Privacy Policy & Disclosures

Last updated: March 2026

We and our affiliates (collectively, “we,” “us,” or “our”) are committed to respecting your privacy and we recognize the need to appropriately secure and manage the personal information you share with us (personal information, or personally identifiable information, includes any information by which you can be identified, including but not limited to name, address, e-mail address, and telephone number). We use technical and procedural security measures to protect personal information under our control against loss or misuse. This Privacy Policy explains how we collect, use, disclose, and safeguard any personal information that you provide to us in the course of using our website and services (collectively, the “Website”) or that we may otherwise collect from or about you in connection with our products and services, as well as your choices and rights with respect to your personal information. Please read this Privacy Policy carefully.

This Privacy Policy does not apply to websites or online services that display or link to another privacy policy or notice, or where your information is collected under a different privacy policy or notice made available to you at the time your information is collected.

if you do not agree with the terms of this privacy policy—including the consent to receive communications by phone, sms/text, and email provided below—please do not access the website or provide us with any personally identifiable information.

Collection of your information

You can generally visit our Website without revealing any personally identifiable information about yourself. However, to learn about our services, we may ask you to provide certain personally identifiable information, and without providing such personally identifiable information, we may be unable to contact you regarding our services. The following is personally identifiable information that we may collect from or about you:

Inquiries and information requests

Information obtained from you when submitting an inquiry or requesting information (including via email, our call center, or other contexts), such as your first and last name, email address, telephone number, and information requested.

Information we collect through your use of our Website

As you navigate through the Website, certain information may be passively collected (i.e., gathered without you actively providing information) using various technologies and means. Our systems may automatically gather information about the areas you visit on the Website and collect operational information about the technology you use, such as your browser, type of computer, operating systems, geolocation, and internet service providers. Like most web sites, we and our service providers (including advertising providers) may track IP addresses during your visit and may also use session, persistent and flash cookies, web beacons, pixel tags and other successor technologies. We may request access or permission to and track location-based information from your computer or mobile device, either continuously or while you are using the Website, to provide location-based services. We and our service providers may also use this information for operations purposes, including improving products and services, optimizing our Website and displaying relevant advertising.

If you wish to change our access or permissions, you may do so in your device’s settings and/or opting-out pursuant to the terms described below, regarding Website Analytics..Your web browser may include settings which allow you to manage or block cookies and other related technologies. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Website. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

No sensitive information

We do not intend to collect sensitive personal information, such as information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; genetic data or other “sensitive data” as that term is defined in the U.S. Privacy Laws.

Use of your information

We may use the information we collect from and about you (and your device) to create, maintain, and provide you with information about the services displayed on our Website; respond to your questions or comments; provide you with customized content, targeted offers and advertising through our Website, online services, other sites, and via email or text message; contact you with information, newsletters, and promotional materials from us or on behalf of our partners and affiliates; develop new products and services, and improve our existing products and services; address problems and review the usage and operations of our Website or business, and improve our Website content, products and offerings; protect the security and integrity of our Website and our business; respond to law enforcement requests and as required by applicable law, court order, and governmental regulations; and as otherwise described to you at the point of data collection and in this Privacy Policy.

In addition to the purposes identified above, any information we collect may also be used for analytics purposes (e.g., evaluating Website usage patterns and advertisement interactions) so that we can gauge the effectiveness of our programs and advertisements, and improve the usefulness of information presented to visitors.

We may combine the personally identifiable information you share with us through this Website with other information we collect from or about you, both online and offline. We may also combine this personally identifiable information with records provided by third parties. We use this consolidated information to help us better design our products, to communicate information to you, to enhance our marketing and research activities, and to facilitate other business functions.

In addition, we may use any information we collect as necessary or appropriate to comply with laws and regulations; monitor, investigate, and enforce compliance with and potential breaches of our policies and procedures and legal and regulatory requirements; comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and exercise or defend our legal rights and our employees, affiliates, customers, contractors, and agents.

Disclosure to institutions: We provide services to educational institutions. If you express interest in one or more of the program(s) at our supported institutions, we may share your information with such institutions and they may contact you directly or we may contact you on their behalf. Once you apply for or register in their programs, your registration information is subject to their applicable privacy policies.

Disclosure for California Consumers: We do not Sell or Share and have not Sold or Shared personal information about California Consumers in the past twelve months. Relatedly, we do not have actual knowledge that we Sell or Share personal information of California Consumers who are under 16 years of age. For purposes of the CCPA, a “Sale” is the disclosure of personal information to a third party for monetary or other valuable consideration, and a “Share” is the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Disclosure for Consumers in other states with U.S. privacy laws: We do not Sell personal information to third parties or Process personal information for purposes of Targeted Advertising or Profiling in furtherance of decisions that produce legal or similarly significant effects concerning a Consumer, as the terms “Sell,” “Process,” “Targeted Advertising,” and “Profiling” are defined in the U.S. Privacy Laws.

Retention of personal information. We retain your personal information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes.

Disclosure of your information

We may share information we have collected about you in certain situations. In addition to any other disclosures of personal information described in this Privacy Policy, your information may be disclosed as follows:

• By law or to protect rights. We reserve the right to disclose information we collect from and about you (and your device) if required to do so by law or by a regulatory authority. We may also disclose your information as part of an investigation or enforcement action relating to improper or illegal conduct in connection with our online services or other products, including, without limitation, any situations that may potentially involve threats to the safety or privacy of any person or misuse of our Website.
• Third-party service providers. We may share your information with third parties that perform services for us or on our behalf, including data analysis, email delivery, internet services, hosting services, customer service, legal and auditing, and marketing assistance.
• Marketing communications. With your consent, or with an opportunity for you to opt-out, we may share your information with third parties for marketing purposes, as permitted by law.
• Third-party advertisers. We may use third-party advertising companies and advertising networks to serve ads when you visit the Website or third-party websites. These companies may use information about your visits to the Website and other websites that is collected via web cookies and similar technologies in order to provide advertisements about goods and services of interest to you.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Sale or transfer of ownership. During the normal course of our business, we may sell or purchase assets. If another entity acquires us or any of our assets, information we collect from and about you (and your device) may be transferred to such entity. Any successor entity shall be bound by terms and conditions reasonably similar to this Privacy Policy.

We and our service providers may create aggregated and/or de-identified databases which we otherwise use or share, but such databases will not include your personally identifiable contact information.

Website analytics

We may also partner with selected third-party vendors, such as Google Analytics, and others, to allow tracking technologies and remarketing services on the Website through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Website, determine the popularity of certain content, and better understand online activity. By accessing the Website and not opting out of the cookie notice on the Website, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for one of the following:

• Digital Advertising Alliance Opt-Out Tool
• Google Analytics Opt-Out Plugin
• Google Ads Settings Page
• Network Advertising Initiative Opt-Out Tool
  

Do-not-track signals and similar mechanisms

Some web browsers may transmit "do-not-track" signals to websites with which the browser communicates. This Website does not currently respond to these "do-not-track" signals.

Third-party websites

The Website may contain links to third-party websites and applications of interest, including advertisements and external services that are not affiliated with us. Once you have used these links to leave the Website, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the Website.

Security of your information

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

Minors

This site is not intended for children under the age of 16. We will not knowingly solicit or collect personal information from visitors in this age group. However, if the parent or the guardian of a child under 16 years old believes that the child has provided us with personal information, the parent or guardian of that child should contact us at the information provided below to request the information's deletion.

Consent to receive communications by phone, SMS/text, and email

Express written consent

By agreeing to our Terms of Use and Privacy Policy, you are providing your express written consent to receive communications from us (or persons or contractors acting on our behalf) at the telephone number(s) and email address you provided with your online submission or registration form. Your consent also serves as your express written consent to your past receipt of communications from us.

You further represent and warrant that: (i) you are at least 18 years old; (ii) you live in the united states; (iii) you have not registered on a national or statewide do not call list; (iv) you are the account holder of, or have the required consent to provide, the phone number(s) and email addresses provided; (v) the phone number(s) and email addresses provided are accurate and you will provide us with notice if you release them or they are otherwise reassigned for any reason.

Communications

Communications may include, without limitation, telemarketing and other promotional content through the use of email, landline phone, cellular phone, text messages (including SMS and MMS), fax, and notifications through any app that we produce or make available.

Communication frequency, revoking consent and opting out

How often we send you communications will vary depending on the number of programs and services you are enrolled in. You may revoke your consent to receive certain communications at any time. To stop receiving text messages reply "stop" to any of our texts. To stop receiving emails click the "unsubscribe" link provided at the bottom of our emails. To stop receiving phone calls, notify us of your request via phone, text message, or email. We will make a commercially reasonable effort to comply with any communications from you opting out. By contacting us to opt-out of a certain communications, you consent to receive a final communication confirming your opt-out.

Agreement to engage electronically

You understand and agree that agreeing to our Terms of Use and Privacy Policy, you are agreeing to execute this consent in electronic form.

Your choices and updating your personal information

You can opt out of promotional emails we may send to you by following the “unsubscribe” instructions provided in such emails. If you opt out of our marketing communications, we may still send you transactional and relationship emails, such as emails about your course registrations and account.

Data subject rights

• Data Subject Rights Disclosure: Consumers who reside in states with U.S. Privacy Laws have the following rights regarding our collection and use of the personal information, subject to certain exceptions. Please read this section carefully as some rights vary by state.

  • Right to Receive Information on Privacy Practices: (California residents only) You have the right to receive the following information at or before the point of collection:

    • The categories of personal information to be collected;
    • The purposes for which the categories of personal information are collected or used;
    • Whether or not that personal information is Sold or Shared;
    • If the business collects Sensitive personal information, the categories of Sensitive personal information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and
    • The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.
    • We have provided such information in this Policy, and you may request further information about our privacy practices by contacting us as at the contact information provided below.

  • Right to Know: (California residents only) You may request that we provide you with information about what personal information we have collected about you, including:

    • The categories of personal information we have collected about you;
    • The categories of sources from which we collected such personal information;
    • The business or commercial purpose for collecting, Selling, or Sharing personal information about you;
    • The categories of third parties to whom we disclose such personal information; and
    • The specific pieces of personal information we have collected about you.
  • Right of Access. You may ask us to confirm whether we are Processing your personal information and request to access your personal information. Please note this right does not apply to California residents.
  • Right to Deletion: You may request that we delete any personal information about you we that we collected from you.
  • Right to Correction: You may request that we correct any inaccurate personal information we maintain about you. Please note this right does not apply to Iowa and Utah residents.
  • Right to Data Portability. You may ask to obtain your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another entity without hindrance. You may not exercise this right more than two times in a calendar year. Please note this right does not apply to California residents.

  • Right to Receive Information About Onward Disclosures: (California residents only) You may request that we disclose to you:

    • The categories of personal information that we have collected about you;
    • The categories of personal information that we have Sold or Shared about you and the categories of third parties to whom the personal information was Sold or Shared; and
    • The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
  • Right to Receive Information about Disclosures. (Delaware residents only) You may require that we disclose to you a list of the categories of third parties to whom your personal information was disclosed.
  • Right to Opt-Out. You have the right to opt out of the Sale of your personal information and the Processing of your personal information for Targeted Advertising. You also have the right to opt-out of the Processing of your personal information for purposes of Profiling in furtherance of decisions that produce legal or similarly significant effects. Please note, these rights do not apply to California residents, as California Opt Out-Rights are described below. Please also note, Iowa, Tennessee, and Utah residents do not have the right to opt out of Profiling in furtherance of decisions that produce legal or similar significant effects.
  • Right to Opt-Out of the Sale and Sharing of Your personal information and Right to Limit the Use of Your sensitive personal information. (California residents Only) You have the right to opt-out of the Sale and Sharing of your personal information. You also have the right to limit the use of your Sensitive personal information to the purposes authorized by the CCPA. We do not Sell or Share and have not Sold or Shared personal information of California Consumers in the past twelve months. Further, we do not use Sensitive personal information for purposes beyond those authorized by the CCPA, and we have not used Sensitive personal information of California Consumers in the preceding twelve months for purposes beyond those authorized by the CCPA.
  • Right to Non-Discrimination: (California residents only) You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
• Exercising Data Subject Rights. You may exercise the data subject rights applicable to you under the U.S. Privacy Laws by contacting our Privacy Office at optout@everspringpartners.com, by calling +1 (312) 324-6002 and submitting details regarding your request. Consumers in some states, including California and Colorado, may also authorize an agent to make data subject requests on their behalf. In such instances, authorized agents may use the same methods as Consumers to submit data rights requests on Consumers’ behalf.
• Verification of Data Subject Requests. We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. Further, when a Consumer authorizes an agent to make a request on their behalf where permitted by U.S. Privacy Laws, we may require the agent to provide proof of signed permission from the Consumer to submit the request, or we may require the Consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
• Non-Discrimination. We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
• Appeals. Consumers of certain states have the right to appeal our decisions on their data subject requests. This section does not apply to California or Utah Consumers, or to Consumers who reside in other states where the applicable U.S. Privacy Law does not give them the right to appeal Controllers’ decisions regarding data subject rights. To appeal our decision on your data subject requests, you may contact our Privacy Office at optout@everspringpartners.com or by calling +1 (312) 324-6002. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

Among the types of Personal Data that this Website collects, by itself or through third parties, there are:

• Trackers
• Usage Data
• Number of Users
• Session statistics
• Gender
• Geography/region
• Device information
• Unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
• Email address
• First name
• Last name
• Phone number
• Date of birth
• City
• State
• Province
• ZIP/Postal code
• Country
• Browsing history
• Clicks
• Page views
• Interest
• Address
• Contact details
• Browser information
• Data communicated while using the service
• Answers to questions
• Keypress events
• Mouse movements
• Scroll Position
• IP Address
• Job position
• Job title
• Work history
• Job skills
• Company name
• Industry
• Education history
• Academic background
• Geography/region
• Company size
• Company revenue
• Date of birth
• Province
• Universally unique identifier (UUID)
  

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

This site is not intended for children under the age of 16. We will not knowingly solicit or collect personal information from visitors in this age group.

Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy. Users are responsible for any third-party Personal Data obtained, published or shared through this Website.

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

• Advertising
• Connecting Data
• Tag management
• Analytics
• Contacting the User
• Remarketing and behavioral targeting
• Hosting and backend infrastructure
• Handling activities related to productivity
• Spam and bots protection
• Managing contacts and sending messages
• User database management
• Managing data collection and online surveys
• Managing landing and invitation pages
• Heat mapping and session recording
• Content performance and features testing (A/B testing)
• Interaction with live chat platforms

Detailed information on the processing of Personal Data

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website.

For more information, please check the privacy policies of the relevant services.Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this Document.

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.

This results in Data flowing through these services, potentially causing the retention of this Data.

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.

This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.

These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.

Some of these services may record sessions and make them available for later visual playback.

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.

The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.

Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.

This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.

Some services offer a remarketing option based on email address lists.Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.

This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Cookie Policy

This Website uses Trackers. To learn more, Users may consult the Cookie Policy.

Further information for Users in the European Union

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
  

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
  

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information.

Notice at Collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

Internet or other electronic network activity information

Personal Data processed: 21

Personal Information collected or disclosed:

• Trackers
• Usage Data
• Number of Users
• Session statistics
• Gender
• Geography/region
• Device information
• Unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
• Email address
• First name
• Last name
• Phone number
• Date of birth
• City
• State
• Province
• ZIP/Postal code
• Country
• Browsing history
• Clicks
• Page views

Purposes:

• Analytics
• Advertising
• Tag management
• Remarketing and behavioral targeting
• Managing landing and invitation pages
  

Retention period: for the time necessary to fulfill the purpose
Sold or Shared: No
Targeted Advertising: No
Third-parties: Google LLC, LinkedIn Corporation, Meta Platforms, Inc., Unbounce Marketing Solutions Inc.

Identifiers

Personal Data processed: 14

Personal Information collected or disclosed:

• Trackers
• Usage Data
• Gender
• Geography/region
• Unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
• Email address
• First name
• Last name
• Phone number
• Date of birth
• City
• State
• Province
• ZIP/Postal code
• Country
  

Purposes:

• Advertising
• Managing landing and invitation pages
  

Retention period: for the time necessary to fulfill the purpose
Sold or Shared: No
Targeted Advertising: No
Third-parties: LinkedIn Corporation, Meta Platforms, Inc., Unbounce Marketing Solutions Inc.

Personal Data processed: 4

Personal Information collected or disclosed:

• Trackers
• Usage Data
• Gender
• Geography/region
  

Purposes:

• Advertising
  

Retention period: for the time necessary to fulfill the purpose
Sold or Shared: No
Targeted Advertising: No
Third-parties: LinkedIn Corporation

You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Website.

For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
• the right to non-discrimination.

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

Additional rights for Users residing in Minnesota and Maryland

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
• The right to review personal data used in the profiling;
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;

Additional rights for Users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

• The right to opt out of the processing of your Personal Information for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Privacy policy updates

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Website after the date such revised Privacy Policy is posted.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Website, if not stated otherwise within this document.

How can we help?

What you can do

• Ask us to know and access the information we hold on you
• Ask us to correct information we hold on you
• Ask us to be forgotten (delete the information we hold on you)
• Ask to port your data to another service

In case of issues

While we strive to create a positive user experience, we understand that issues may occasionally arise between us and our users. If this is the case, please feel free to contact us.

Contact us
If you have questions or comments about this Privacy Policy, or to exercise your rights as described in this Privacy Policy, please email us at optout@everspringpartners.com or call us at +1 (312) 324-6002.