Privacy

We collect the following categories of Data.

2.1 Information you provide

• Name and preferred name
• Date of birth
• Job title, employer, and profession
• Contact information, including email address, telephone number, and mailing address
• Demographic information such as postal code, preferences, and interests
• Payment Information, including credit and debit card numbers, processed by our payment providers
• Accessibility and accommodation requests, which may include health-related information you choose to share
• Dietary requirements you provide for in-person events
• Content you submit through discussion boards, coaching sessions, intake forms, and correspondence

2.2 Assessment Data

• IP address
• Web browser type and version
• Operating system and device type
• Referring URL, activity on the Website, and exit URL
• Cookie information, described in Clause 11

2.4 Event recordings

• Delivering the Services you purchase, including course access, assessments, coaching, and event administration
• Processing payment and maintaining financial records
• Administering assessments and delivering your results
• Providing accessibility accommodations you request
• Responding to inquiries and support requests
• Internal record keeping and quality improvement
• Improving our products and services
• Sending promotional material that may interest you, where you have opted to receive it
• Market research, conducted by email, telephone, or mail
• Meeting legal, tax, and regulatory obligations

3.2 We rely on the following legal bases where the EU General Data Protection Regulation or the UK General Data Protection Regulation, as retained and amended by the UK Data Protection Act 2018, applies to you: performance of a contract for delivery of purchased Services, consent for marketing communications and event recording, legitimate interests for service improvement and security, and legal obligation for tax and record-keeping requirements.

• 3.2.1 If you access our Services from Canada, Australia, Brazil, or another country with its own comprehensive data protection law, such as PIPEDA, the Australian Privacy Act, or the LGPD, we process your Data consistent with the applicable requirements of that law to the extent it applies to our processing.

• 3.2.2 Marketing consent. Where the law of your country requires opt-in consent before we send you marketing communications, such as the law of the European Union, the United Kingdom, or Canada, we will only send marketing email or text messages after you have affirmatively opted in, and you may withdraw that consent at any time. Where opt-out marketing is lawful, such as in the United States, we rely on the opt-out mechanism described in Clause 9.

3.3 We do not use automated decision-making that produces legal or similarly significant effects concerning you. Assessment results are interpretive tools reviewed by qualified practitioners, not automated determinations about you.

3.4 We may use artificial intelligence tools to support content development, administrative communication, and internal operations, as described in Clause 17 of the Terms and Conditions. We do not submit your Assessment Data, coaching records, or personal disclosures to third-party artificial intelligence systems for training purposes.

4.1 Assessment Data belongs to you. We use it to deliver your results, prepare your coaching or workshop experience, and support your development.

5.1 We do not sell your personal Data. We do not share your personal Data for cross-context behavioral advertising.

5.2 Unless required or permitted by law, and subject to this Clause, your Data is not disclosed to third parties.

5.3 We use service providers who process Data on our behalf and only to the extent required to perform the services we request. These include:

• Payment processors, including Stripe and PayPal
• Buy-now-pay-later and installment providers, including Klarna, Afterpay, and PayPal, where you choose that option at checkout. When you use one of these services, you share information directly with the provider, and the provider's handling of your information is governed by its own privacy policy.
• Our learning platform provider
• The Life Languages™ assessment provider, Life Languages International™ (Life Languages Sales and Marketing, LLC), whose terms and privacy policy are available at https://www.lifelanguages.com/legal
• Email and communication platforms
• Scheduling tools used for coaching sessions
• Event venues, for attendance lists and accessibility arrangements

Any use of your Data by these providers for other purposes is prohibited. Each is required to process Data consistent with this Policy and applicable law.

5.4 We may disclose Data where required by law, court order, or lawful request by a government authority, or where necessary to protect our legal rights or the safety of any person.

6.1 We may from time to time expand or reduce our business, which may involve the sale of a division or the transfer of control of a division to another party. Data relevant to a transferred division will be transferred with it, and the new owner or controlling party will be permitted, under the terms of this Policy, to use the Data for the purposes for which you supplied it.

6.2 Where your Data will be transferred in this manner, you will be contacted in advance and given the choice to have your Data deleted or withheld from the new owner or controller.

7.1 We retain Account information and Assessment Data for as long as your Account is active and for 3 years after your last purchase or interaction with us, unless a longer period is required by law or for a legitimate business purpose such as tax records or dispute resolution.

7.2 Specific retention periods:

Data type	Retention period
Account and profile information	Active account plus 3 years
Assessment Data and reports	Active account plus 3 years
Payment and transaction records	7 years, for tax and audit purposes
Event recordings and photographs	3 years, or until you withdraw consent
Marketing contact information	Until you unsubscribe, plus a suppression record retained indefinitely so we do not re-contact you
Website analytics and Cookie data	24 months
Support and correspondence records	3 years

7.3 At the end of a retention period, Data is deleted or irreversibly de-identified.

7.4 You may request earlier deletion under Clause 8. Deletion may end your access to purchased Services, including course content within your one-year access window.

8.1 Depending on your state or country of residence, you may have the right to:

• Access the personal Data we hold about you and receive a copy
• Correct inaccurate or incomplete Data
• Delete your personal Data
• Portability, meaning receipt of your Data in a portable, machine-readable format
• Opt out of the sale or sharing of personal Data and of targeted advertising. We do not engage in these practices, but the right is stated here for clarity.
• Limit the use of sensitive personal information
• Non-discrimination for exercising any of these rights
• Appeal a denial of any request
• Withdraw consent at any time where processing is based on consent, including consent to event recording

8.2 These rights are available to residents of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Maryland, and other states with comprehensive privacy statutes, to individuals in the European Union and United Kingdom under the EU and UK General Data Protection Regulation, and, to the extent provided by local law, to individuals in Canada, Australia, Brazil, and other countries with comparable data protection statutes.

8.3 How to exercise your rights. Email m4sacademyinfo@measures4success.com with your name, the email address associated with your Account, and a description of your request. You may also write to us at our Premises or call 855-438-5777.

8.4 Our response. We will confirm receipt within 10 business days and respond substantively within 45 calendar days. Where a request is complex, we may extend by an additional 45 days and will notify you of the extension and the reason.

• 8.4.1 If you are making a request under the EU or UK General Data Protection Regulation, we will instead respond within one calendar month of receiving your request, extendable by a further two months for complex or numerous requests. We will tell you within the first month if an extension is needed and explain why.

9.1 Where you are asked to submit Data, you will be given options to restrict our use of it, including:

• Use of Data for direct marketing
• Sharing of Data with third parties
• Inclusion in event recordings and photographs

9.2 You may unsubscribe from marketing communications at any time using the link in any email we send, or by contacting us directly. Unsubscribing from marketing does not stop transactional messages about a Service you have purchased.

10.1 You may access certain areas of the Website without providing any Data. To use all Services and Systems, you may be required to submit Account information or other Data.

10.2 You may restrict your browser's use of Cookies. See Clause 11.

11.1 We use the following categories of Cookies:

• Strictly necessary Cookies, which enable core functions such as login and payment. These cannot be disabled without affecting site function.
• Analytics Cookies, which help us understand how visitors use the Website.
• Preference Cookies, which remember your settings.

11.2 You may accept, refuse, or manage non-essential Cookies through the Cookie banner presented on your first visit, or at any time through your browser settings. Refusing non-essential Cookies does not prevent you from purchasing or accessing Services.

11.3 We honor Global Privacy Control and similar browser-based opt-out signals where technically feasible.

12.1 You may access your Account at any time to view or amend your Data. You may need to update your Data if your circumstances change. Marketing preferences may also be stored and changed at any time.

12.2 To request a full copy of your personal Data, follow the process in sub-Clause 8.3.

13.1 Data security matters to us. We maintain physical, electronic, and managerial safeguards to protect Data collected online, including encryption in transit, access controls limiting Data to personnel who require it, and vendor agreements requiring equivalent protection.

13.2 No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you are responsible for keeping your Account credentials confidential.

13.3 Breach notification. If a breach affecting your personal Data occurs, we will notify you and any required regulator within the timeframes set by applicable law, and we will describe what happened, what Data was involved, and what steps we are taking.

14.1 Our Services are operated from the United States, and your Data is stored and processed there. If you access our Services from outside the United States, you understand and agree that your Data will be transferred to, stored in, and processed in the United States, a country whose data protection law may differ from that of your home country.

14.2 Where your Data originates in the European Economic Area, the United Kingdom, or Switzerland, we rely on recognized transfer mechanisms as applicable, including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and, where relevant, the Swiss-U.S. Data Privacy Framework. You may request a copy of the relevant safeguard by contacting us under Clause 16.

14.3 EU and UK representative. [Measures4Success, LLC to confirm: if you process the personal data of individuals in the EU or UK on anything more than an occasional basis, Article 27 of the EU and UK GDPR requires you to appoint a local representative in each region and publish their contact details here. Confirm your EU and UK visitor volume with counsel so this subclause can name the representative or state that the occasional-processing exemption applies.]

We reserve the right to change this Privacy Policy as necessary or as required by law. Changes will be posted on the Website with an updated revision date. Where a change materially affects your rights, we will notify you by email. You are deemed to have accepted the revised Policy on your first use of the Website following the change.

Questions, requests, and complaints regarding this Privacy Policy should be directed to:

Measures4Success, LLC
1802 Vernon Street NW, PMB2275
Washington, DC 20009 m4sacademyinfo@measures4success.com
855-438-5777

For questions about orders, payments, or cancellations, contact m4sacademysales@measures4success.com.

If you are located in the European Union or United Kingdom and believe we have not resolved your concern, you have the right to lodge a complaint with the supervisory authority in your EU member state of residence or with the UK Information Commissioner's Office. If you are located in another country with its own data protection authority, you may have an equivalent right to lodge a complaint there.