SkillClass

PRIVACY POLICY

Last Updated: October 3, 2026

This Privacy Policy explains how CyrusX LLC, a California limited liability company authorized to transact business in Michigan, doing business as SkillClass and operating from West Bloomfield, Michigan ("SkillClass," "we," "us," or "our"), collects, uses, discloses, and protects Personal Information when you visit skillclass.com, when you purchase or use our courses and mentorship programs, and when you interact with our accounts on Instagram, Facebook, LinkedIn, TikTok, X, YouTube, or any other social or messaging platform where we operate an account now or in the future (each, a "Platform").

This Privacy Policy is part of and is governed by our Terms of Service Agreement. Capitalized terms used but not defined here have the meanings given in that agreement. Your Personal Information is not shared with unrelated third-party businesses except as expressly set forth in this Privacy Policy.

WE MAY MODIFY THIS PRIVACY POLICY AT ANY TIME IN OUR SOLE DISCRETION, SUBJECT TO APPLICABLE LAW. WHEN WE DO, WE WILL REVISE THE LAST UPDATED DATE AT THE TOP OF THIS PAGE, AND WHERE THE CHANGES ARE MATERIAL WE WILL TAKE REASONABLE STEPS TO BRING THEM TO YOUR ATTENTION. YOUR CONTINUED USE OF THE SERVICES AFTER THE REVISED LAST UPDATED DATE IS A MANIFESTATION OF ASSENT TO THE MODIFIED PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MUST STOP USING THE SERVICES.

1. Definitions.

As used in this Privacy Policy:

●1.1 "Cookies" means small text files placed on your device to store data that can be recalled by a web server in the domain that placed the Cookie.

●1.2 "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

●1.3 "Platform" has the meaning given above.

●1.4 "Services" means the skillclass.com website, the courses, mentorship programs, and program materials we make available, our Platform accounts and automated messaging features, and any associated services, software, features, or content made available by SkillClass.

●1.5 "Tracking Technologies" means Cookies and similar technologies, including pixel tags, web beacons, JavaScript tags, local storage objects, software development kits, and similar tracking technologies.

●1.6 "You" or "Your" refers to the individual visiting or using the Services.

2. Types of Personal Information We Collect.

Information You Give Us Directly

●Your name, email address, and, where you provide it, your telephone number, mailing address, country, institution, training level, and specialty.

●Your account credentials for the Services, held in hashed form by our course platform.

●The content of messages, comments, replies, mentions, support requests, and forms you send us.

●Material you submit in connection with a mentorship program, including manuscript drafts, research summaries, and related correspondence.

●Recordings and transcripts of mentorship sessions and calls, where the session is recorded. Section 8 describes how that works.

●Photographs, video, audio, and testimonial content you submit, and the selections you make on our Consent and Media Release form.

●Records of your purchases, including what you purchased, when, the amount, and the payment method type and last four digits. We do not receive or store your full payment card number.

Information Collected Automatically

●IP address, browser type and version, operating system, device type, screen size, language, and referring and exit pages.

●Pages viewed, time on page, links clicked, videos and lessons started and completed, and other interactions with the Services.

●Approximate location inferred from your IP address. We do not collect precise real-time geolocation.

●Information collected through Tracking Technologies as described in Section 5.

Information We Receive From the Platforms

●Your user ID and public username or handle on that Platform.

●Your public display name and profile picture, where the Platform provides them.

●The content of messages, comments, replies, or mentions you send to our accounts, with their timestamps, conversation identifiers, and message identifiers.

●Publicly available profile information the Platform exposes, such as a professional headline or public biography.

●Aggregate engagement metrics the Platform reports to us, such as counts of views, likes, and follows.

What we actually receive from a Platform varies by Platform and depends on that Platform’s own settings and permissions and on your privacy choices within it.

Information We Do Not Collect

We do not collect your password to any Platform or other personal internet account, your full payment card details, your government identifiers, or any data from your accounts beyond what you send us directly or what a Platform makes available to us.

We do not seek to collect sensitive Personal Information as that term is defined under California law, and we do not use or disclose it for any purpose other than those permitted without an option to limit. Please do not send us personal health information, medical records, images of medical studies, or details about your own or another person’s medical condition. These channels are not confidential, are not covered by the Health Insurance Portability and Accountability Act, and we cannot evaluate individual cases. If you send that information anyway, we will handle it under this Privacy Policy and delete it when we are able to.

3. Sources of Personal Information Collection.

●Directly from you, when you contact us, create an account, complete a form, make a purchase, or participate in a program.

●Automatically from your device and browser, through Tracking Technologies, when you use the Services.

●From the Platforms, when you interact with our accounts on them.

●From our service providers, including our course and checkout platform, our payment and installment providers, our email platform, and our analytics and advertising partners.

●Derived internally, as inferences drawn from the information above.

4. Categories of Personal Information, Purposes, Disclosures, and Retention.

The table below sets out, for each category of Personal Information we collect, the sources it comes from, the business or commercial purposes for which we use it, the categories of third parties to whom we disclose it, and how long we keep it.

We do not collect biometric information, precise geolocation, government identifiers, financial account numbers, or the contents of mail, email, or text messages other than those you send to us. We do not knowingly collect Personal Information from anyone under eighteen (18) years of age. The retention periods above are our current standard periods. We may keep information longer where a legal hold, an investigation, or an actual or anticipated legal claim requires it, or where a longer period is required by law.

5. Cookies and Similar Technologies.

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the Cookie. We use Cookies and similar technologies, including pixel tags, web beacons, JavaScript tags, local storage objects, and similar tracking technologies (together, "Tracking Technologies"), to enable our systems to recognize your browser, deliver certain features, analyze usage, and support advertising and analytics functions.

Pixel tags, web beacons, and clear GIFs are tiny graphics embedded in web pages or emails that function similarly to Cookies. They track whether a page or an email has been opened, clicked, or shared, and they transmit that information to the operator of the pixel.

The table below sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

6. How SkillClass Uses Your Personal Information.

●To provide, operate, maintain, and improve the Services.

●To create and administer your account, deliver the courses and mentorship programs you purchase, and schedule and conduct sessions.

●To process payments, installments, refunds, and chargebacks.

●To read and respond to your messages, comments, replies, mentions, and support requests, including through the automated features described in Section 7.

●To send you transactional and service communications about your purchases, your account, and the programs you are enrolled in.

●To send you marketing communications where you have not opted out, and to measure whether they are effective.

●To advertise the Services, where we run advertising, including through interest-based and retargeted advertising on the Platforms and on search and display networks, and to measure the results of that advertising.

●To understand aggregate engagement so that we can improve the content we publish.

●To detect, prevent, and address security incidents, fraud, and misuse of the Services.

●To comply with legal obligations, to establish, exercise, or defend legal claims, and to protect our rights and the rights of others.

We will not use your Personal Information for a materially different, unrelated, or incompatible purpose without telling you first.

7. Automated and AI-Assisted Processing.

7.1 Some replies from our Platform accounts are generated automatically using artificial intelligence assisted software rather than written by a person in real time. Message and comment content may be processed by a third-party artificial intelligence service provider for the sole purpose of composing a reply.

7.2 We require every service provider that processes Personal Information on our behalf, including any artificial intelligence provider, to implement appropriate data security measures and to process that information only in accordance with our instructions and applicable law. We do not authorize service providers to use your information for their own purposes except as permitted by this Privacy Policy or required by law.

7.3 Model training. The artificial intelligence providers that process message content for us under written terms, OpenAI and Anthropic, are contractually restricted from using that content to train or improve their models. Those restrictions are subject to a limited exception described in 7.4. Other service providers named in Section 9.1 process Personal Information under their own terms, which in some cases permit them to use data derived from customer content to develop and improve their own services. Where that is so, we have elected out of that use where an election is offered to us.

7.4 Review of flagged content. Where an artificial intelligence provider’s automated systems flag content as a suspected violation of that provider’s policies, the provider may retain that content and have it reviewed, including by people working for the provider or its own service providers, in order to enforce those policies and prevent abuse. That review can occur outside the United States. This is the one circumstance in which message content you send us may be read by someone other than SkillClass and the recipients described in Section 9.

7.5 Automated replies may be inaccurate or incomplete and are not reviewed by a person before they are sent. If you would prefer to communicate with a person instead of an automated system, say so in your message, reply "STOP" to opt out of automated replies, or email [email protected].

7.6 We do not make decisions producing legal or similarly significant effects about you solely by automated means.

8. Recording of Sessions and Calls.

8.1 What this Section covers. Sales and business telephone calls with SkillClass, mentorship sessions, onboarding and discovery calls, and any other live audio or video call between you and SkillClass or a mentor.

8.1.1 Sales and business calls. Telephone calls with SkillClass about enrollment, billing, and support are placed and received through our business telephone platform, and those calls are recorded and, when available, transcribed.

8.1.2 Mentorship sessions. Mentorship sessions do not take place on our business telephone platform.

8.2 Notice and consent. We tell you before a recording starts and you may decline. If you decline, the session proceeds without a recording, or, where a recording is integral to the session, we will say so and you may end the call without penalty and reschedule under our Terms of Service Agreement. We do not record a call without telling you first. Recording laws differ from state to state and some require the consent of everyone on the call, so we obtain your consent before recording regardless of where you are.

8.3 What we record and why. Where a session is recorded, the recording may capture audio, video, anything shared on screen, the in-meeting chat, and an automated transcript. We use recordings so that you can review the session afterwards, to train and supervise our own staff and mentors, and to resolve a question about what was said or agreed. We do not use session recordings in advertising, testimonials, or other promotional material. Promotional use of your name, likeness, image, or voice is handled through our Consent and Media Release form and through that form only.

8.4 Who receives a recording. Quo, formerly OpenPhone, is our business telephone platform and it stores recordings of sales and business calls (quo.com). Where a call is scheduled through Calendly, and a meeting assistant is enabled, Calendly may create a recording, transcript, or written summary of that call (calendly.com). Each of these providers acts on our instructions under Section 9.2. Your mentor and the SkillClass staff who support your program have access. We do not disclose a recording to any other third party except as Section 9.3 describes.

8.5 Retention. Recordings and transcripts are kept for up to 12 months from the call date and are then deleted, except where Section 13.2 applies.

8.6 Your choices. You may ask us for a copy of a recording of a session you attended, ask us to delete it, or decline recording for any future session. Use the process in Section 17.

8.7 Other people on the call. Do not invite anyone else to a recorded session without telling us first, and do not record a session yourself, or share a recording we gave you, without our written permission and the permission of everyone recorded.

9. Sharing of Your Personal Information.

Service Providers and Partners

9.1 We disclose Personal Information to the following categories of third parties, each acting on our behalf or for the purposes described:

●Kajabi, which hosts our website, store, checkout, customer accounts, course and program materials, and our email marketing campaigns (kajabi.com).

●Stripe, which processes card payments (stripe.com), and Klarna, which assesses and administers installment plans under its own terms and privacy policy (klarna.com).

●Hosting, infrastructure, storage, and security providers.

●ManyChat, which collects names, email addresses, and telephone numbers through our social channels and sends automated messages and marketing communications (manychat.com).

●Zapier, which moves information between ManyChat, Kajabi, and our own restricted spreadsheets (zapier.com).

●Metricool, which is website and social media analytics, including measurement of website visits and interactions.

●Respond.io, whose AI Agent composes automated replies to your messages, qualifies enquiries, and escalates them to a person, as described in Section 7. Respond.io carries our WhatsApp, voice, and email channels and records calls placed on its voice channel (respond.io).

●Quo, formerly OpenPhone, which provides our business telephone service, carries our telephone calls and any text messages, and stores call recordings as described in Section 8 (quo.com).

●Calendly, which schedules calls and meetings, and which, where its meeting assistant is enabled, records, transcribes, and summarizes them (calendly.com).

●OpenAI and Anthropic, whose application programming interfaces process message content under their commercial terms in order to produce those replies (openai.com, anthropic.com).

●Analytics providers, which measure how the Services are used.

●Advertising partners, which deliver and measure our advertising as described in Section 19, where we run advertising.

●The Platforms themselves, including Meta Platforms, Inc., LinkedIn Corporation, TikTok Inc., X Corp., and Google LLC, to the extent required for their messaging and content services to function.

●Zoom or Google Meet, used to conduct mentorship sessions.

●Professional advisors, including our accountants, auditors, and attorneys.

This list may not be exhaustive as to all the third parties SkillClass may share your Personal Information with. SkillClass maintains internal records of the third parties that receive your Personal Information. A current list of third-party service providers is available on request at [email protected].

Processor Control

9.2 We require all service providers that process Personal Information on our behalf to implement appropriate data security measures and to process that information only in accordance with our instructions and applicable law. We do not authorize service providers to use your information for their own purposes except as permitted by this Privacy Policy or required by law.

9.2.1 Providers acting for their own purposes. Several of the providers named in 9.1 act on our instructions for the information we give them and, separately, for their own purposes as to information they generate about how their own services are used. That second category includes account, billing, and usage information, and in some cases information about visitors to our Website, and it is governed by that provider’s own privacy policy rather than by this one. Kajabi, Zapier, ManyChat, Calendly, and Metricool each operate in this way. We do not control that processing, and we link to each provider’s site in 9.1 so that you can read its policy.

9.2.2 Changes to sub-processors. Each provider named in 9.1 engages its own sub-processors and may change them. The notice we receive, and the time we have to object, differ from provider to provider and in some cases are short. We review changes we are notified of, and a current list of the providers we use is available on request at [email protected].

Other Circumstances in Which We Disclose Information

9.3 We also disclose Personal Information in the following circumstances:

●With your consent, or at your direction.

●As necessary to provide the Services through trusted third parties.

●With our parents, subsidiaries, successors, assigns, licensees, affiliates, and business partners.

●Where our business or its assets are purchased by a third party, as described in Section 23.

●To government authorities.

●Under court order, subpoena, or other valid legal process.

●To protect our employees, contractors, officers, managers, members, users, and owners.

●To prevent fraud or a violation of law, or to enforce our Terms of Service Agreement.

●Where we are otherwise legally obligated to do so.

Each Platform Collects on Its Own Account

9.4 Each Platform independently collects information about you under its own privacy policy, over which we have no control. Your use of a Platform is governed by that Platform’s terms and privacy policy in addition to this one.

10. Our Role: Controller.

10.1 SkillClass is a controller, and a business as that term is used under California law, with respect to all Personal Information described in this Privacy Policy. We determine the purposes and means of processing it. The providers listed in Section 9.1 act as our service providers or processors, except for the Platforms and the advertising partners, which act as independent controllers or businesses for their own purposes as described in their own policies.

10.2 We do not process Personal Information on behalf of any customer as a processor, and we do not host end-customer data on behalf of any other business.

10.3 Where a service provider processes Personal Information on our behalf, we require a written agreement restricting its use of that information to our instructions and to the provision of its services to us.

11. No Liability for Third-Party Services and Third-Party Links.

11.1 Third parties whose services we use, and third-party websites and services reachable through the Services, have their own privacy policies, which govern their collection and use of information and over which we have no control.

11.2 Even after we delete information from our own systems, that information may remain available in a third-party provider’s database, in backups, or in a Platform’s records, subject to that party’s own retention practices.

11.3 SkillClass has no responsibility or liability for the collection, use, storage, or disclosure of information by any third-party provider, Platform, or website. Information you provide through the Services is provided at your own risk.

12. Personal Information Transfer and Storage.

12.1 SkillClass operates in the United States and our own records are held here. Personal Information is also processed by the service providers named in Section 9.1, and several of them, and the sub-processors they engage, operate outside the United States. Content delivery and infrastructure providers in particular may process information at the location closest to the person using the Services. We do not represent that Personal Information remains within the United States at all times.

12.2 The Services are offered to residents of the United States. We do not accept purchases from residents of the European Economic Area or the United Kingdom, and we do not offer the Services to them. If you access the Services from outside the United States, you do so on your own initiative, and you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those of your country.

13. Retention of Your Information.

13.1 We keep Personal Information only for as long as is necessary for the purposes for which it was collected, as described in this Privacy Policy. The current standard retention period for each category is stated in the table in Section 4.

13.2 We may keep Personal Information for longer where a legal hold or an investigation applies, where it is necessary to establish, exercise, or defend a legal claim, or where a longer period is required by tax, accounting, or other recordkeeping law.

13.3 When a retention period expires and no exception applies, we securely delete the information or irreversibly anonymize it so that it can no longer be associated with you.

13.4 Information may persist for a period in routine system backups and in the databases of third-party providers and Platforms, subject to their own retention practices.

14. Personal Information Security.

14.1 We use administrative, technical, and physical safeguards that are appropriate and commercially reasonable for a business of our size and the information we hold, including encrypted connections, access controls and restricted credentials, and secure storage of application access tokens.

14.2 No method of transmission over the internet and no method of electronic storage is completely secure, and we cannot assure the absolute security of your information. You are responsible for keeping your account credentials confidential.

14.3 If we discover a breach of security involving unencrypted Personal Information that has caused or is likely to cause substantial loss or injury, we will notify affected individuals without unreasonable delay, consistent with the Michigan Identity Theft Protection Act, MCL 445.61 et seq., and any other applicable state breach notification law.

15. No Users Under Age of 18.

15.1 The Services are intended for adults. You must be at least eighteen (18) years of age to create an account, to purchase a course or a mentorship program, or to submit media or testimonial content to us. We do not knowingly collect Personal Information from anyone under eighteen (18) and we do not knowingly permit anyone under eighteen (18) to purchase from us.

15.2 If we learn that we have collected Personal Information from a person under eighteen (18), we will delete it and close any associated account. If you believe we hold information about a person under eighteen (18), contact us at [email protected]. See also Section 26.

15.3 We do not sell or share the Personal Information of consumers under sixteen (16) years of age.

16. Communications and Marketing.

16.1 We send transactional and service communications about your purchases, your account, and the programs you are enrolled in. You cannot opt out of these while your account is open, because they are necessary to provide the Services.

16.2 We send marketing communications by email where you have given us your email address. You may opt out at any time by using the unsubscribe link in any marketing email or by emailing [email protected]. Opting out of marketing does not stop transactional and service communications.

16.3 You may opt out of automated replies on the Platforms as described in Section 7.5.

16.4 Telephone numbers and text messages. We collect a telephone number where you give us one, including through the messaging tools described in Section 9.1. Our messaging and business telephone platforms are able to send text messages, and we send them only to a person who has given prior express consent to receive them.

16.5 How text message consent works. Consent to receive text messages is separate from any other consent you give us, is never a condition of purchasing anything, and is limited to the program you agreed to receive messages about. We keep a record of each consent. Message frequency varies. Message and data rates may apply. You may stop receiving text messages at any time by replying STOP to any message, and we may send one final message confirming that you have been unsubscribed. Reply HELP for help, or email [email protected].

16.6 What is not a text message. Automated messages we send inside a Platform’s own messaging system, for example an Instagram or Facebook direct message, are not text messages and are covered by Section 7.

16.7 Before we start a new program. If we begin sending marketing text messages of a kind not described in 16.4, we will obtain your separate express consent first and will update this Privacy Policy and our Terms of Service Agreement before the first message goes out.

17. General Privacy Rights.

17.1 We extend the following rights to every user, regardless of where you live. You may ask us to:

●Confirm whether we hold Personal Information about you, and provide a copy of it.

●Correct Personal Information that is inaccurate or out of date.

●Delete Personal Information we hold about you, subject to the exceptions in Section 13.2.

●Provide your Personal Information in a portable, machine-readable format.

●Stop sending you marketing communications.

●Stop sending you automated replies.

●Opt out of the sharing of your Personal Information for cross-context behavioral advertising, as described in Section 19.

17.2 To make a request, email [email protected] with the subject line "Data Request." Include the email address associated with your account, or the username or handle and the Platform you used to contact us, and describe your request clearly enough for us to evaluate it.

17.3 Verification. We verify a request by confirming that it is associated with an email address linked to a registered account, or by matching the information you provide against our records. We cannot respond to a request we are unable to verify. We may ask for additional information for that purpose and will use it only to verify the request.

17.4 Authorized agents. An authorized agent may submit a request on your behalf with written permission signed by you, and we may require you to verify your own identity directly with us. A parent or guardian may submit a request on behalf of a minor in their care.

17.5 Timing. We acknowledge receipt within ten (10) business days and respond within forty-five (45) days. If we need more time, we will tell you why and how much longer we need, up to a total of ninety (90) days. There is no fee unless a request is manifestly unfounded or excessive, in which case we will explain our decision.

17.6 Appeal. If we decline your request in whole or in part, you may appeal by replying to our response or by emailing [email protected] with the subject line "Privacy Request Appeal" within a reasonable time. We will respond in writing within forty-five (45) days with our decision and the reasons for it. If we deny the appeal, we will tell you how to contact your state attorney general to submit a complaint.

17.7 Non-discrimination. We will not discriminate against you for exercising any of these rights.

17.8 Platform permissions. You can also revoke our access at any time from within the relevant Platform’s own settings, for example under Apps and Websites on Instagram and Facebook, Permitted Services on LinkedIn, or the equivalent authorization screen on another Platform.

18. California Users’ Rights.

18.1 This Section supplements the rest of this Privacy Policy and applies to consumers residing in California under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, Cal. Civ. Code § 1798.100 et seq. Where this Section conflicts with anything else in this Privacy Policy, this Section controls for California residents.

18.2 The categories of Personal Information we collect, the sources, the business and commercial purposes, the categories of third parties to whom we disclose it, and the retention period for each category are set out in the table in Section 4. We have collected each of those categories in the preceding twelve (12) months.

Your California Rights

●Right to Know About Personal Information Collected, Disclosed, or Sold or Shared. You may request the categories and specific pieces of Personal Information we have collected about you, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties to whom we disclose it.

●Right to Request Deletion of Personal Information. You may request that we delete Personal Information we collected from you, subject to the exceptions permitted by law and described in Section 13.2.

●Right to Correct Inaccurate Personal Information. You may request that we correct inaccurate Personal Information we maintain about you, taking into account its nature and the purposes of processing.

●Right to Opt-Out of the Sale or Sharing of Personal Information. We do not sell Personal Information for monetary consideration. We do share Personal Information for cross-context behavioral advertising, and you have the right to opt out. See Section 19.

●Right to Limit Use of Sensitive Personal Information. We do not collect or process sensitive Personal Information as defined in Cal. Civ. Code § 1798.121 for any purpose that would give rise to this right. If that changes, we will update this Privacy Policy and provide the mechanism.

●Right to Non-Discrimination for Exercising CCPA Rights. We will not deny you goods or services, charge you a different price, or provide you a different level of service because you exercised a right.

●Shine the Light. Under California Civil Code § 1798.83, California residents may request information about disclosures of Personal Information to third parties for their own direct marketing purposes. We do not make those disclosures.

18.3 To exercise a California right, email [email protected] with the subject line "California Privacy Request" and follow the process in Sections 17.2 through 17.6. You may submit up to two requests to know in any twelve-month period. An authorized agent registered with the California Secretary of State may submit a request on your behalf. Our disclosure will cover the preceding twelve (12) month period.

19. Do Not Sell or Share My Personal Information; Opt-Out Preference Signals.

19.1 We do not sell your Personal Information for monetary consideration, and we have not done so in the preceding twelve (12) months.

19.2 Our use of advertising and analytics Tracking Technologies, including GA4 through Google Tag Manager, Google Ads conversion tracking, Meta Pixel, Metricool analytics, ManyChat’s website pixel or widget, and Respond.io’s website widget, may involve the "sharing" of Personal Information for cross-context behavioral advertising under the California Privacy Rights Act and similar laws. You have the right to opt out of this sharing. Under the California Privacy Rights Act, this type of sharing is regulated separately from the "sale" of Personal Information.

19.3 To opt out of sharing, email [email protected] with the subject line "Do Not Sell or Share My Personal Information." Include the email address associated with your account, and, so that we can apply your choice to Tracking Technologies on your browser, tell us which browser and device you use. We will apply your opt-out within fifteen (15) business days.

19.4 You may also use the advertising platform opt-out tools listed in the Targeting / Advertising (Non-Strictly Necessary) row of the table in Section 5, which operate at the level of the advertising platform rather than at the level of our Services.

19.5 Opt-out preference signals. Where our Services are technically able to receive and process an opt-out preference signal such as Global Privacy Control, we treat that signal as a valid request to opt out of the sharing of Personal Information for cross-context behavioral advertising for the browser or device that sent it. Where a signal is applied to a browser rather than to an account, it will not carry across your other browsers or devices, and we encourage you to use the email channel in Section 19.3 so that we can apply your choice to your account.

19.6 Do Not Track. Our Website does not respond to Do Not Track browser signals, because no common industry standard for them has been adopted. Do Not Track is a different mechanism from the opt-out preference signals described in Section 19.5.

20. Supplemental Notice for Residents of Other United States States.

20.1 A number of states other than California have enacted comprehensive consumer privacy laws. Residents of those states may have rights to confirm whether we process their Personal Information and to access it, to correct inaccuracies, to delete it, to obtain a portable copy, and to opt out of targeted advertising, the sale of Personal Information, and profiling in furtherance of decisions producing legal or similarly significant effects.

20.2 We honor these requests through the process described in Sections 17.2 through 17.6, regardless of whether your state has enacted such a law.

20.3 Right to appeal. If we decline a request, residents of states that provide an appeal right, and every other user, may appeal as described in Section 17.6. If the appeal is denied, you may contact your state attorney general to submit a complaint.

20.4 Universal opt-out mechanisms. Several states require controllers to honor a universal opt-out mechanism. Our treatment of those signals is described in Section 19.5.

20.5 Targeted advertising. Our advertising is described in Section 19. You may opt out through the channels described there.

20.6 We do not process Personal Information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

21. Notice to Nevada Residents.

21.1 Nevada law gives Nevada residents the right to direct a business not to sell certain covered information it has collected or will collect about them. We do not sell covered information as that term is defined under Nevada law. If you are a Nevada resident and wish to submit a request in any event, email [email protected] with the subject line "Nevada Opt-Out Request" and include the email address associated with your account.

22. Information for Michigan Residents.

22.1 SkillClass operates from West Bloomfield, Michigan. Michigan has not enacted a comprehensive consumer data privacy statute of the kind adopted in California and certain other states. The protections described in this Section arise from specific Michigan statutes and from the rights we extend voluntarily to all users regardless of residence.

Breach Notification

22.2 The Michigan Identity Theft Protection Act, MCL 445.61 et seq., requires notice to Michigan residents following a security breach involving unencrypted personal information where the breach has caused or is likely to cause substantial loss or injury. We will provide that notice without unreasonable delay and will include the information the statute requires.

Records of Educational and Media Purchases

22.3 The Michigan Preservation of Personal Privacy Act, MCL 445.1711 et seq., restricts disclosure of records identifying a customer as having purchased, leased, rented, or borrowed written materials, sound recordings, or video recordings. We do not disclose records identifying you as a purchaser of a course, a program, or recorded or written educational materials to any third party for that third party’s own marketing purposes. Section 9 describes the service providers and advertising partners that receive information in connection with the Services, and Section 19 describes how to opt out of sharing for cross-context behavioral advertising.

22.4 Removing your name. Where we disclose a record of that kind for the purpose of marketing goods and services to you, Michigan law gives you the right to have your name removed from any list we exchange or sell. To remove your name, email [email protected] with the subject line “Michigan Purchase Record Removal” and include the email address associated with your account. You may also write to us at the address in Section 27. We will remove your name within thirty (30) days of receiving your request.

Social Media Credentials

22.5 Michigan’s Internet Privacy Protection Act, MCL 37.271 et seq., prohibits employers and educational institutions from requiring a person to disclose credentials to a personal internet account. We will never ask you for the password to any social media or other personal account, and you should not provide one to us or to anyone claiming to represent us.

Unfair Practices

22.6 Nothing in this Privacy Policy is intended to waive any right you may have under the Michigan Consumer Protection Act, MCL 445.901 et seq., or any other Michigan law that cannot be waived by agreement.

Michigan Requests

22.7 Michigan residents may use the process described in Section 17 to access, correct, or delete information we hold. Email [email protected] with the subject line "Michigan Privacy Request." We respond to these requests on the same terms we offer residents of states with comprehensive privacy statutes.

23. Purchase or Sale of the Services or Other Assets.

23.1 If SkillClass is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, Personal Information may be among the assets transferred or disclosed to the parties to that transaction and their advisors. We will require any acquirer to honor the commitments in this Privacy Policy with respect to information transferred to it, and we will notify you before your Personal Information becomes subject to a different privacy policy.

24. How to Stop SkillClass From Collecting Your Personal Information.

●Stop using the Services, and do not submit information to us or to our Platform accounts.

●Block or disable Cookies and similar technologies through your browser settings and the tools listed in Section 5.

●Opt out of sharing for cross-context behavioral advertising as described in Section 19.

●Unsubscribe from marketing email as described in Section 16.2.

●Opt out of automated replies as described in Section 7.5.

●Revoke our access through the relevant Platform’s own settings as described in Section 17.8.

●Close your account and request deletion as described in Section 17.

Some of these steps will limit or prevent your use of the Services.

25. Your Obligations.

25.1 You agree to provide accurate information, to keep your account credentials confidential, not to submit another person’s Personal Information without that person’s permission, and not to submit personal health information or other sensitive information we have asked you not to send. You are responsible for the information you choose to submit through the Services.

26. Children’s Online Privacy Protection Policy.

26.1 The Services are not directed to children under thirteen (13) years of age, and we do not knowingly collect Personal Information from them. Several Platforms set their own minimum age of thirteen (13) or higher. If you believe a child under thirteen (13) has provided us with Personal Information, contact us at [email protected] and we will delete it promptly. The minimum age to use the Services is eighteen (18), as stated in Section 15.

27. Contact and Notices.

Questions about this Privacy Policy, or about how we handle your information, may be sent to:

CyrusX LLC, doing business as SkillClass

6311 Haggerty Rd, Unit 890

West Bloomfield, MI 48322

United States

[email protected]

skillclass.com