PRIVACY POLICY

Fiduciary Training Online Course

Last Updated: July 10, 2025

1. INTRODUCTION

Gaffney Hill Consulting, LLC ("Company," "we," "us," or "our") is committed to protecting the privacy of users ("you" or "your") of our fiduciary training online course platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our Service.

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide:

• Account registration information (name, email address, phone number)
• Professional information (job title, company, license numbers if applicable)
• Payment information (credit card details, billing address)
• Course progress and completion data
• Assessment results and scores
• Communications with customer support
• Feedback and survey responses

2.2 Information Automatically Collected:

• IP address and device information
• Browser type and operating system
• Pages visited and time spent on the Service
• Course engagement metrics (video watch time, module completion)
• Login timestamps and session duration
• Cookies and similar tracking technologies

2.3 Information from Third Parties:

• Payment processor information
• Social media profile information (if you choose to connect accounts)
• Employer-provided information (for corporate training programs)

3. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

3.1 Service Provision:

• Creating and managing your account
• Delivering course content and materials
• Tracking course progress and completion
• Issuing certificates of completion
• Processing payments and managing subscriptions

3.2 Communication:

• Sending course-related notifications
• Providing customer support
• Sending marketing communications (with your consent)
• Notifying you of updates to our terms or policies

3.3 Improvement and Analytics:

• Analyzing usage patterns to improve our Service
• Personalizing your learning experience
• Developing new courses and features
• Conducting research and analytics

3.4 Legal and Compliance:

• Complying with legal obligations
• Protecting against fraud and abuse
• Enforcing our Terms of Use
• Responding to legal requests and court orders

4. SHARING YOUR INFORMATION

4.1 We Do Not Sell Personal Information: We do not sell, rent, or trade your personal information to third parties for their commercial purposes.

4.2 When We May Share Information:

Service Providers: We may share information with trusted third-party service providers who assist us in operating our Service, including:

• Payment processors
• Email service providers
• Cloud storage providers
• Analytics providers
• Customer support platforms

Employers/Sponsors: If your employer or organization sponsors your course enrollment, we may share your progress and completion status with them.

Legal Requirements: We may disclose information when required by law, regulation, or court order, or to protect our rights or the safety of others.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

With Your Consent: We may share information with your explicit consent for specific purposes.

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 Types of Cookies:

• Essential Cookies: Necessary for the Service to function properly
• Performance Cookies: Help us understand how users interact with our Service
• Functionality Cookies: Remember your preferences and settings
• Marketing Cookies: Used to deliver relevant advertisements

5.2 Managing Cookies: You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our Service.

6. DATA RETENTION

We retain your personal information for as long as necessary to:

• Provide you with our Service
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Maintain records for regulatory compliance

Generally, we retain:

• Account information: For the duration of your account plus 7 years
• Course completion records: Indefinitely for certification purposes
• Payment records: As required by law (typically 7 years)
• Analytics data: Up to 3 years in aggregated form

7. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication requirements
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

8. YOUR RIGHTS AND CHOICES

8.1 Access and Correction: You may access, update, or correct your personal information through your account settings or by contacting us.

8.2 Data Portability: You may request a copy of your personal information in a commonly used format.

8.3 Deletion: You may request deletion of your personal information, subject to legal retention requirements.

8.4 Marketing Communications: You may opt out of marketing communications at any time by:

• Clicking the unsubscribe link in emails
• Adjusting your account preferences
• Contacting customer support

8.5 Cookies: You can manage cookie preferences through your browser settings.

9. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

9.1 Right to Know: You have the right to know what personal information we collect, use, and share.

9.2 Right to Delete: You have the right to request deletion of your personal information.

9.3 Right to Opt-Out: You have the right to opt out of the sale of personal information (though we do not sell personal information).

9.4 Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, please contact us using the information provided below.

10. INTERNATIONAL DATA TRANSFERS

If you are located outside the United States, please note that we may transfer your personal information to the United States and other countries where our service providers operate. These countries may have different data protection laws than your country of residence.

11. CHILDREN'S PRIVACY

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

12. THIRD-PARTY LINKS

Our Service may contain links to third-party websites or services. This Privacy Policy does not apply to such third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending an email notification to registered users
• Providing notice through our Service

Your continued use of the Service after such changes constitutes acceptance of the updated Privacy Policy.

14. CONTACT INFORMATION

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Privacy Officer Gaffney Hill Consulting 

6800 Gulfport Blvd South Ste 201 - 124 

South Pasadena, FL 33707

[email protected] 727-423-2169

15. EFFECTIVE DATE

This Privacy Policy is effective as of [INSERT DATE] and was last updated on July 10, 2025.