This Privacy Policy (the “Policy”) describes the privacy practices of and the manner in which Finding Mastery Inc. and its affiliates (“Finding Mastery,” also “we,” “our,” and “us”) collect, use and disclose information, including your Personal Data, in connection with our services, websites (including findingmastery.com), online courses, digital content, and other services and products controlled, owned or licensed by Finding Mastery (collectively, the “Services”). For the purposes of this Policy “Personal Data” mean information that can personally identify you, including but not limited to first name, last name, and contact information.

When you access or use any of the Services, or take other actions described below, you agree to the terms of this Policy.

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICES.

In the context of this Policy, Finding Mastery acts as a data controller for the information we process, with the exception of information processed solely pursuant to the instruction of a third-party institution, business organization, or another controller, in which case Finding Mastery acts as a data processor.

1. INFORMATION WE COLLECT AND RECEIVE

Finding Mastery collects and receives the following types of information from you when you purchase, access or use the Services as described further below.

1. Information you provide directly to us. We receive information from you when you access or use our Services (e.g., when you register for our Services, sign up to receive electronic to other marketing communications, subscribe to our podcast or newsletter, purchase a course, communicate with customer service, or participate in surveys or marketing promotions). Depending on the Services you access and use, the types of information we collect includes your name, address, email address, phone number, other contact information, payment information collected and used by our third-party payment processor(s) such as credit or debit card numbers, information regarding your use of the Services, and any other type of information or Personal Data you submit to us at your discretion. You can elect not to provide such information, but, in general, most of the information we request from you is required in order for us to provide the Services and the lack of such information will prevent us from doing so. We will collect, use, transfer and disclose this information as described in this Policy.
2. Information we receive from third parties. We may receive information about you from third parties and our business partners (e.g., payment service providers, security services, business partners, client organizations), as well as receive information about you that is publicly or commercially available, and we may combine that with the information we have collected or received about you in other ways. These sources vary over time, but we protect this information according to the practices described in this Policy plus any additional restrictions which may be imposed by the source of the information.
3. Information that we automatically collect. Finding Mastery automatically collects certain information as you access or use the Services. We and our service providers (which are third-party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting:
   • technical data, such as your domain name, the browser type and language, and operating system you are using, your Internet Protocol (IP) address, country, and city, your device types, mobile device identifier, the date and time of your request, if any, and the device you are using, referring and exit pages and URLs, platform type, landing pages, error logs, and other similar information;
   • usage data, such as the date and time of your requests, the number of clicks, information you download, which Services you use and how you use them; pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites; information from interactive Services, including engagement during course sessions, and records of any contact we have with you by telephone, email or online; and
   • your interactions with our customer service, such as the date, time and reason of contracting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.

   Finding Mastery may collect information about you when you visit a Finding Mastery website through the use of “cookies.” (See our “Cookies” section below for more details).

   We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you.

   If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications.

4. To protect you, ourselves and others. We may collect or receive your information to protect you, ourselves, and others by enhancing our ability to detect, prevent, or otherwise address fraud, illegal activities, security or technical issues, or to protect against harm to the rights, property, or safety of Finding Mastery, its customers, users or the public, or otherwise enforce our rights.

We also may collect or receive information for other purposes that may be described to you at the point of collection or for which you provide your consent, or as permitted or required by applicable law.

We keep your Personal Data for no longer than necessary for the purposes for which it is collected and processed. The length of time for which we retain Personal Data depends on the purposes for which we collect and use it, the instructions of a controller when we act as a processor, and/or our requirements to comply with applicable laws.

3. USING YOUR INFORMATION

Depending on the Services you purchase, access or use, we use your information to:

• meet our contractual commitments to you,
• create your account,
• administer your account and respond to your requests,
• provide the Services you request,
  maintain and improve the Services and to develop new Services,
• provide you with information related to the Services, including changes to the Services, or other information we think you may find useful about our Services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes,
• customize content supplied to you based on your use of the Services (e.g., course companion guide),
• to track, evaluate, and analyze individual and aggregate use of the Services and to share, publish, or otherwise publicize information, but not Personal Data, describing such use,
• provide recommendations or advertising for products and services that may be of interest to you,
• prevent, investigate and deal with fraud, violation of intellectual property rights and other laws and unauthorized use of Services or your account,
• to protect you, ourselves and others,
• to anonymize your Personal Data (meaning to render your Personal Data in a form that does not identify you and where you can’t reasonably be re-identified through the use of that information or in combination with other information), after which we may use it for our analytics services. Please note that once your Personal Data is anonymized, it is no longer covered by privacy laws and can be freely used by us or others to gain insights.
• as otherwise reasonable and appropriate to the legitimate business needs of Finding Mastery related to the Services,
• as otherwise described to you in this Policy, for example in the section describing how we share your information, including Personal Data, with third parties.

4. SHARING YOUR INFORMATION

If we share information, including Personal Data, with third parties we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell information to any third party. We share information as follows:

• With clients, Finding Mastery shares anonymized Personal Data related to your use, results from your interaction with, and overall engagement with the Services.
• With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing, our learning management system platform, customer support, operation and administration of the Services, processing information that you provide to us, for security and technical protections, and other tasks related to the Services. We allow these third parties to access only the information needed to perform those services.
• We may share information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (e.g., a subpoena or court order); (b) enforce our Terms and Conditions of Use, this Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Finding Mastery, its agents and affiliates, its users and/or the public.
• With affiliates of Finding Mastery, or with successors in the event of or in contemplation of a merger, acquisition, divestiture or reorganization, in whole or part, for use consistent with this Policy.
  With other parties in connection with certain prospective or completed business transactions.
• As otherwise described to you at the point of collection, pursuant to your consent, or as otherwise permitted by law.

5. YOUR RIGHTS AND CHOICES

You have certain rights with respect to your information as further described in this section. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us as described in the “Contacting Us” section of this Policy.

You can tell us not to contact you with promotional information regarding our Services and services and those of third parties either at the point your information is requested on our website (by checking the relevant box), or by following the unsubscribe instructions on promotional communications sent to you. You can also exercise this right at any time by contacting us using the “Contacting Us” details at the end of this Policy.

You may request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling);
• update information about you that is out of date or incorrect;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services;
• revoke your consent for the processing of your information; and
• delete certain information we are holding about you (a request that you be “forgotten”).

You can opt-out of receiving certain cookies by adjusting your browser settings to refuse certain cookies or to alert you when a cookie is placed. Your browser settings may not permit you to block the use of certain non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.

Please note, that certain information may be exempt from such requests in some circumstances, which may include circumstances under which we need to continue processing your information for our legitimate interests or to comply with a legal obligation. An exercise of the right to be forgotten will result in your inability to use certain of the Services.

We may request that you provide us with information necessary to confirm your identity before responding to your request. In the case of access and correction requests, please provide as much detail as you can about the particular Personal Data you seek, in order to help us locate it. We will consider all requests and provide our response promptly, and within any time period required by applicable law.

In situations in which we process your Personal Data only on behalf of a customer such as a client organization, we may refer your request to the relevant party and cooperate with its handling of the request.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals. We do not recognize or respond to browser initiated Do Not Track (“DNT”) signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

6. SECURITY

Finding Mastery takes information security seriously and has taken various measures to keep your information secure from unauthorized access or disclosure, whether that information is stored physically or electronically. Finding Mastery has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the information collected from you in accordance with this Policy. Finding Mastery has security measures in place to protect against the loss, misuse, or alteration of your information. Despite these efforts, Finding Mastery cannot guarantee that unauthorized access or disclosure of information will never happen. If you have concerns, do not access or use the Services.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Given that the Internet is a global environment, using the Internet to collect and process information necessarily involves the transmission of data on an international basis. Therefore, by accessing or using any of the Services, you acknowledge and consent to the transfer, storage or use of your information outside your country of residence to any country where we have facilities or engage trusted third parties (e.g., payment processors, cloud service or other IT providers and other companies that provide services to us). You understand that the countries to which we may transfer information may not have as comprehensive a level of data protection as in your country.

8. EUROPEAN UNION USERS

For Personal Data about European residents, when the purposes of processing are satisfied, and we are not required to retain Personal Data to comply with applicable law, we will delete or anonymize your Personal Data within a maximum of twelve (12) months.

Legal Basis for Use (e.g., processing) of Your Information:

You expressly grant us the right to use your information:

• Where the use of your information is necessary to perform our obligations under a contract with you (e.g., to comply with the terms of service of our Services, which you accept by browsing, accessing and/or registering for);
• Where the use of your information is necessary for our legitimate interests or the legitimate interests of others (e.g., to provide security for our Services; operate our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud); or
• With your consent; or
• Other grounds, as required or permitted by law in the specific respective context.

If you have any questions or complaints about Finding Mastery’s privacy practices, you may contact us at the email address or mailing address set forth under the “Contacting Us” section below. We will work to resolve the issue with you.

8. CHILDREN’S’ PRIVACY

Generally, our Services are for users 13 years of age or older, and users must be 13 or older to create an account for Services. For Services offered to users under 13 years of age, we either provide the Services without collecting, using, or disclosing “personal information” (as defined in the Children’s Online Privacy Act (“COPPA”), except as permitted by COPPA, or we obtain consent in advance of such use from a parent or legal guardian. If we have reason to believe that any personal information has been submitted to us by a child under 13 in the United States or a child under 16 in the EU without legally valid consent, we will take reasonable steps to delete that information as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws. If you have any comments or questions on policies related to children’s personal information or about our commitment to protecting your and your children’s privacy, please contact us using the information listed in the “Contacting Us” section below.

9. LINKS TO OTHER WEBSITES

You may find links to third-party websites from any of the Services. Except as described in this Policy, we will not provide any of your Personal Data to these third parties without your consent. We provide links to third party services as a convenience to our users. These links are not intended as an endorsement of or referral to the linked services. These websites may have their own privacy, cookies and/or other policies, which you should check. We do not accept responsibility or liability for their policies because we have no control over them.

10. COOKIES AND OTHER ONLINE RECOGNITION AND AUTHENTICATION TECHNOLOGIES

Our Services may use online technologies called “cookies”, “pixels”, and “beacons”, as well as other local storage technologies. This section explains what these technologies are and how they may be used.

Cookies, Pixels and Other Local Storage Technologies. Generally speaking, “cookies” are text files that are placed in your device’s browser that can be used to help recognize your browser across different web pages, websites, and browsing sessions. A “pixel” is a tiny image embedded onto a website that loads when you visit and performs a similar functionality through the use of cookies. Your browser or device may offer settings related to cookies. For example, you may be able to configure your browser not to accept cookies, remove cookies, or to notify you when a cookie is being sent. For more information about whether these settings are available, what they do, and how they work, visit your browser or device’s help material. If you decide not to accept cookies from us, you may not be able to take advantage of all of the features of the Services.

Cookies are stored on your device or in “local storage”. We may also use other types of local storage technologies, such as Local Shared Objects (sometimes called “Flash cookies”), in connection with our Services. These technologies are similar to cookies in that they are stored on your device and can be used to maintain information about your activities and preferences.

Our Services may use cookies, pixels, or other local storage technologies in combination with other information about you to enhance and personalize your experience on our Services (or elsewhere online), including:

• to help authenticate you when you use our Services;
• to remember your preferences and registration information;
• to present and help measure and research the effectiveness of our Service, advertisements, and email communications (by determining which emails you open and act upon); and
• to customize the content and advertisements provided to you through our Services and on other websites and services you visit.

Beacons. Beacons are small pieces of code placed on web pages, videos, and in emails that can communicate information about your browser and device to a server. Beacons can be used, among other things, to count the users who visit a web page or read an email, or to deliver a cookie to the browser of a user viewing a web page or email.

10. CHANGES TO THIS POLICY

The information practices described in this Policy are current as of the effective date set out at the end of this document. Finding Mastery reserves the right periodically to update this Policy at its discretion. We will provide notice of any such changes (including when they will take effect) in accordance with applicable law. Your continued use of the Services after any such updates take effect will constitute acknowledgement and acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Policy, you may cease accessing or using the Services.

11. CONTACTING US

If you have any questions, comments, or requests regarding this Policy, please contact us by post or email using the following contact information:

• Via email at info@findingmastery.net.
• Write to us at the following address: Finding Mastery
  128 Sierra Street 2nd Floor,
  El Segundo, CA 90245

Please allow up to five (5) business days for us to reply.

This Policy was last updated on November 15, 2022.