Privacy policy

Last updated: October 9, 2026

This Notice at Collection and Privacy Policy (“Privacy Notice”) describes how Saidwell LLC and Processing Company, Civility LLC (“Saidwell,” the “Company,” “we,” “our,” or “us”) collects, uses, and discloses, processes, and/or retains personal information (“Information Practices”). This Privacy Notice explains the privacy rights available to you under applicable privacy laws and how you can exercise those rights. We respect your privacy and are committed to providing a transparent notice of our privacy practices.

Saidwell provides courses, resources and related services designed to help individuals and groups strengthen their communication skills in a variety of personal and professional settings, including at home, in the workplace, and during meaningful or important life moments. Through the Saidwell Platform and Services, users may access content intended to support more thoughtful, effective, and constructive communication. The Saidwell Platform and Services are directed to and intended for use by individuals and groups located in the United States.

This Privacy Notice applies when you visit our website (www.saidwell.com), use the App, and all features, applications, social media channels, browser plugins, content, downloads, and other online services that we make available or that link to this Privacy Notice (together, the “Platform”). This Privacy Notice also covers information we collect about you offline, from third parties, or when you contact us by phone.

This Privacy Policy is governed by (U.S.) privacy laws. Certain states provide specific rights to their residents as listed below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable law. Unless you are a California resident, any rights that may be available in your state are not afforded to you under this Privacy Notice while you are operating in your commercial or employment capacity.

The terms used in this Privacy Notice have the same or similar meaning as those terms in each of the applicable state laws, or the closest approximation of such terms.

Notice at collection

The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared for the purposes of cross-context behavioral advertising (e.g., targeted advertising).

General personal information

We collect, use, and process the categories of personal information described below for the business and commercial purposes listed in this notice. The purposes that apply to all categories of personal information are set out immediately below. Additional purposes that apply to specific categories are identified in the table.

Universal Purposes. We collect, use, and process each category of personal information described below for the following purposes:

• To fulfill or meet the reason for which you provided the information, and to provide you with the products, services, or information you request.

• For auditing relating to consumer transactions, including ad impressions where applicable, and for compliance with regulations and internal policies.

• For fraud prevention, security monitoring, and detection of and protection against malicious, deceptive, fraudulent, or illegal activity.

• For debugging to identify and repair errors that impair existing or intended functionality.

• To undertake internal research for technological development and demonstration.

• To undertake activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance that service.

• To share personal information with service providers and contractors that perform services on our behalf and carry out the business purposes described in this notice.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

• To comply with applicable laws, regulations, legal processes, and enforceable governmental requests, and to establish, exercise, or defend legal claims.

• For any other purpose disclosed to you at the time of collection or with your consent.

In addition to the universal purposes above, we use each category of personal information for the additional purposes described in the table below.

Categories of Personal InformationAdditional Category Specific Purposes for Collection, Use, or ProcessingSold or Shared for Targeted Advertising
Identifiers: For example, name, address, Internet Protocol address, email address, or other similar identifiers.• To service transactions and accounts, including customer service, account maintenance, customer verification, payment processing, billing, collections, and enforcement of our contractual rights. • To communicate with you about your account, transactions, our services, and changes to our Platform or offerings, including through email, text message, and other channels you have authorized. • To present our Platform and its contents to you, enable interactive features, and personalize your experience. • To work with advertising and marketing partners to deliver, measure, and personalize advertising, and to provide you with products or services that may be of interest to you. • For short-term, transient use limited to the current interaction and not used to build a profile about you or otherwise alter your experience outside the current interaction.We may sell or share this information with third parties through advertising, analytics, and lead-generation technologies for cross-context behavioral advertising. In certain jurisdictions, we do so only with your opt-in consent; elsewhere, you may opt out through our cookie settings or the “Do Not Sell or Share My Personal Information” link.
(Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, name, signature, bank account number, credit card number, debit card number, or any other financial information.• To service transactions and accounts, including customer service, account maintenance, customer verification, payment processing, billing, collections, and enforcement of our contractual rights.No
Characteristics of CA or Federal Protected Classifications: For example, primary language, age, household composition.• To service transactions and accounts, including customer service, account maintenance, and customer verification. • To present our Platform and its contents to you and personalize your experience.No
Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, purchasing or consuming histories or tendencies, referral activity, rewards earned and redeemed, and marketplace transaction history.• To service transactions and accounts, including customer service, account maintenance, customer verification, payment processing, billing, collections, and enforcement of our contractual rights. • To communicate with you about your account, transactions, our services, and changes to our Platform or offerings, including through email, text message, and other channels you have authorized. • To present our Platform and its contents to you, enable interactive features, and personalize your experience. • To work with advertising and marketing partners to deliver, measure, and personalize advertising, and to provide you with products or services that may be of interest to you. • For short-term, transient use limited to the current interaction and not used to build a profile about you or otherwise alter your experience outside the current interaction.We may sell or share this information with third parties through advertising, analytics, and lead-generation technologies for cross-context behavioral advertising. In certain jurisdictions, we do so only with your opt-in consent; elsewhere, you may opt out through our cookie settings or the “Do Not Sell or Share My Personal Information” link.
Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with our website, application, or rewards program activity.• To communicate with you about your account, transactions, our services, and changes to our Platform or offerings. • To present our Platform and its contents to you, enable interactive features, and personalize your experience. • To work with advertising and marketing partners to deliver, measure, and personalize advertising, and to provide you with products or services that may be of interest to you. • For short-term, transient use limited to the current interaction and not used to build a profile about you or otherwise alter your experience outside the current interaction.We may sell or share this information with third parties through advertising, analytics, and lead-generation technologies for cross-context behavioral advertising. In certain jurisdictions, we do so only with your opt-in consent; elsewhere, you may opt out through our cookie settings or the “Do Not Sell or Share My Personal Information” link.
Geolocation Data: For example, information that can be used to determine a device’s physical location.• To service transactions and accounts, including customer verification and service dispatch. • To present our Platform and its contents to you and personalize your experience based on your general location. • For short-term, transient use limited to the current interaction and not used to build a profile about you or otherwise alter your experience outside the current interaction.We may sell or share this information with third parties through advertising, analytics, and lead-generation technologies for cross-context behavioral advertising. In certain jurisdictions, we do so only with your opt-in consent; elsewhere, you may opt out through our cookie settings or the “Do Not Sell or Share My Personal Information” link.
Sensory or Surveillance Data: For example, call recordings or other audio, electronic, or visual monitoring or surveillance.• To service transactions and accounts, including customer service, account maintenance, and customer verification, including quality assurance and training.No
Inferences / Profile Data: Inferences drawn from personal information to create a profile reflecting preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.• To communicate with you about your account, transactions, our services, and changes to our Platform or offerings. • To present our Platform and its contents to you, enable interactive features, and personalize your experience. • To work with advertising and marketing partners to deliver, measure, and personalize advertising, and to provide you with products or services that may be of interest to you.We may sell or share this information with third parties through advertising, analytics, and lead-generation technologies for cross-context behavioral advertising. In certain jurisdictions, we do so only with your opt-in consent; elsewhere, you may opt out through our cookie settings or the “Do Not Sell or Share My Personal Information” link.

Note: We do not collect Professional or Employment-Related Information, or Education Information in the consumer context.

Sensitive personal information

Categories of Sensitive Personal InformationPurposes for Collection, Use, or ProcessingSold or Shared for Targeted Advertising
Account log-in• To perform services or provide goods you request and reasonably expect from us • To detect, prevent, and investigate security incidents involving your information • To investigate or curtail malicious, fraudulent, or illegal actions directed at us and to prosecute those responsible • To ensure the safety of you and others • To enhance your experience on our website in real time, so long as we do not disclose your information to a third party • To perform services for our business needs such as maintaining accounts, providing customer service, and fulfill orders • To ensure the quality or safety of a product, service, or device • To collect or process sensitive personal information where such information is not being used to infer characteristics about you but may be used to provide a specific good or service based on the sensitive information you provided. • For strictly internal purposes, including, but not limited to, performing internal analytics to better our products, offerings, and services.No

Note: We do not collect other sensitive personal information under applicable state laws.

Retention periods

The period of time for which we retain information depends on the purposes for which we collect or use that information. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

Notice of sale and/or share

Our use of tracking technologies may be considered a sale or sharing with third parties for cross-context behavioral advertising (e.g., targeted advertising) under applicable state law. You can opt-out of being tracked by these third parties by clicking the “Do Not Sell or Share My Personal Information” link and choosing your preferences. Please note that this link provides opt-out rights under all applicable state laws, also known as “opt-out rights” or “personal data use opt-out”. You may also opt out by enabling a recognized opt-out preference signal such as the Global Privacy Control (“GPC”) on your browser or device, see “Making Requests to Opt-Out; Opt-Out Preference Signals” below for details.

Privacy policy

The purpose of this Privacy Policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices. You have certain rights to control the use of your personal information. This Privacy Policy describes your rights as they relate to our Information Practices as to your personal information and how you can exercise those rights.

The following table includes disclosures for the preceding 12 months: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.

General personal information

CategoryBusiness or Commercial Purpose for Collection & DisclosureCategories of Service Providers / Contractors to Whom Disclosed
Identifiers• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction
Personal Information Categories from Cal. Civ. Code § 1798.80(e)• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction
Commercial Information• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction
Internet or Other Similar Network Activity• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction
Geolocation Data• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction
Sensory Data• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction
Inferences• Providing, operating, supporting, and improving Saidwell’s services and Platform. • Responding to inquiries, and requests for information. • Establishing and managing relationships with customers, prospective customers, and business partners. • Communicating regarding services, transactions, facilities, contracts, support, and other business matters. • Administering billing, payments, accounting, and commercial transactions • Operating, maintaining, securing, troubleshooting, and improving the website and related systems • Conducting analytics, behavioral analysis, business intelligence, advertising, marketing, lead generation, audience measurement, and campaign attribution • Understanding website use, visitor interests, and potential customer demand • Maintaining records of consent and privacy preferences • Detecting and preventing fraud, security incidents, misuse, and unlawful activity • Complying with legal, regulatory, contractual, accounting, and recordkeeping obligations • Establishing, exercising, or defending legal claims • Evaluating or carrying out mergers, acquisitions, restructurings, financing transactions, or other corporate transactions• Affiliates and related entities • Website hosting, cloud storage, and information-technology providers • Customer relationship management and communications providers • Analytics, behavioral analysis, and performance-monitoring providers • Advertising, marketing, and social-media partners • Lead-generation and business-intelligence providers • Consent-management and privacy-compliance providers • Translation, font, and website-functionality providers • Security, fraud-prevention, and incident-response providers • Payment processors, billing providers, financial institutions, and accounting providers • Logistics, warehousing, transportation, carrier, fulfillment, and other operational partners • Insurance providers and claims administrators • Legal, accounting, audit, compliance, and other professional advisers • Government authorities, regulators, law-enforcement agencies, courts, and other parties where disclosure is required or permitted by law • Buyers, investors, lenders, successors, and other parties involved in an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or other corporate transaction

Sensitive personal information

Unless otherwise allowed by applicable state law, we will only collect certain types of sensitive personal information with your consent. We do not use or disclose the below sensitive personal information for purposes other than those business purposes specifically enumerated under applicable state law, including California.

CategoryBusiness or Commercial Purpose for Collection & DisclosureCategories of Service Providers / Contractors to Whom Disclosed
Account log-in• To perform services or provide goods you request and reasonably expect from us • To detect, prevent, and investigate security incidents involving your information • To investigate or curtail malicious, fraudulent, or illegal actions directed at us and to prosecute those responsible • To ensure the safety of you and others • To enhance your experience on our website in real time, so long as we do not disclose your information to a third party • To perform services for our business needs such as maintaining accounts, providing customer service, and fulfill orders • To ensure the quality or safety of a product, service, or device • To collect or process sensitive personal information where such information is not being used to infer characteristics about you but may be used to provide a specific good or service based on the sensitive information you provided • For strictly internal purposes, including, but not limited to, performing internal analytics to better our products, offerings, and services• Service Providers who assist us in offering a product or service to you or assist us in completing a transaction requested by you • Service providers who assist our business in operations, such as cloud storage providers, web hosting providers, cybersecurity providers, operating and management companies

Note: We do not collect other sensitive personal information under applicable state laws.

For each category of personal information identified above, we also disclose such personal information to the following categories of third parties:

At Your Direction. We may disclose your personal information to any third party with your consent or at your direction. For example, at your direction and with your consent, we may share your course completion information with a third party you designate, such as an employer, coach, or continuing-education provider.

Business Transfers or Assignments. We may disclose or transfer your personal information to a buyer, successor, or other entity as reasonably necessary to facilitate a merger, divestiture, restructuring, reorganization, dissolution, joint venture, collaboration, assignment, sale, transfer, or other disposition of all or any portion of our business, assets, or stock (including as a going concern or in connection with any bankruptcy, liquidation, or similar proceeding), in which personal information held by Saidwell about our Platform users is among the assets transferred.

Legal and Regulatory. We may disclose your personal information to government authorities, regulatory agencies, law enforcement, and courts as reasonably necessary to comply with any court order, law, or legal process, including to respond to any government, regulatory, or law enforcement request; to enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes; to assert and defend legal claims; to protect the rights, property, or safety of Saidwell, our customers, or others, including exchanging information with other companies and organizations for the purposes of fraud protection; and as otherwise permitted or required by law.

Mobile information. We do not share mobile information with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent are excluded from all categories of information we disclose and will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

De-identified and aggregated information. We may disclose aggregated information about our users and de-identified data or information that does not identify an individual, without restriction. Where we maintain de-identified data (data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual), we commit to the following: (1) we take reasonable measures to ensure the data cannot be associated with an individual; (2) we publicly commit to maintaining and using the data in de-identified form and will not attempt to re-identify the data, except for the purpose of determining whether our de-identification processes comply with applicable law; and (3) we contractually obligate any recipients of the de-identified data to comply with all applicable requirements regarding de-identified data.

What we sell to third parties or share with third parties for cross-context behavioral advertising and right to opt-out

We have sold or shared with third parties for cross-context behavioral advertising (e.g., targeted advertising) the following categories of personal information to advertising networks and data analytics providers in the preceding 12 months: Identifiers; Internet or Other Similar Network Activity; Commercial Information; Geolocation Data; and Inferences / Profile Data.

We do not sell or share your sensitive personal information without your consent.

Right to opt-out of sale/sharing or targeted advertising

You have the right to direct us to stop selling or sharing your personal information (the “Right to Opt-Out”). You may exercise this right by: (1) Clicking “Do Not Sell or Share My Personal Information” to use our interactive opt-out form; or (2) Submitting your request through an Opt-Out Preference Signal/Universal Opt-Out Mechanism, as described further below in the section titled “Making Requests to Opt-Out; Opt-Out Preference Signals.”

We do not have actual knowledge that we sell the personal information of minors under 18 years of age.

Cookies and other tracking technologies

The Platform may use first-party and third-party “cookies,” as well as other tracking technologies, to enhance the experience of the Platform and for advertising and analytics purposes. These technologies are used for record-keeping purposes, to ensure the Platform operates properly, to track how website visitors interact with the Platform, and for advertising. Cookies are small files that a website places on a website visitor’s hard drive through their web browser. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you choose to refuse cookies, please note that some parts of the Platform may not function properly as a result.

Right to opt-out of marketing communications

You may opt out of marketing communications at any time:

• Email marketing: Use the unsubscribe link in the footer of any marketing email.

• SMS/text marketing: Reply “STOP” to any marketing text message, or text STOP to 1-844-398-5077.

• Telemarketing calls: Inform the sales representative who calls you, or email support@saidwell.com with your request.

Third party links

The Platform may contain links to other websites or applications. Please be aware that we are not responsible for the content or privacy practices of such other websites or applications. We encourage our users to be aware when they leave our Platform and to read the privacy statements of any other website or application that collects personal information.

Your state law privacy rights

Right to Know/Access: Certain states provide the right to request our disclosure of any of the following:

• The categories of personal information we have collected about you (which may include any inferences).

• The categories of sources from which the personal information is collected.

• the business or commercial purpose for collecting, selling, or sharing with third parties for cross context behavioral advertising (e.g., targeted advertising).

• The categories of third parties to whom we disclose personal information.

• The specific third parties to whom we disclose personal information.

• The specific pieces of personal information we have collected about you.

Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of our processing. We may request documentation from you to help assess accuracy. If we determine the contested information is more likely than not accurate based on the totality of circumstances, we may deny the request and will explain the basis for our decision.

Right to Delete: You have the right to request that we delete personal information we have collected from or about you, subject to certain exceptions permitted by law. If we cannot fully comply with a deletion request, we will explain why and delete the information that is not subject to an exception.

Right to Opt-Out of Sale/Sharing; Targeted Advertising: You may have the right to “opt out” of the “sale”, “sharing” of your personal information for cross-context behavioral advertising, or processing of your personal data for purposes of targeted advertising (as those terms are defined by applicable state law).

Right to Withdraw Consent: Where we have collected or used your personal information based on your consent, you have the right to withdraw your consent at any time. Upon receiving your withdrawal request, we will stop processing the applicable personal data as soon as practicable, but not later than 30 days after receiving your request (or such shorter period as required by applicable state law).

Right to Opt-Out of Certain Profiling: Under certain state laws, you have the right to opt out of the processing of your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal: If we deny your request to exercise any of the rights described above, you may have the right to appeal that decision by submitting a request to appeal to us.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your state privacy rights. However, we may still offer you certain financial incentives permitted under applicable state law, such as discounts, rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.

How to exercise your rights

Making Requests to Know/Access, Delete, or Correct: You may exercise your rights, as applicable by state law, by submitting a verified consumer request to know information (and to receive your personal information in a portable format), to correct information, or for deletion.

The response to a request to know will provide the personal information we have collected and maintained about you, in a portable format, unless an exception under applicable state law applies. Please note that, depending on the applicable state law, we may not be required to provide personal information to you if you make multiple requests in a certain time period.

To submit a valid request, please email us at support@saidwell.com or by calling toll-free at 1-844-398-5077. We will verify your identity by comparing the name and email address you provide with the information associated with your account or previously provided when you interacted with us, such as when you created an account, requested information, made a purchase, or contacted customer support. Please include your full name, the email address associated with your account or prior interaction, and any other details that may help us locate the relevant records and confirm that you are authorized to make the request. If you call 1-844-398-5077 you will be asked to provide the same information requested in the email for verification purposes. If you submit a request that is not through one of the above designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies with your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days, or as allowed under applicable law, describing our verification process. We will confirm receipt of the request and respond to your request, consistent with applicable law, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted. We do not knowingly collect information of minors under the age of 18.

Making Requests to Opt-Out; Opt-Out Preference Signals: Our use of tracking technologies may be considered a sale/sharing for targeted advertising under applicable state law. You can exercise your Right to Opt-Out of being tracked by these third parties by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our website and selecting your preferences, or by broadcasting an Opt-Out Preference Signal/Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing (or targeted advertising) will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. Because the signal is browser-specific, you will need to broadcast subsequent signals if you are accessing our website through different online devices (e.g., computers, smartphones, tablets).

Withdrawing Consent: Where we have collected or used your personal information based on your consent, you may withdraw your consent by submitting a withdrawal request through our webform or via toll-free number 1-844-398-5077. If you call us toll-free we will ask that you provide the information requested in our webform.

Appealing a Denial of a Request: If we deny or decline to take action on your verified consumer request, you have the right to appeal. To submit an appeal, email us at support@saidwell.com within 90 days of receiving our denial. We will inform you in writing of any action taken or not taken in response. We will also include a written explanation of the reasons for our decision and information about how to file a complaint with your state Attorney General or applicable regulatory authority.

Using an authorized agent to submit a request

California: Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information, to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive personal information. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request. To submit authorized agent documentation, contact us at support@saidwell.com.

Other States: If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable state law. If a power of attorney is not submitted, you may be required to provide commercially reasonable identification of your identity and evidence of your authorized agent’s authority to act on your behalf. For example, you may need to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request, by contacting us at support@saidwell.com.

Changes to our privacy notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Platform and update the notice’s “Last Revised/Reviewed” date. Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes.

Contact for more information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under applicable state law, please do not hesitate to contact us at: support@saidwell.com, by phone at 1-844-398-5077, or by mail at 188 Front Street, Suite 116-48, Franklin, TN, 37064.

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