first. GDPR/CCPA language is readiness, not a UK/EU offer and not a sale of data.
• Health / sleep-symptom data is sensitive. Separate form (document 11). No public quiz.
• No pixels. No analytics until document 10 says so.
• No HIPAA badge.
• No automated diagnosis.
• This notice is dormant. The collection stop rule is still on.

Evidence status / Confidence / Residual uncertainty

Evidence status. Complete PIPA-first privacy notice for Blue Book v0.1-DOMAIN-DRAFT, dated 20 August 2026. Controller and privacy officer: 이성재. Sensitive-data path deferred to document 11. Cookie path deferred to document 10. Sale/share: none. UK/EU/EEA default-excluded. HIPAA badge refused. Dormancy stated in the header and in Section 2.

Confidence. Medium as a structural notice a Korean privacy lawyer can mark up to article numbers. Low as an operative collection instrument: processor names, retention integers, hosting country, and the exact PIPA overseas-transfer consent UI are still [BRACKETS]. GDPR/CCPA columns are readiness text only.

Residual uncertainty. (1) Precise PIPA article mapping (consent vs. statutory exception vs. "legitimate interests analogue") needs Korean counsel; this draft uses plain-English bases. (2) Whether overseas-transfer consent must be collected as a standalone checkbox in addition to document 11. (3) Tax and commercial retention periods for a natural-person coach in Seoul. (4) Whether CCPA applies at all (thresholds, California Clients on the Allowed list). (5) Processor DPAs not executed; the collection stop rule stays on until they are. (6) PIPC guidance on health-adjacent coaching notes may treat more habit logs as sensitive than this table assumes; when in doubt we treat them as sensitive. (7) If the Act on Promotion of Information and Communications Network Utilization and Information Protection (Network Act) still attaches to any marketing email, a separate Korean consent UI may be required before any newsletter. Counsel residual required before any lift of the collection stop rule.

REFUND AND GUARANTEE OPERATIONS POLICY

The Practice - Behavioral Sleep Improvement Coaching

Document: 13-Refund-Guarantee-Operations-Policy Version: Blue Book v0.1-DOMAIN-DRAFT Effective date: 20 August 2026 (KST) Status: Dual-use. Client-facing rules are Sections 1 to 7 and 12. Internal SOP is Sections 8 to 11 and 13. Publish the client-facing sections (or a short page that matches them) only after counsel residual. Do not publish internal scripts that discuss chargeback evidence in a way that coaches Clients to fabricate a story. Owner / sole refund approver: 이성재, Seoul, Republic of Korea. Related instruments: Client Service Agreement Section 9 (including Protocol Completion Guarantee v1, dated 20 August 2026 KST) and Section 10 (document 07); Website Terms (document 08); Privacy Notice (document 09); offer architecture Guarantee v1.

Plain summary (for Emperor Livingstone)

This policy says what money can go back and what cannot. The Practice sells process and effort, not hours slept. The only product promises are the process and effort paths, including Protocol Completion Guarantee v1 (four effort conditions; two extra 45-minute Sessions or unused-session refund after Week 2 and before Week 6; 9 cash touchpoints; after Week 6 extra Sessions only). Sleep hours are not a refund reason. Testimonials are never a price of a refund. Korean consumer law, if it applies, sits above this policy, and English-only is not an exemption. Only 이성재 may approve a refund. Display name Livingstone is not a legal-name change. The "I still cannot sleep" script is empathy plus the contract, not a new promise.

This policy exists so that Hormozi-style risk-reversal is not imported as a physiological money-back offer.

1. Purpose and Hierarchy

1.1 This policy tells staff and Clients what refunds and guarantees exist, what is banned, who may approve money out, and what to say when a Client reports that they still cannot sleep.

1.2 Order of authority (highest first):

(a) mandatory Consumer Law, including the Act on Consumer Protection in Electronic Commerce, Etc. if it applies to the sale; (b) Client Service Agreement Section 10 (savings clause) and Section 9 including Schedule A Protocol Completion Guarantee v1; (c) this policy; (d) the checkout page captured at purchase; (e) marketing copy.

1.3 Marketing copy loses. If an ad, landing page, or DM promised "sleep 8 hours or your money back," that copy was unauthorized. Honor the Client Service Agreement and Consumer Law. Then kill the copy. Do not "make the ad true" by paying a physiological guarantee as a new product feature.

2. Allowed Guarantees (Process / Effort / Service Only)

The only guarantees the Practice may offer, write, or speak are the following.

2.1 Coach-miss remedy. If the Coach cancels a booked Session and does not offer a make-up inside [MAKE-UP WINDOW, e.g. 14 days], the Client may choose:

(a) a refund of the unused prepaid portion allocated to that Session (Fees ÷ [SESSION COUNT], unless Schedule A states another allocation); or (b) one extra Accountability Session of the same length.

2.2 Coach-cannot-continue refund. If the Program ends early solely because the Coach cannot continue (extended illness, failed assignment, Coach-initiated stop other than Client breach or Red Flag), unused prepaid Sessions are refunded. If the Client Service Agreement's Homework condition applies to that path, "Homework" means timely submission of assigned logs or checklists. It does not mean a sleep score.

2.3 Stop-sale before any Session. If the Coach refuses or ends enrollment under Red Flag / stop-sale rules before any Session, refund Fees actually received, minus a processor cost only if Consumer Law allows that deduction.

2.4 Convenience termination by the Coach. Pro-rata refund of unused prepaid Sessions. The Homework condition does not apply.

2.5 Minor slip-through. Refund under document 12. Administrative, not result-based.

2.6 Failed geo or collection stop rule still on. If we took money from a restricted geography or before the collection stop rule was lifted and we cannot lawfully deliver, refund.

2.7 Effort-only extra credit (optional, only if Schedule A states it). A limited extra Accountability credit may be conditioned on attendance and log submission (for example, attended [X of Y] Sessions and submitted the assigned logs). Sleep metrics shall not appear.

2.8 Honest-scarcity failure. If a "limited seats" statement was operationally false, the Client may request a remedy: honor the offered seat, or refund unused Fees if we cannot. Do not invent a medical bonus as compensation.

2.9 Protocol Completion Guarantee v1 (dated 20 August 2026 KST). This is the client-exit path. It sits in CSA Section 9.4 and Schedule A. All four effort conditions: attend or 24h reschedule; diary 6 of 7 nights each elapsed week; run the written protocol; still believes the container was not delivered as described. Remedy (choose one) within 14 days of the last held Session: (i) two extra 45-min Sessions in the next 30 days, or (ii) unused-session refund if exit is after Week 2 and before Week 6. Unused = Sessions not yet held. Week 0 and held weeks are earned. Offboarding is not in the unused fraction. Allocation key: 9 touchpoints. After Week 6: extra Sessions only. If effort missed: written recap, no extra Sessions, no 9.4 refund. Korean e-commerce withdrawal, if it applies, sits above this clause. Goodwill refunds are unadvertised (CSA 9.9).

These are service and effort guarantees. They are the entire guarantee set at v0.1 after the 20 August 2026 rewrite.

3. Banned Guarantees (Hormozi Collisions)

The following shall not be written on the Site, spoken on a sales call, placed in a DM, used as a downsell, used as an upsell tier, or honored as if they were Practice policy. Names in parentheses are the corpus collisions this Blue Book refuses.

3.1 Win-your-money-back on hours slept. Any offer that refunds, credits, or makes the Program "free" if the Client does or does not sleep a stated number of hours, or hit a stated sleep-efficiency, AHI, or wearable score. (Money Models "Win Your Money Back" on a result such as weight lost.)

3.2 Service-until-asleep / service-until-result. Any promise to keep coaching at no extra charge until the Client "falls asleep," "sleeps through," or "is cured." (Offers "service-until-result.")

3.3 Unconditional medical-result guarantee. "If you are not satisfied because you still have insomnia, full refund, no questions." Satisfaction language must not be a proxy for a medical result. An unconditional service apology refund, if the founder ever chooses one, is a goodwill payment under Section 9, not a claim that insomnia is a covered defect.

3.4 "Cured insomnia or refund" and equivalents. Including "treated," "fixed," "eliminated," "no more insomnia," "apnea resolved," or "finally healed" paired with a refund or a free-until language.

3.5 Time-boxed physiological promise. "Sleep 7 hours within 21 days or your money back." Duration-plus-metric is a guarantee collision even without the word "guarantee."

3.6 Pay-for-performance on biology. Revshare-style or "pay us when your Oura score moves" structures.

3.7 Guarantee as a paid tier. "The premium package includes a results guarantee; the cheap package does not." That trains the market that the expensive tier is a medical warranty. Banned. (Money Models feature-downsell of the guarantee.)

3.8 Testimonial-conditioned win-back. "Refund if you post a story / leave a review / shoot a video." Testimonials are never a refund condition (Section 5).

3.9 Partner-clinic or device warranty. "If the mattress / supplement / clinic does not fix you, we refund coaching." The Practice does not stack clinical partners as treatment.

3.10 Anti-guarantee used as a taunt. We may refuse Clients who need a medical promise (that is a stop-sale). We shall not market "all sales final because we are that confident you will be cured."

3.11 Implied guarantee via typical-results numbers. Publishing "clients sleep X hours by week Y" as if it were a promise. Client-reported habit change is a different, lawyered testimonial problem. It is not a refund trigger and not a substitute guarantee.

If a banned line has already been published, take it down, keep a screenshot in the legal file, and handle any incoming claim under Section 1.2 (mandatory law and the CSA first). Do not leave the line up "until the funnel is rebuilt."

4. Consumption-Conditioned Refunds: Effort Only, Never Sleep Metrics

4.1 Consumption conditions are allowed only as evidence of effort, and only where Section 2 already creates a money path that mentions Homework or attendance.

4.2 Allowed condition examples

• attended at least [X of Y] live Sessions (other than Coach-miss Sessions);
• submitted the assigned wind-down log or habit checklist by the stated deadline for those Sessions;
• used the agreed between-Session channel rather than going silent.

4.3 Banned condition examples

• average [N] hours of sleep;
• "asleep within 20 minutes";
• wearable score above a threshold;
• clinician-confirmed remission;
• "you still feel tired";
• a before/after sleep-diary metric.

4.4 Staff shall not "help" a Client meet a banned condition, and shall not move a Client into a banned condition because the Client is unhappy.

4.5 If Schedule A is silent, do not invent a consumption-conditioned extra credit on the call.

5. Testimonials Are Never a Refund Condition

5.1 A Client may refuse a testimonial, a review, a public post, or a video and still receive every refund, credit, or make-up that the Client Service Agreement, this policy, or Consumer Law provides.

5.2 Staff shall not say "leave a review and I will process this faster," "I can only refund if you send a testimonial we can use," or "the win-back requires a story."

5.3 Optional testimonial invitations happen after the money issue is closed, on a separate message, with a separate consent. Never in the same paragraph as a refund decision.

5.4 Do not withhold a refund to pressure publicity. That is a banned collision and a Consumer Law risk.

6. Cooling-Off Residual (Korean E-Commerce Act)

6.1 Residual, stated plainly. The Practice is an English-only, fully online coaching service operated by a natural person in Seoul. That fact pattern may still be an electronic-commerce transaction under the Act on Consumer Protection in Electronic Commerce, Etc. We will not pretend that English-only sales are exempt. Counsel residual is open on applicability, the exact cooling-off window, and whether a particular Program is a digital service for which withdrawal is limited once performance started with the Client's agreement.

6.2 Operating rule while the residual is open. If a Client who looks like a "consumer" under Korean law asks to withdraw shortly after paying, do not refuse on the ground that the Site is in English. Escalate to 이성재 the same day. Compare:

(a) statutory withdrawal if counsel or the then-current internal memo says the Act applies and the transaction is still eligible; against (b) the process/effort paths in Section 2.

Give the Client the more favorable outcome of (a) or (b) when (a) applies. If you do not know, do not invent a denial. Park the charge, do not deliver further Sessions if delivery would kill a statutory withdrawal that still exists, and get a written call from counsel or from the founder after counsel.

6.3 Do not draft around the Act. Do not add "you waive cooling-off because you clicked that this is a digital download" without counsel. Some digital-content exceptions require specific pre-consent language. That language is not in this v0.1 draft as a waiver trick. If we later add a compliant digital-content disclosure, it will be a labeled amendment.

6.4 Foreign Clients. A Client in an Allowed Country may also have a home-country cooling-off rule. Do not tell them "Korean law only, you have no rights." Take the request, apply Section 1.2, and do not use geo as a taunt.

6.5 Confirmation documents, itemized receipts, and business-identity disclosures that the Act may require are a fulfillment duty, not a refund trick. Missing a confirmation document is not a reason to deny a legitimate withdrawal; it is a reason to improve operations.

7. How a Client Asks (Client-Facing)

7.1 Email [EMAIL] with: full name, invoice or checkout reference [INVOICE NUMBER], which path in Section 2 (or a statutory withdrawal) you believe applies, Session dates, and, if an effort condition is relevant, confirmation that assigned Homework was submitted.

7.2 Do not send sleep-study PDFs or hour-by-hour diaries to "prove you still cannot sleep." Those are not refund evidence. They are Sensitive Personal Information we do not want on a refund thread (see document 11).

7.3 Target response: [CLAIM SLA, e.g. 10 business days] from a complete request. Approved refunds go back to the original payment method when [PAYMENT PROCESSOR] allows.

7.4 This Section does not limit a faster statutory timetable if one applies.

8. Who May Approve Refunds (Internal)

8.1 Only 이성재 may approve a refund, credit, extra Session in lieu of money, or goodwill payment. There is no junior "just refund them" authority at this version.

8.2 If a contractor receives a request, the contractor acknowledges receipt ("we have your email; the founder will decide") and forwards the thread the same day. The contractor does not negotiate a new guarantee.

8.3 Approval record (keep with the invoice): date, amount, path (2.1 / 2.2 / 2.3 / 2.4 / 2.5 / 2.6 / 2.7 / 2.8 / statutory cooling-off / goodwill / chargeback-lost), whether Homework was relevant, and a note that no testimonial was required. Do not store extra symptom narrative.

8.4 Goodwill payments (money the CSA does not require) are allowed as a founder judgment when they reduce dispute cost or correct a service failure. They are not to be described to the Client as "because you still cannot sleep." Describe them as "a service adjustment" or "unused Session refund."

8.5 Partial refunds must use a written allocation (usually Fees ÷ Session count × unused Sessions). Do not "split the difference" against a sleep metric.

9. Chargeback SOP (Internal)

9.1 Preference. Ask the Client to use Section 7 before a card chargeback for a coaching-quality dispute. We will not threaten a Client for using a non-waivable card-network or Consumer Law right.

9.2 When a chargeback notice arrives:

(a) Calendar the processor deadline. Do not miss it. (b) 이성재 owns the response. (c) Gather: Client Service Agreement acceptance (timestamp, checkbox text), Schedule A / checkout capture, payment reference, Session attendance log, Homework-received log (effort, not scores), age-gate and geo-gate records, this policy version, and any emails about rescheduling. (d) Do not attach symptom diaries, Red Flag answers, or document 11 content unless counsel says the chargeback claim put those facts in issue and the network requires them. Default: keep sensitive data out of card-network packets. (e) Contest bad-faith or factually false claims (for example, "item not received" after the Client attended Sessions). Represent facts. Do not moralize. (f) Accept and close if the Client Service Agreement or Consumer Law already required us to refund and we were late. (g) After close, update the approval record. If we lost because our confirmation document or identity label was missing, fix the operations gap.

9.3 Do not ask the Client to withdraw a chargeback in exchange for a testimonial or a "we will keep coaching until you sleep."

9.4 Do not send the Client a script for what to tell their bank. That reads as coaching a representation.

9.5 Repeat chargeback-and-re-enroll patterns are a stop-sale. Refund if money is still ours and terminate.

10. Script: "I Still Can't Sleep" (Internal, Then Client-Facing Lines)

Use this when the Client's complaint is a physiological result, not a missed Session.

10.1 Internal mindset. This is the highest-risk sentence in the business. It is not a refund trigger under Section 2. It may be a Red Flag (refer to a clinician). It may be ordinary disappointment. It is never a reason to invent a banned guarantee on the call.

10.2 Say (client-facing):

"I hear that nights are still hard. I do not want to brush that off. I also need to be precise about what we sold. We sold coaching: information, lifestyle fit, and accountability. We did not sell a number of hours, a cure, or a medical result, and I cannot refund against how you are sleeping. If I missed a Session or I cancelled and did not make it up, we fix that under the process guarantee. If a cooling-off right applies to your purchase, we honor that. If you want to stop, we can close the Program and calculate unused Sessions only where the agreement or the law says they are refundable. I am not able to offer 'your money back because you still cannot sleep.' If anything about your health feels unsafe, please contact a licensed clinician or local emergency services. That is not me diagnosing you."

10.3 Do not say:

• "If you sleep under six hours this week I will refund you."
• "We will keep going free until you are fixed."
• "Leave a review and I will make an exception."
• "Your insomnia should have been gone by now."
• "Stop your CPAP / stop your medication and you will see."
• "I guarantee you will sleep next month."
• "The law does not apply because this is in English."
• "HIPAA means I cannot talk about refunds."

10.4 Then triage:

10.5 After the conversation, write a short note: date, which path, no new guarantee given. Do not paste the Client's symptom narrative into a shared channel.

11. Sales and Marketing Controls (Internal)

11.1 Sales calls may describe Section 2 in the same words as the Client Service Agreement. Sales calls may not "sweeten" with a banned line to close a high-ticket yes.

11.2 Downsells are payment timing or less access. Downsells are not "add a sleep guarantee."

11.3 Upsells are adjacent coaching (for example, a travel-habit container). Upsells are not devices, supplements, or a warranty.

11.4 Urgency and scarcity must be true calendar or cohort capacity. Fake "3 spots left" is both an ethics failure and a refund risk under Section 2.8.

11.5 If a prospect says "I will only buy if you guarantee I sleep 8 hours," that is a stop-sale. Thank them and decline. Do not split the difference.

11.6 Affiliate and referral partners get this banned list. A partner who publishes a banned guarantee is cut and the copy is treated as unauthorized marketing under Section 1.3.

12. Client-Facing Short Form (May Be Posted)

Refunds and guarantees (the Practice)

We guarantee our process and our effort, not your biology.

• If we cancel a Session and do not make it up in time, you get that Session refunded or an extra Accountability Session.
• If we cannot continue the Program, unused prepaid Sessions are refunded (effort conditions, if any, are about logs and attendance, never hours slept).
• We do not refund because you still cannot sleep, still feel tired, or still have a low wearable score. We did not sell those outcomes.
• You will never be asked for a testimonial in order to receive money the contract or the law already gives you.
• Mandatory consumer rights, including any cooling-off right that applies to this online sale, are not waived. English-only delivery is not an exemption story.
• Ask: [EMAIL]. Approver: 이성재.

Full terms: Client Service Agreement (document 07) and this policy.

13. Founder Checklist (Each Refund)

• [ ] Which path (Section 2.x / statutory / goodwill / chargeback)?
• [ ] CSA and checkout capture attached?
• [ ] Sleep metric used as a reason? If yes, stop and rewrite the reason.
• [ ] Testimonial mentioned? If yes, remove it from the deal.
• [ ] Sensitive attachments stripped from the card-network file?
• [ ] Amount = written allocation?
• [ ] Processor refund initiated; Client emailed in English, factual tone?
• [ ] Incident / approval record filed?
• [ ] Unauthorized marketing copy, if any, killed?

14. Review

Review when a chargeback is lost, when counsel residual on the E-commerce Act arrives, when a Successor Entity is formed (re-paper who approves), when Session count or [PRICE] changes, or every 90 days. Next review: [NEXT REVIEW DATE, e.g. 18 November 2026].

No one except 이성재 may amend the banned list downward (that is, to allow a physiological guarantee). Counsel may mark the list upward (stricter).

Evidence status / Confidence / Residual uncertainty

Evidence status. Dual client-facing + internal operations policy, Blue Book v0.1-DOMAIN-DRAFT, 20 August 2026. Allowed set limited to process/effort/service. Banned set lists the Hormozi collisions named in the method cards (win-your-money-back on hours; service-until-asleep; unconditional medical-result; cured-or-refund; guarantee-as-tier; testimonial-conditioned win-back). Consumption conditions effort-only. Testimonials never a refund condition. E-commerce Act residual and no-English-only-exemption rule included. Chargeback SOP. Founder-only approval. "I still can't sleep" script included.

Confidence. High as an internal control that matches documents 07 and the method-card constraints. Medium as a published consumer page: statutory cooling-off dates and digital-content exceptions are not filled because applicability is an open residual. Low as a substitute for counsel on a denied withdrawal.

Residual uncertainty. (1) Whether the Act on Consumer Protection in Electronic Commerce, Etc. applies to this English-only Seoul-operator sale, including withdrawal windows, digital-service exceptions, and confirmation-document duties. This policy assumes it may apply. (2) Card-network rules of [PAYMENT PROCESSOR] and the Client's issuing bank can override our preference for email-first disputes. (3) Limitation-of-liability in the CSA does not let us refuse a mandatory refund. (4) Goodwill refunds, if used often, can become an implied typical practice; track frequency at review. (5) Successor Entity assignment must rename the approver. Counsel residual required before the first paid enrollment and before any public guarantee sentence is shipped.

Hormozi Offer Legal Redline Rules

Blue Book, Core Legal Package, Part C (Marketing, Claims, Geo)

Plain summary (for Emperor Livingstone)

Hormozi methods stay; the health-claim versions do not. Every lever below is marked ALLOW, ALLOW-WITH-EDITS, or BAN. A BAN is not a suggestion: recut the artifact, do not just add a disclaimer. Paid ads, public pages, pixels, and lead magnets that collect contact data sit under a stop rule. A stop rule is a hard stop. This stop rule may be lifted only when a real lawyer is hired (or a dated leftover-risk note exists after a quote) and the Domain Sign-Off Certificate is in force. Process and effort guarantees only, honest scarcity only, adults 18+ only. The Practice does not diagnose, treat, or cure. Testimonials are never a refund condition. 이성재 is the operator and stays the legal party.

1. Purpose

1.1. Hormozi methods stay. The health-claim versions of those methods do not. This file is the redline other domains must apply before a Grand Slam Offer, Core Four script, money-model lever, or LTV play is written into public or sales language.

1.2. Every lever below is marked ALLOW, ALLOW-WITH-EDITS, or BAN. A BAN is not a suggestion. Recut the artifact. Do not "just add a disclaimer" (document 15, clause 1.2; document 06, clause 1.3).

1.3. Paid ads, public pages, pixels, and lead magnets that collect contact data remain under a stop rule. A stop rule is a hard stop. This stop rule may be lifted only when a real lawyer is hired (or a dated leftover-risk note exists after a quote) and the Domain Sign-Off Certificate (document 01) is in force (document 02). This redline may be used now for internal drafting only.

1.4. Process and effort guarantees only. Honest scarcity only. Adults 18+ only. The Practice does not diagnose, treat, or cure. No free sleep-diagnosis quiz. No HIPAA badge. No white-coat imagery.

2. How to use this redline

2.1. Name the Hormozi lever the draft is using. Match it to a section below. If two levers sit in one sentence, run both sections.

2.2. Apply the ruling. Write the required rewrite into the artifact. Delete the kill example language if it appears anywhere (ads, DMs, decks, invoices, UGC the Practice adopts).

2.3. Send the recut line through document 15 (claims matrix) as atomic claims. Only GREEN rows, and YELLOW rows with a complete packet, may proceed to document 17.

2.4. Founder preference cannot recolor a BAN. Napoleon/Emperor may accept leftover risk of launching without counsel in a dated writing. That instrument does not rewrite this redline.

3. Ruling key

4. Summary table (read this first, then the sections)

5. Value equation

Lever. Value ≈ (Dream Outcome × Perceived Likelihood of Achievement) ÷ (Time Delay × Effort and Sacrifice). Hormozi raises the top and drives the bottom toward zero.

Ruling. ALLOW-WITH-EDITS.

Required rewrite. Raise Likelihood by naming process and support: live sessions, a written habit map, weekly accountability, make-up rules if the coach misses. Cut Time Delay to the first behavioral win (first completed wind-down week, first attended session). Cut Effort with templates and a short core, not by promising that biology will do the work. Dream Outcome may be lifestyle and skill (clearer mornings, a travel checklist, a wind-down they can run). Dream Outcome may not be hours slept, AHI, "insomnia gone," or "cured in 21 days."

Kill example. "Wake up sleeping 8 hours, guaranteed. 21-day insomnia reset. We make it effortless so your body has no choice."

6. Value stack (core and bonuses)

Lever. List every problem, convert each to a named solution, trim expensive/low-value items, stack cheap/high-perceived-value bonuses (checklists, recordings, templates, partner bonuses).

Ruling. ALLOW-WITH-EDITS for core coaching plus non-clinical bonuses. BAN for clinical partners and for mattress / supplement / clinic / pharmacy items presented as a treatment bonus.

Required rewrite. Stack what the Practice actually delivers: session recordings the client already paid for, habit-map templates, a travel protocol that is still coaching, office hours. Cost next to perceived value is fine. Do not add a somnologist, a hospital, a CPAP shop, a pill, or a mattress brand as "included treatment." A client's already-owned consumer product may be discussed as environment (document 04, clause 5.4) without endorsement as medical treatment.

Kill example. "Bonus: partner mattress + magnesium protocol + a clinic consult so we treat the whole problem."

7. Scarcity

Lever. Limited units, limited bonuses, limited seats or cohorts. Honest capacity is the ethical version Hormozi himself flags.

Ruling. ALLOW-WITH-EDITS for real seats. BAN for fake remaining spots.

Required rewrite. State a number the operator can defend that calendar day (KST): "I take N high-ticket clients this month because that is all I can coach well." Keep a live seat ledger. If the number changes, change the copy the same day. Honest-scarcity failure is a refund path (document 13, clause 2.8).

Kill example. "Only 3 spots left" on a day the ledger shows eleven open seats. "Medical window closing. Apnea gets worse if you wait."

8. Urgency

Lever. Rolling cohorts, seasonal windows, promotion or bonus expiry, exploding opportunity.

Ruling. ALLOW-WITH-EDITS for real cohort dates and real bonus-expiry that matches operations. BAN for fake countdowns and for disease-urgency closes.

Required rewrite. Publish the actual cohort start date. A countdown is allowed only if it is tied to that date or to a real bonus the Practice will in fact withdraw. Red-flag danger is a referral, not a close (document 05). Do not sell "buy tonight or your condition becomes dangerous."

Kill example. A looping 24-hour timer that resets. "Your insomnia window is closing. Enroll before it becomes chronic."

9. Guarantees (the collision center)

Lever. Unconditional, conditional, anti-guarantee, implied (pay-for-performance). Conditional variants taught: service-until-result, time-boxed extra service, credit, personal 1:1, ancillary-cost refunds, release-of-commitment, delayed second payment, first-outcome, consumption-conditioned "crazy" guarantees.

Ruling. ALLOW-WITH-EDITS for process/effort/service only (document 13, section 2). BAN for all of the following: unconditional medical-result guarantees; service-until-asleep or work-until-the-result; win-your-money-back on sleep hours, latency, AHI, wearable scores, or symptom disappearance; "crazy" consumption guarantees advertised as free treatment ("do the work or your insomnia program is free").

Required rewrite. Use only the written set in document 13: coach-miss remedy, coach-cannot-continue refund, stop-sale refund, convenience termination, minor slip-through, failed geo or failed stop-rule lift, optional effort-only extra credit if Schedule A states it, honest-scarcity failure. Sales may describe those paths in the same words as the Client Service Agreement. Sales may not sweeten a close with a banned line.

Kill example. "Fall asleep in 12 minutes or your money back." "We work until you sleep through the night, free." "Cured insomnia or refund." "Win your money back if you do not sleep 7 hours." "Do the modules and your treatment is free."

10. Anti-guarantee

Lever. Do not take clients who need a medical promise to start. Hormozi notes that people who buy only because of a guarantee can be poor clients.

Ruling. ALLOW.

Required rewrite. Say it as a stop-sale, not as a taunt that implies a cure. Allowed: "We do not take clients who need a medical promise to start. If you will only buy if I guarantee hours slept, this is not a fit." Banned posture: "All sales final because we are that confident you will be cured" (document 13, clause 3.10).

Kill example. "All sales final. We are that sure your insomnia ends."

11. Naming (MAGIC wrapper)

Lever. Magnetic reason-why + Avatar + Goal + Interval + Container word (challenge, blueprint, intensive, system, reset). Rename the wrapper when the offer fatigues. Do not change fulfillment.

Ruling. ALLOW-WITH-EDITS.

Required rewrite. Container words are fine (intensive, system, reset, blueprint, cohort). Avatar and interval are fine if they do not pair a disease with a deadline. Do not use clinic, protocol-as-treatment, diagnosis, patient, therapy, or a disease-plus-interval name. Do not price-compare to a sleep lab as a reason to skip a physician (document 04, clause 8.2).

Kill example. "Insomnia Cure Intensive." "21-Day Apnea Protocol." "Clinical Sleep Therapy Challenge."

12. Lead magnet

Lever. Complete solution to a narrow problem that reveals the next paid problem. Types taught: reveal-a-problem ("think diagnosis"), sample/trial, one step of a multi-step process.

Ruling. ALLOW-WITH-EDITS for audit / habit map / checklist on a narrow non-clinical problem. BAN for "reveal diagnosis," sleep-score toys, ISI/STOP-BANG/AHI scoring, and any health-data quiz before the collection stop rule is lifted (and not after as a diagnosis toy). Official ISI / STOP-Bang / IRLS / ESS / official CSD: default never-buy.

Required rewrite. Name it as an audit or habit map. Example direction: a 3-night wind-down audit that does not score a disorder and does not collect contact data until the collection stop rule is lifted (documents 01 and 02). This stop rule may be lifted only when a real lawyer is hired (or a dated leftover-risk note exists after a quote). Consumption should be easy. The next step is a fit call, not a diagnosis reveal. No free sleep-diagnosis quiz. Ever.

Kill example. "Reveal your diagnosis. Find out if you have apnea in 90 seconds. Enter your email for your sleep score."

13. Warm outreach ("guarantee the dream outcome")

Lever. The Leads warm-outreach script: guarantee the dream outcome or work until they get it.

Ruling. BAN that script for this Practice.

Required rewrite. Warm outreach may offer a fit conversation, name real capacity, and describe process. Allowed direction: "If we are a fit, you get the sessions on the calendar. If we are not, I will say no. I do not guarantee a biological result." Do not promise the dream outcome. Do not promise free work until they sleep.

Kill example. "I will guarantee you sleep through the night or I will keep working for free until you do."

14. Win Your Money Back

Lever. Pay now. Get cash or store credit if they hit a result, complete actions, or both. Hormozi lists weight loss, fitness, self-care, and mental-health management as ideal use cases. Sleep looks the same and is the trap.

Ruling. BAN for sleep metrics, sleep-study scores, symptom disappearance, or any body result. ALLOW-WITH-EDITS for action-based credit (attend calls, log wind-down, complete modules) if and only if (a) Schedule A already states it, (b) it is not advertised as free treatment, (c) testimonials are never a qualification, and (d) it is not paired with an unconditional satisfaction-as-medical-result guarantee.

Required rewrite. If used at all, write it as extra accountability credit for documented effort, in the same family as document 13, clause 2.7. Do not headline it as "free." Do not put it on ads. Default off for public copy at v0.1.

Kill example. "Win your money back if you do not lose the insomnia. Post a review to qualify."

15. Decoy plus "results guaranteed" premium

Lever. Advertise a thin cheap or free option, then present a premium with more features, bonuses, and a guarantee. The book's pairing includes a "sleep routine" inside a premium with "results guaranteed."

Ruling. BAN.

Required rewrite. A cheaper container may exist (less access, payment plan, group instead of 1:1). It may not exist so that the expensive tier can say "results guaranteed." Premium is more coaching time and support, not more biology.

Kill example. "Free sleep-routine PDF, or the Premium Intensive with results guaranteed."

16. Downsell that removes a results guarantee

Lever. Convert a no by removing features, including removing the guarantee. LTV playbook repeats "no guarantee / worse guarantee" as a pricing lever.

Ruling. BAN when the thing removed is a results guarantee. That teaches the market that the expensive tier included an outcome promise.

Required rewrite. Downsell is payment timing or less access (fewer sessions, group instead of 1:1, no on-site). If any guarantee exists on both tiers, it is the same process/effort set. There is no "guaranteed-results tier."

Kill example. "Stay at this price and I guarantee you will sleep. Or take the cheaper plan with no sleep guarantee."

17. Continuity

Lever. Keep them buying (bonus-to-join, discount-to-join, waived fee). Works "especially well" on slow results. Sleep is also slow and medical.

Ruling. BAN as unfinished treatment. ALLOW-WITH-EDITS as skill maintenance.

Required rewrite. Frame optional continuity as community, monthly skill, or a seasonal reset, with clear cancel rights (document 13; document 20 if a group exists). Bill in a disclosed cycle. Do not use a long commitment period to hide a results guarantee. Do not say "stay until you are fixed."

Kill example. "Subscription until your insomnia is gone. Cancel when you are cured."

18. Testimonials as payment or as a refund condition

Lever. Free training paid in testimonials. Win-back criteria that include reviews and public posts. Retention steps that farm testimonials.

Ruling. BAN as payment for free work, and BAN as a required public post for a refund or credit.

Required rewrite. Testimonials, when the publishing stop rule is later lifted, are opt-in, licensed (document 14), limited to habits, mornings, travel, perceived rest, and program experience, with typicality in the unit (document 15, Y-rows). This stop rule may be lifted only when a real lawyer is hired (or a dated leftover-risk note exists after a quote). Invite after the money issue is closed, on a separate message. Never in the same paragraph as a refund decision (document 13, section 5).

Kill example. "Do the 12 weeks free, send a video, and we will call it even." "I can refund you if you post a story."

19. Affiliates and physicians (의료법 Art. 27(3))

Lever. Lead-getters: customer referrals, employees, agencies, affiliates/partners.

Ruling. ALLOW-WITH-EDITS for non-clinical adjacent partners (exec coaches, HR, travel, performance) with a written banned-claims list. BAN paid inducement to a physician, hospital, clinic, or pharmacy to send patients. That is patient solicitation for profit under Medical Service Act (의료법) Article 27(3), as commonly read. Generic, unpaid "see a somnologist or licensed physician" language in document 05 is not an affiliate program.

Required rewrite. Customer referrals may be an offer (a credit or a seat for a peer who is accepted) if the copy stays non-clinical and the peer still passes the red-flag screen. No named hospital. No revenue claim that the Practice treated anyone. A partner who publishes a banned guarantee is cut (document 13, clause 11.6).

Kill example. "We pay Dr. X per patient you send." "Physician-approved, hospital-affiliated sleep cure."

20. Core Four paid ads and cold channels

Lever. Warm outreach, free content, cold outreach, paid ads. Scale: More / Better / New.

Ruling. Paid ads: BAN while the ads stop rule is still on (documents 01 and 02), then ALLOW-WITH-EDITS only through document 17. This stop rule may be lifted only when a real lawyer is hired (or a dated leftover-risk note exists after a quote). Cold outreach: ALLOW-WITH-EDITS (FTC-level honesty still applies; fewer platform rules is not a license to diagnose). Free content: ALLOW-WITH-EDITS, same claims matrix as paid (document 17 applies to organic health-adjacent posts).

Required rewrite. Creative uses value-equation language without medical claims. Next step is book a fit call plus honest seat cap. Translate proof to performance and life quality, not medical recovery. Platforms already throttle health and sleep claims. Leftover risk: policies change (document 17).

Kill example. Shipping a Meta ad that says "finally sleep, guaranteed" while the collection stop rule is still on.

21. Attraction offers ("free," giveaway, pay-later)

Lever. Discount, free, win-your-money-back, giveaway, decoy, buy-X-get-Y, pay-less-now / pay-more-later. Hormozi: obey the law, especially around "free"; be transparent; check counsel.

Ruling. BAN for "free medical consult," "free if you do not sleep better," and "advertise as free" by pairing store credit with an unconditional medical-result guarantee. ALLOW-WITH-EDITS for a paid or application-based attraction that is clearly coaching, with any "free" word lawyered before public use.

Required rewrite. Attraction is an application, a narrow audit (when the collection stop rule is lifted), or a paid starter container. If more than a trivial share of pay-later buyers cancel, fix the promise, the conditions, or the price. Do not fix it by adding a biology guarantee.

Kill example. "Free insomnia consult. Pay only if you sleep."

22. Upsell, LTV, and Crazy Eight

Lever. More of, or more help with, what they just bought. Crazy Eight: raise price, cut delivery cost, more later, more now, better version, fewer units, lower quality, adjacent cross-sell.

Ruling. ALLOW-WITH-EDITS for adjacent coaching (deeper 1:1, couple/exec version, travel protocol, on-site intensive that is still coaching). BAN for supplements, unregulated devices, clinic packages, and cross-sell into clinical care sold as the Practice's treatment.

Required rewrite. Raise price because capacity and surplus support it, not because the claim got louder. A warm handoff to a physician is a stop-sale or a referral with no revenue claim that you treated them. Delivery-cost cuts must not cut activation (templates, group hours, recorded reviews).

Kill example. "Add the clinic package and the mouthguard. That is how we treat apnea."

23. Priced warranty and ultra-high-ticket anchor

Lever. Pricing play: sell a guarantee or warranty. Ultra-high-ticket anchor to make the core offer the obvious choice.

Ruling. BAN for sleep-outcome insurance or a priced warranty on hours slept (play #10 is for products with a repair cost). ALLOW-WITH-EDITS for an ultra-high-ticket anchor that is more access (on-site, exec intensive), still non-clinical. BAN if the anchor is sold as "medical-grade results."

Required rewrite. Anchor with time, access, and travel support. Core offer remains coaching. Do not sell "sleep outcome insurance."

Kill example. "USD 2,000 extra for a sleep-result warranty." "The USD 40,000 tier is medical-grade."

24. Quantified outcome plus duration (implied guarantee)

Lever. Hormozi flags quantified outcome + time interval as implying a guarantee and as a platform-policy fail (weight-loss / income examples).

Ruling. BAN when the quantity is biological (hours, latency, AHI, "insomnia gone") plus a deadline.

Required rewrite. Intervals may name the container ("a 21-day cohort of wind-down coaching"). They may not name the body result. See document 15, R-03 / R-04.

Kill example. "Fix insomnia in 21 days." "AHI under 5 by week four."

25. Retention activation (not a sleep KPI)

Lever. Activation points, 5 Horsemen, churn checklist, retention steps: activate, then optional testimonial, then refer, then a later offer (Hormozi calls this ascend).

Ruling. ALLOW-WITH-EDITS. Activation is behavioral (week-1 protocol completed, two sessions attended). BAN activation defined as WASO, AHI, or hours slept. BAN firing language that re-diagnoses why they "failed to get better." ALLOW firing clients who demand a diagnosis or a cure.

Required rewrite. Track attendance and habit logs. Exit-interview script does not confirm a self-label (document 04, clause 9). Testimonials in these retention steps remain optional and licensed.

Kill example. "Clients who cut WASO 40 percent stay. If you are not better, you failed treatment."

26. How this file feeds document 17

26.1. No Hormozi sentence goes to a public surface, a DM, or a high-ticket close until it has a document 15 row and a document 16 ruling that is ALLOW or ALLOW-WITH-EDITS (with the rewrite applied).

26.2. A BAN lever cannot be rescued by a GREEN structure sentence in the footer.

26.3. New use of an old line (website line reused as a 6-second hook) is a new clearance (document 15, clause 2; document 17).

27. Enforcement

27.1. Copy halt. Steuben may kill a page, ad, or script under document 01, clause 6.

27.2. Stop-sale. If a prospect will buy only on a banned guarantee, decline (document 13, clause 11.5).

27.3. Unauthorized marketing loses. If banned copy shipped, take it down, file a screenshot, honor document 13's authority order (mandatory law and the Client Service Agreement first). Do not "make the ad true" by paying a physiological guarantee as a new feature.

27.4. Repeat breach. A second intentional use of a BAN lever is a launch-stop-rule event.

28. Pre-publication checklist (offer language)

• [ ] Value equation raises likelihood via process, not promised sleep hours.
• [ ] Stack has no clinical, mattress, supplement, or clinic treatment bonus.
• [ ] Scarcity number matches today's seat ledger.
• [ ] Urgency matches a real cohort date. No looping timer.
• [ ] Guarantee text is document 13 only.
• [ ] Anti-guarantee is a stop-sale, not a cure taunt.
• [ ] Name has no medical container and no disease + deadline.
• [ ] Magnet is audit/habit map. No diagnosis quiz. No health-data quiz while the collection stop rule is still on.
• [ ] No "I guarantee the dream outcome" script.
• [ ] No win-back on sleep metrics. No testimonial-for-refund.
• [ ] No decoy-plus-results-guaranteed premium. No results-guarantee downsell.
• [ ] Continuity is skill maintenance.
• [ ] No paid physician inducement.
• [ ] 18+ stated. Allowed-geo only (document 24).
• [ ] No HIPAA badge. No white coat.

Evidence status / Confidence / Leftover uncertainty

Evidence status. Domain redline translating the Hormozi method cards (Offers, Leads, Money Models, LTV, Pricing, Retention) into the Practice's already-issued constraints (documents 04, 13, 15). Statute names used as commonly accepted: Medical Service Act (의료법) Article 27(3) on patient solicitation for profit; Act on Fair Labeling and Advertising and KFTC backdrop for false scarcity and claims; FTC Act §5 and FTC Health Products Compliance Guidance as posture for US-facing speech; FTC Endorsement Guides for testimonials. Korean E-commerce Act may still apply to English-only sales by a Seoul operator (document 13, section 6). No counsel memo is attached.

Confidence. High that physiological win-backs, service-until-asleep, fake scarcity, diagnosis magnets, medical naming, physician kickbacks, and results-guarantee tiers must stay BAN. High that process/effort guarantees and honest seats are the only conversion tools this domain will allow to be discussed. Medium that any particular action-based credit sentence will survive Korean fair-labeling review if it ever appears near the word "free."

Leftover uncertainty.

1. How a given FTC or state attorney general would treat an action-based credit advertised at all is leftover risk. That is why public "free" framing stays default-off.
2. 의료법 Article 27(3) enforcement on an English-language affiliate page from a Seoul operator is not a decided case in this file. Default: no paid clinical inducement.
3. Platform health and sleep policies can be stricter than this redline (document 17).
4. This document is not licensed legal advice and is not a substitute for Korean MSA/PIPA/KFTC/E-commerce counsel and US FTC/health-coaching counsel.

Allowed Country / Geo List

Blue Book, Core Legal Package, Part C (Marketing, Claims, Geo)

Plain summary (for Emperor Livingstone)

After collection later starts, commercial features may be designed for United States, Canada, Australia, New Zealand, and Singapore, plus Korea in English. A person in Korea who uses the English path is not barred because they are in Korea. Korean-language service is out of scope at this version.

Default exclude: United Kingdom, European Union, EEA (Iceland, Liechtenstein, Norway), and Switzerland. Do not target, do not knowingly sell, do not take a lead form from those countries. Adding the UK or EU (or EEA or Switzerland) is Napoleon's call. It is not a marketing experiment. Steuben cannot lift that exclusion alone.

This list may be used now to design gates. It does not start collection, paid ads, or checkout. Collection stop rule is still on. No forms, pixels, or offer buttons live here.

1. Purpose

1.1. This file is the live allow / exclude list for commercial features: lead capture, booking, sale, paid ads targeting, and checkout. It is not a travel blog and not a statement that local coaching law has been fully mapped for every listed country.

1.2. The Practice is English-only, fully online, high-ticket / hybrid, client-paid, with no audience at the date of this draft. The founder, 이성재, operates from Seoul. English-only delivery is not a statute exemption. Korean PIPA still attaches. The Act on Consumer Protection in Electronic Commerce, Etc. (전자상거래법) may still apply to English-only sales by a Seoul operator (document 13, section 6).

1.3. United Kingdom, EU, EEA, and Switzerland are default-excluded until a signed-off GDPR + CAP / health-claims set exists. Adding those countries is an escalation to Napoleon (section 9). It is not a marketing experiment.

1.4. This list may be used now to design gates. It does not lift the collection, paid-ads, or checkout stop rule. Those remain under documents 01 and 02.

2. How to read this list

"Located in" means the person's apparent location at the time of the commercial act (IP / payment / self-attestation used together, section 8). It is not citizenship by itself.

3. ALLOW (default) countries

These five are the default commercial countries at v0.1, plus Korea as operator home (section 4).

3.1. ALLOW means the Practice is willing to sell after the collection stop rule is lifted, not that every regulator in that country has been briefed.

3.2. Country addenda may be added later. Until an addendum exists, use documents 04, 12, 13, and 15 as the floor.

3.3. Do not add a sixth commercial country in ads or checkout without section 9.

4. Korea (operator home)

4.1. The Republic of Korea is the operator's home. The founder 이성재 resides in Seoul. Korean-language service is out of scope at this version. Do not publish a Korean medical-claim page to "explain" the English page (document 06, clause 1.6; document 17, clause 11.3).

4.2. Korean residents using English are NOT excluded. A person in Korea who passes the 18+ gate and uses the English commercial path is not barred because they are in Korea.

4.3. What still attaches when a KR resident (or any buyer from a Seoul operator) uses the English path:

1. PIPA (개인정보 보호법). Privacy control is PIPA-first (documents 09, 10, 11, 18).
2. Possible E-commerce Act (전자상거래법) duties: identity disclosure, confirmation documents, cooling-off leftover risk (document 13, section 6). Do not refuse a withdrawal on the ground that the Site is in English.
3. Medical Service Act (의료법) leftover risks on unlicensed practice and medical advertising, including Article 27(3) on patient solicitation for profit (document 16, section 19).
4. Act on Fair Labeling and Advertising and KFTC backdrop for claims and fake scarcity.

4.4. Korea is not used as a paid-ads target market for a Korean-language sleep-treatment campaign. If a later Korean-language offer is contemplated, that is a new Blue Book draft and a counsel track, not a quiet SKU.

5. DEFAULT EXCLUDE: United Kingdom, EU, EEA, Switzerland

5.1. Do not target or knowingly sell into:

• the United Kingdom;
• any Member State of the European Union;
• any EEA state that is not an EU Member State (Iceland, Liechtenstein, Norway);
• Switzerland.

5.2. The condition for adding this class is a signed-off GDPR + CAP / health-claims set (and the Swiss counterpart a lawyer names). Structural "GDPR-ready" sentences in other Blue Book files do not add these countries (document 00, clause 1.4). Adding the UK or EU is Napoleon's call.

5.3. Why they are grouped: UK GDPR / EU GDPR / ePrivacy-style cookie rules, and UK CAP / ASA plus EU / Member-State health-claim and consumer regimes, are not built in this package. Switzerland is grouped because a separate health-advertising and data-protection set would be required. This file does not invent the contents of those sets.

5.4. Implementation: ads country-exclude this class; checkout country-block this class; Website Terms say so (document 08, section 3). If money is taken by mistake, refund and do not deliver (document 13, clause 2.6).

5.5. Browsing a public educational page from an excluded country does not enroll the person and does not mean the Practice is targeting that country.

6. SANCTIONS EXCLUDE (OFAC / UN categories)

6.1. The Practice will not take payment from, or deliver coaching to, a person or entity where doing so would violate comprehensive sanctions administered by the US Office of Foreign Assets Control (OFAC), or comprehensive United Nations Security Council sanctions, as those lists stand on the date of the transaction.

6.2. Usual OFAC comprehensive-sanctions program categories (names, not a homemade country code): Cuba; Iran; North Korea (DPRK); Syria; and the Crimea, Donetsk, and Luhansk regions of Ukraine (plus any other region OFAC later lists under a comprehensive program). Also: any person or entity on the OFAC Specially Designated Nationals and Blocked Persons (SDN) list, regardless of country.

6.3. UN category: jurisdictions or parties subject to comprehensive UN Security Council sanctions then in force.

6.4. Do not invent fake country law. This section is a payment-and-delivery screen against commonly published sanctions programs. It is not a claim that coaching is illegal in a named country under that country's domestic coaching statute. Lists change. Before the first paid enrollment, and on a 90-day cadence after, the operator (or a lawyer) must check the current OFAC program page and UN sanctions list, not this paragraph's memory.

6.5. Other US, UN, EU, UK, Korean, Australian, Singapore, New Zealand, or Canadian restrictive measures may also make a particular payment unlawful. If a processor declines a jurisdiction, do not route around the decline.

6.6. If a comprehensive program is added or removed by OFAC or the UN after this draft, follow the official list the same day. Do not wait for a Blue Book rewrite to refuse a banned payment.

7. Leftover risk: VPNs and circumvention

7.1. A VPN, proxy, or similar method can hide a UK / EU / EEA / Swiss or sanctioned location. Country-block is best-effort, not a guarantee.

7.2. Website Terms already state that disguising a UK, EU, or EEA location to buy or to submit a lead is a material breach (document 08, clause 3.4). Apply the same rule to Switzerland and to sanctions countries.

7.3. Operating controls (use together):

1. Payment-descriptor and billing-address country.
2. IP country at checkout (session country-gate token is allowed as strictly necessary, document 10).
3. Self-attestation: "I am not located in the United Kingdom, the EU, the EEA, or Switzerland, and I am not attempting to buy from a comprehensively sanctioned jurisdiction."
4. If two signals conflict (for example, IP in France, card in the US), do not enroll. Refund if money was taken. Do not ask the person how to beat the gate.

7.4. Do not store extra identity documents "to defeat VPNs." That is a new collection. Collection stop rule is still on until documents 01, 02, and 09 allow it.

7.5. Leftover risk: a determined VPN user plus a third-country card may still pass. If later discovered, stop delivery, refund unused fees where the agreement or the law requires, and record the incident. Do not threaten. Do not keep the file as a lead.

8. Implementation (checkout, Terms, ads)

8.1. Checkout country-block. Commercial features (email capture, booking, purchase) accept only ALLOW countries in section 3 plus Korea in section 4, and reject DEFAULT EXCLUDE and SANCTIONS EXCLUDE. If a vendor cannot restrict by country, do not enable the vendor.

8.2. Website Terms of Use. Document 08, section 3, must keep pointing at this list. If this list changes, update the Terms date the same day (KST).

8.3. Ads country. When paid ads later start (document 17), campaigns target only ALLOW countries (and, if ever used, Korea as English-language only). Exclude UK, EU, EEA, Switzerland, and any sanctions geography the ad platform can exclude. Do not use condition-proxy targeting (document 17, clause 8.4).

8.4. Age gate still applies in every allowed country. 18+ only (document 12). Country-allow does not enroll a minor.

8.5. Claims still apply in every allowed country. Document 15 rows do not become looser because the IP is in Texas or Singapore.

8.6. Failed country refund. If we took money from a restricted geography or before collection was allowed and we cannot lawfully deliver, refund (document 13, clause 2.6).

9. Adding or removing a country

9.1. Adding the United Kingdom, any EU or EEA state, or Switzerland is an escalation to Napoleon. It changes legal limits (GDPR / UK GDPR, ePrivacy / PECR-style cookies, CAP / ASA or Member-State health-claim rules, Swiss counterparts). Marketing demand is not a reason. Required: a dated Napoleon / Emperor writing, a lawyer leftover-risk note on those tracks, and a new Blue Book version. Steuben cannot add this class alone.

9.2. Adding any other country (for example, Japan or the United Arab Emirates) requires: a one-page leftover-risk note (consumer law, advertising, data, sanctions, language), Steuben stamp, and an amendment line in document 25. Default: do not add.

9.3. Removing a country may be done by Steuben immediately if a regulator question, processor ban, or sanctions listing appears. Notify Napoleon the same day (KST).

9.4. Document 15, clause 13.2: a country added or removed is an immediate claims-matrix refresh.

10. What this list is not

1. Not a tax-nexus or permanent-establishment opinion (see document 03). A Korean company and a US LLC are not chosen. Intelligent Solutions is the other business and is not this Practice.
2. Not a license to practice medicine or coaching in any listed country.
3. Not a GDPR application. Excluded countries stay excluded.
4. Not a promise that VPN circumvention is impossible.
5. Not an English-only exemption from Korean law.
6. Not a HIPAA map. No HIPAA badge.

11. Review cadence

11.1. Every ninety (90) days KST: confirm ALLOW rows still match operations, re-read current OFAC comprehensive programs and UN lists, confirm ads and checkout excludes still match section 5.

11.2. Immediate review: first paid enrollment; first paid ad; processor country-decline; a person in an excluded country demands service; counsel memo; Napoleon escalation request.

11.3. Next review target: 18 November 2026 (KST), or sooner if section 11.2 fires.

Evidence status / Confidence / Leftover uncertainty

Evidence status. Domain country-control list. ALLOW set is a business-scope decision (US, CA-English, AU, NZ, SG) plus Korea as operator home. DEFAULT EXCLUDE for UK / EU / EEA / Switzerland matches documents 00, 04, and 08. Sanctions section names usual OFAC comprehensive-program categories and UN comprehensive sanctions as commonly published. It does not invent domestic coaching statutes. Korean E-commerce Act and PIPA leftover risks are carried from documents 09 and 13. No counsel memo is attached. Official sanctions lists were not re-fetched at stamp time; they must be checked before the first payment.

Confidence. High that UK / EU / EEA / Switzerland must stay excluded until a GDPR + CAP / health-claims set exists. High that Korean residents using English are not excluded, and that PIPA plus a possible E-commerce Act still attach. High that comprehensive-sanctions counterparties must be refused. Medium that any particular US state will treat this coaching model as outside unlicensed-practice rules. That is why diagnose / treat / cure stays banned rather than "cleared for all fifty states."

Leftover uncertainty.

1. State unlicensed-practice lines in the United States vary and are not pre-cleared here.
2. Canadian provincial, Australian, New Zealand, and Singapore consumer and advertising details are leftover risks, not mapped law.
3. Whether the Korean E-commerce Act applies to a given English-only online sale by a Seoul natural person is an open leftover risk (document 13). This list assumes it may apply.
4. VPN circumvention cannot be fully closed with an IP gate.
5. OFAC and UN lists change. Section 6.4 is a check-the-primary-source duty.
6. This document is not licensed legal advice and is not a substitute for Korean MSA / PIPA / KFTC / E-commerce counsel, US FTC / sanctions / health-coaching counsel, or local counsel in any ALLOW country.