Privacy Policy

01Information We Collect

1.1 Information You Provide to Us

• Account & Profile Data: name, email address, postal address, phone number, username, password, demographic details, and any other information you choose to provide.
• Payment Data: billing address, credit/debit card numbers, and other payment details (processed via PCI-compliant third-party processors — CONDUCTR does not directly store full card numbers).
• Content & Communications: messages, support requests, survey responses, testimonials, uploaded files, and content you post in community forums or coaching sessions.
• Minor Participant Data: if you are a parent or legal guardian registering a minor for youth programs, we collect the minor's name, age, and program-related information reasonably necessary to provide the applicable Services.

1.2 Information Collected Automatically

When you use the Services, we automatically collect certain information, including:

• Device Data: IP address, browser type, operating system, device identifiers, language preferences.
• Usage Data: referring URLs, pages viewed, links clicked, session duration, and other activity metrics.
• Cookies & Similar Technologies: we use cookies, pixel tags, and local storage to recognize your browser/device and improve functionality (see Section 8).

1.3 Information from Third Parties

We may receive information about you from:

• Payment processors (e.g., Stripe, PayPal) for transaction confirmation.
• Marketing partners and social platforms (e.g., Facebook, Instagram) if you interact with our ads or social content.
• Event platforms and affiliates that help manage ticketing, referrals, or co-hosted programs.
• Service providers that support scheduling, hosting, video conferencing, transcription, course hosting or related operational functions.

1.4 Session Recording Data

All coaching sessions — including individual 1:1 sessions and group calls — may be recorded for accuracy, quality assurance, and the protection of all parties. By participating in any live session, you consent to such recording and acknowledge that recording may occur where enabled or disclosed in connection with the applicable session or program. Recordings and transcripts may include audio, video, screen shares, chat messages, participation activity, and related communications.

Recordings and related communications are stored securely and retained for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law, legal process, dispute resolution needs, security purposes, or legitimate business operations. Recordings are periodically reviewed for continued necessity and securely deleted when no longer required for these purposes.

We may use third-party service providers to host, process, store, transcribe, analyze, or support recordings and related session data, subject to appropriate contractual confidentiality and security protections.

Participation in certain live sessions or programs may require consent to recording as a condition of participation. If you do not consent to recording where required for a particular session or program, you may not be able to participate in those Services. For participants under 18, the parent or legal guardian's consent to these Terms constitutes consent to session recording on behalf of the minor, subject to the additional verifiable consent requirements described in Section 10 for participants under 13.

1.5 Sensitive Personal Information

Certain personal information we collect may be considered "sensitive personal information" or "special category data" under applicable privacy laws, depending on your jurisdiction. This may include information listed above such as account credentials, payment-related information, audio or video recordings, communications content, information relating to youth program participation, or other information described in this Privacy Policy.

Where we process sensitive or special category personal information, we do so only where reasonably necessary to provide, administer, secure, support, and improve the Services; comply with legal obligations; protect participant safety and security; prevent fraud or misuse; or otherwise as permitted by applicable law. We seek to apply appropriate safeguards and limit the collection, use, retention, and disclosure of such information to what is reasonably necessary for these purposes.

02How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the Services.
• Process and manage orders, subscriptions, and program registrations.
• Respond to inquiries, comments, and support requests.
• Send transactional messages, administrative notices, and service-related announcements.
• Personalize content, recommendations, and marketing communications.
• Improve and develop new products, features, and user experiences.
• Detect, prevent, and address technical issues, fraud, or violations of our Terms of Service.
• Comply with legal obligations and protect our rights.
• Review session recordings for coaching quality, accuracy, and dispute resolution purposes.

03Legal Bases for Processing (EEA/UK Users)

If you reside in the European Economic Area or the United Kingdom, we process your personal data only where we have a valid legal basis to do so under applicable data protection law, including the UK GDPR and EU GDPR. Depending on the circumstances, we may rely on one or more of the following legal bases:

Performance of a Contract

We process personal information where necessary to provide the Services you request, including: creating and managing accounts; processing purchases, registrations, and payments; providing coaching sessions, educational programs, community access, and customer support; facilitating participation in youth programs; and communicating with you regarding your account or the Services.

Legitimate Interests

We process certain personal information as reasonably necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. These interests may include: maintaining, securing, and improving the Services; preventing fraud, abuse, unauthorized access, or violations of our Terms; managing business operations and administrative functions; reviewing coaching sessions and recordings for quality assurance, dispute resolution, training, and safety purposes; responding to inquiries and support requests; analyzing usage trends and engagement to improve functionality and user experience; and protecting the rights, property, and safety of CONDUCTR, our users, and others.

Consent

We rely on your consent where required by applicable law, including for: sending certain marketing or promotional communications; placing non-essential cookies or similar tracking technologies on your device; collecting or processing certain categories of sensitive personal information where consent is legally required; and obtaining verifiable parental consent for participants under 13 in accordance with COPPA and other applicable laws. You may withdraw your consent at any time by contacting us or using available opt-out mechanisms, although withdrawal will not affect processing already conducted prior to withdrawal.

Compliance with Legal Obligations

We may process personal information where necessary to comply with applicable laws, regulations, legal processes, court orders, governmental requests, accounting requirements, child safety obligations, or other lawful obligations.

04Sharing & Disclosure of Information

We do not sell your personal information for monetary compensation. We may share it only:

• Service Providers: with trusted vendors who perform services for us (e.g., hosting, email delivery, payment processing, analytics, video conferencing, transcription, security, and related operational services) under confidentiality and security agreements.
• Business Transfers: in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, provided that the successor entity continues to honor this Policy.
• Legal & Compliance: when we reasonably believe disclosure is necessary to comply with applicable law, subpoena, court order; to enforce our agreements or policies; or to protect the rights, property, or safety of CONDUCTR, our users, or others.
• Consent: with your consent or at your direction.

We may also disclose information in aggregated or de-identified form that does not reasonably identify an individual. For participants under 13, we obtain separate verifiable parental consent before disclosing personal information to any third party, except where such disclosure is reasonably necessary for delivering the Services, complying with legal obligations, protecting safety or security, or otherwise permitted by applicable law.

Current Operators Receiving Personal Information

05International Transfers

If you are located outside of the United States, your information may be processed in countries other than your own, including the United States, where privacy and data protection laws may differ from those in your jurisdiction. Personal data may be transferred, accessed, and stored globally as necessary for the uses and disclosures stated in this Privacy Policy. By providing your personal data to CONDUCTR, you agree to CONDUCTR transferring your personal data to its affiliates globally and to third parties that provide services to CONDUCTR.

06Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected or as required by law. The specific retention period for personal information depends on the nature of the information, the purpose for which it was collected, the sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, applicable legal requirements, and whether the information is necessary for ongoing operational or legitimate business purposes.

Session recordings, transcripts, chat communications, participation activity, and related program records may be retained for a longer period (a minimum of two years or longer) where reasonably necessary for: quality assurance and training; safeguarding and participant safety; dispute resolution and enforcement of program policies; legal compliance and evidentiary preservation; security monitoring and fraud prevention; and maintaining accurate business and operational records.

Where reasonably possible, we seek to limit retention by securely deleting, de-identifying, anonymizing, or restricting access to personal information that is no longer required for active operational, legal, or business purposes. In some circumstances, we may retain limited information for longer periods where required or permitted by law, including to comply with legal obligations, preserve evidence, resolve disputes, enforce agreements, protect minors and participant safety, or establish, exercise, or defend legal claims. We periodically review our data retention practices and evaluate whether continued retention of personal information remains reasonably necessary in light of the purposes for which it was collected and applicable legal requirements.

07Security

We employ reasonable administrative, technical, and physical safeguards designed to protect your information against unauthorized access, alteration, disclosure, or destruction. No system is 100% secure; therefore, we cannot guarantee absolute security or prevent all potential security incidents.

08Cookies & Tracking Technologies

We use and our service providers may use cookies, pixels, local storage, software development kits (SDKs), and similar tracking technologies to operate, analyze, improve, personalize, and support the Services:

• Essential Cookies to enable core functionality, authentication, security, and operation of the Services.
• Analytics Cookies to understand usage and improve performance, troubleshoot performance issues, measure engagement, and improve functionality (for example, Google Analytics or similar tools).
• Advertising Cookies to deliver relevant ads and measure campaign effectiveness.

These technologies may collect information such as IP address, browser type, device identifiers, pages visited, links clicked, session activity, and similar usage information. Most browsers allow you to refuse cookies or notify you when a cookie is being placed. Disabling cookies may affect functionality. Depending on your jurisdiction, you may also have the right to opt out of certain advertising-related tracking or targeted advertising activities.

09Your Choices & Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information, which may include the right to:

• Access, correct, update, or delete personal information.
• Withdraw consent at any time (where processing is based on consent).
• Object to or restrict, or request limitation of certain processing activities involving your data.
• Opt out of marketing communications (unsubscribe link in emails).
• Request access to or data portability of certain personal information.
• Request information about categories of personal information collected, disclosed, or shared, as applicable under certain state privacy law.
• Lodge a complaint with a supervisory or regulatory authority.

Submit requests by emailing [email protected]. Please note, we may take reasonable steps to verify your identity before responding to certain requests, as permitted or required by applicable law.

10Children and Youth Privacy

CONDUCTR is committed to protecting the privacy and safety of children. In connection with our youth-related Services, including programs involving participants under 18, we seek to process personal information in a manner that is appropriate to the age and developmental needs of the participant and consistent with applicable child privacy and safeguarding principles. Our compliance practices, including our Children's Online Privacy Protection Act ("COPPA") related parental consent and youth privacy procedures in the United States, are designed to support responsible handling of children's personal information and age-appropriate privacy protections. When designing and operating youth-related programs, features, and communications, we consider:

• The nature of the Services provided;
• The sensitivity of the information involved;
• Safeguarding participant safety considerations;
• The need for age-appropriate privacy protections; and
• The rights and freedoms of minor participants.

We seek to limit the collection, use, retention, and disclosure of personal information relating to minors to what is reasonably necessary to provide, secure, administer, and improve youth-related Services consistent with applicable law.

We do not knowingly use personal information collected from participants under 18 for behavioral advertising, cross-context behavioral advertising, or automated profiling for marketing purposes.

Participants Under 13

Certain youth programs may be made available to participants under the age of 13. When we knowingly collect personal information from children under 13, we do so in accordance with COPPA and other applicable laws. Before collecting personal information from a child under 13:

• The parent or legal guardian will receive direct notice describing what information we collect, how the information may be used, and our disclosure practices.
• CONDUCTR will obtain verifiable parental consent through a method reasonably designed to confirm that the person providing consent is the child's parent or legal guardian. Acceptable methods include a signed consent form submitted digitally or by mail, or email confirmation combined with an additional verification step.
• Personal information collected from participants under 13 is used to provide, administer, support, secure, and improve the applicable youth program Services and related operations consistent with this Privacy Policy.
• Parents and legal guardians may request to review the personal information collected from their child, correct the information, request its deletion, and revoke consent for future collection or use of the child's information, subject to applicable legal limitations and operational requirements, by contacting [email protected]. Revocation of consent may result in the child's removal from the program.
• Session recordings involving participants under 13 may be treated as sensitive personal information and may be retained, processed, stored, and disclosed only as reasonably necessary to provide the Services, comply with legal obligations, protect safety and security, resolve disputes, or otherwise as permitted by applicable law.
• Acceptance of these Terms of Service alone does not satisfy any verifiable parental consent requirement under COPPA. A separate consent process will be completed at enrollment for all participants under 13.

Youth Program Participants Ages 13 Through 17

For participants ages 13 through 17, all registration, payment, and consent must be completed by a parent or legal guardian. Applicable state privacy laws may provide additional rights for minors in this age group. Parents or legal guardians may contact us at [email protected] to request access to, correction of, or deletion of their minor child's information.

Marketing and Likeness — Participants Under 18

Youth program participation may involve collection of audio, video, chat communications, and session recordings that may contain a child's voice, image, likeness, or other personal information reasonably necessary to provide and administer the program. We do not use the name, image, likeness, voice, or testimonial of any participant under 18 years of age for marketing, promotional, or advertising purposes without separate, explicit written consent from the parent or legal guardian. Consent provided within these Terms does not constitute authorization for marketing use of a minor's likeness. A standalone marketing consent form is required and will be provided separately at enrollment.

11Third-Party Links & Services

The Services may contain links to external sites not operated by us. We are not responsible for their privacy practices. We encourage you to review the privacy policies of every site you visit.

12Marketing and Promotional Use

By participating in the Services, adult participants (18 and older) acknowledge that CONDUCTR may request permission to use their name, image, likeness, testimonial, or program results for marketing and promotional purposes. Such use requires separate written consent and will not occur without it. You may withdraw marketing consent at any time by contacting [email protected] without affecting your continued access to the Services.

13Changes to This Privacy Policy

We may update this Policy periodically to reflect changes in our Services, legal obligations, operational practices, technology, or other business developments. If we make material changes, we will notify you by posting an updated version with a new "Last updated" date and, where appropriate, through email or in-service notice. Your continued use of the Services following the effective date of an updated Privacy Policy constitutes acknowledgment of the updated Policy to the extent permitted by applicable law.

14Contact Us

For questions about this Privacy Policy or our privacy practices, contact us at [email protected].