ENGAGEMENT FINDER® PRIVACY POLICY

Effective Date: August 14, 2026
Last Updated: August 14, 2026

Engagement Finder® respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how Frye Consulting Group, doing business as Engagement Finder® (“Engagement Finder,” “Engagement Finder®,” “we,” “us,” or “our”) collects, uses, processes, discloses, stores, and protects personal information when you access or use our websites, applications, eLearning platform, self-assessments, digital workbooks, courses, community features, forums, events, webinars, artificial intelligence-enabled features, eCommerce store, merchandise services, customer support, and other products or services that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy should be read together with our Terms of Service, Cookie Policy, applicable Return and Refund Policy, and any additional privacy notice presented for a specific Engagement Finder® product, feature, application, educational program, or service.

By using the Services, you acknowledge the practices described in this Privacy Policy.

Where consent is legally required for a particular processing activity, we will request that consent separately.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through Engagement Finder® Services that link to or reference this Privacy Policy.

It may apply to information collected when you:

• Visit an Engagement Finder® website or application;
• Create or manage an account;
• Complete an Engagement Finder® self-assessment;
• Receive assessment results, reports, recommendations, or learning resources;
• Participate in courses, learning activities, webinars, or events;
• Use a digital or electronic workbook;
• Participate in forums, community discussions, topics, or other interactive features;
• Make a purchase;
• Join a subscription or membership, where offered;
• Contact customer or technical support;
• Communicate with Engagement Finder®;
• Subscribe to marketing communications;
• Interact with Engagement Finder® through authorized third-party platforms; or
• Otherwise use a Service that references this Privacy Policy.

A separate or supplemental privacy notice may apply to child-directed services, organizational accounts, school programs, specific applications, research activities, or other specialized Engagement Finder® offerings.

2. What Is Personal Information?

For purposes of this Privacy Policy, “personal information,” “personal data,” or similar terms generally mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identified or identifiable person or household.

The precise definition may vary depending upon the law applicable to you.

Personal information generally does not include information that has been properly aggregated, anonymized, or deidentified so that it cannot reasonably be associated with an identifiable individual.

3. Categories of Personal Information We May Collect

The personal information we collect depends upon how you interact with Engagement Finder® and which Services you use.

We may collect the following categories of information.

1. Identification and Contact Information

This may include:

• First and last name;
• Username or display name;
• Email address;
• Telephone number;
• Mailing or billing address;
• Organization or company;
• Job title or professional affiliation; and
• Other contact information you choose to provide.

1. Account and Authentication Information

This may include:

• Username;
• Account identifier;
• Password or encrypted authentication credentials;
• Account preferences;
• Account status;
• Sign-in history; and
• Security or authentication information.

Passwords should be protected using appropriate technical safeguards and should not be stored in readable plain-text form.

1. Assessment Information

When you participate in an Engagement Finder® assessment, we may collect information such as:

• Assessment responses;
• Selected answers;
• Assessment completion information;
• Scores;
• Style classifications;
• Orientation classifications;
• Engagement patterns;
• Assessment reports;
• Personalized recommendations;
• Related reflections or exercises;
• User-generated goals associated with the assessment experience; and
• Inferences generated from assessment responses.

Assessment information may reveal or allow us to infer information about your preferences, tendencies, communication approach, leadership approach, decision-making approach, personality-related characteristics, engagement styles, or other characteristics addressed by the applicable assessment.

Engagement Finder® will process assessment information for the purposes described in this Privacy Policy and the applicable assessment experience.

1. eLearning and Course Information

We may collect information relating to your learning activity, including:

• Courses enrolled in;
• Lessons viewed;
• Course progress;
• Completion status;
• Quiz or knowledge-check responses;
• Workbook activity;
• Certificates or badges earned;
• Webinar or event attendance;
• Learning preferences;
• Resources accessed; and
• Related platform activity.

1. Community and User-Generated Content

If you participate in community areas, forums, topics, discussions, comments, profiles, networking functions, virtual events, or similar features, we may collect information you choose to submit, including:

• Posts;
• Comments;
• Questions;
• Replies;
• Profile information;
• Images;
• Uploaded files;
• Discussion activity;
• Reactions;
• Forum participation; and
• Other User Content.

Please use care when posting information to community areas.

Information you voluntarily make available through a public or member-visible area may be viewed, copied, shared, or used by other users according to the visibility settings of that area.

You should not post Social Security numbers, financial-account information, passwords, medical records, government identification numbers, or other highly sensitive information in community areas.

1. Purchase and Transaction Information

When you purchase a product or Service, we may collect information such as:

• Products or Services purchased;
• Order number;
• Transaction date;
• Purchase amount;
• Billing information;
• Shipping information;
• Subscription status;
• Payment status;
• Refund or return history; and
• Related customer-service information.

1. Payment Information

Payments may be processed by third-party payment processors.

Depending upon the payment method and processor used, payment providers may collect information such as your payment-card number, expiration date, billing address, financial account information, or digital-wallet information.

Engagement Finder® may receive transaction confirmations, payment status, limited card information such as card type or last four digits, or other information needed to manage a transaction.

We do not intend to retain complete payment-card information unless necessary and handled in accordance with applicable payment-security requirements.

1. Device, Technical, and Usage Information

When you access the Services, we and our authorized technology providers may automatically collect information such as:

• Internet Protocol (IP) address;
• Browser type;
• Device type;
• Operating system;
• Device identifiers;
• Language settings;
• Approximate location derived from IP address;
• Referring and exit pages;
• Pages or screens viewed;
• Links clicked;
• Date and time of access;
• Session information;
• Login activity;
• Error reports;
• Interaction data;
• Cookie identifiers; and
• Other technical information relating to your use of the Services.

1. Communications and Customer Support

If you communicate with Engagement Finder®, we may collect:

• Your contact information;
• The content of your message;
• Customer-support requests;
• Technical-support information;
• Complaint or feedback information;
• Survey responses; and
• Other information you voluntarily provide.

Where legally permitted and appropriately disclosed, certain support sessions, webinars, meetings, or calls may be recorded.

1. Event and Webinar Information

If you register for or attend an Engagement Finder® webinar, virtual event, live training, or in-person event, we may collect:

• Registration information;
• Attendance information;
• Questions submitted;
• Poll responses;
• Chat participation;
• Feedback;
• Event preferences; and
• Related communications.

1. Professional, Educational, or Organizational Information

Where relevant to a Service, you may provide information regarding:

• Employer;
• School or educational institution;
• Industry;
• Job function;
• Professional role;
• Educational role;
• Professional interests; or
• Other organizational affiliations.

1. Information Derived or Inferred From Other Information

We may create reasonable inferences from information you provide or your use of the Services for purposes such as:

• Generating assessment results;
• Providing recommendations;
• Personalizing learning resources;
• Improving Services;
• Understanding platform engagement; or
• Providing features you request.

1. Sensitive Personal Information

Engagement Finder® does not intentionally require users to provide highly sensitive personal information unless reasonably necessary for a particular Service and appropriately disclosed.

Depending upon the Services used and information voluntarily supplied, we could receive information that qualifies as “sensitive personal information” or “sensitive data” under certain laws.

Where applicable law requires consent or imposes additional restrictions on processing sensitive data, we will apply those requirements.

4. Sources of Personal Information

We may collect personal information from:

You Directly

For example, when you create an account, take an assessment, make a purchase, submit a form, participate in a community, or contact us.

Your Use of the Services

Certain device, usage, cookie, analytics, security, and technical information may be collected automatically.

Service Providers

We may receive information from payment processors, website hosts, eCommerce platforms, fulfillment providers, customer-support systems, webinar platforms, analytics services, or other service providers assisting us in providing the Services.

Organizations That Provide Access to Engagement Finder®

If your access is sponsored, purchased, or administered by an employer, government organization, school, educational institution, nonprofit organization, consultant, or other organization, that organization may provide us with information necessary to establish or manage your participation.

Third-Party Platforms

If you interact with Engagement Finder® through social media, third-party login services, video platforms, event platforms, or other integrations, we may receive information consistent with your settings and the third party's privacy practices.

Publicly Available Sources

Where lawful and appropriate, we may receive business or professional information from publicly available sources.

5. How We Use Personal Information

We may use personal information for the following legitimate business and operational purposes.

Provide and Operate the Services

Including to:

• Create and manage accounts;
• Authenticate users;
• Provide assessments;
• Calculate or generate assessment results;
• Generate reports and recommendations;
• Deliver courses and learning materials;
• Track learning progress;
• Provide digital workbooks and resources;
• Operate community features;
• Provide customer and technical support; and
• Deliver other requested Services.

Process Purchases and Transactions

Including to:

• Process payments;
• Fulfill purchases;
• Deliver digital products;
• Coordinate merchandise fulfillment;
• Process shipping;
• Send transactional communications;
• Manage subscriptions;
• Process returns or refunds; and
• Maintain appropriate transaction records.

Personalize the Engagement Finder® Experience

Including to personalize:

• Assessment feedback;
• Recommendations;
• Educational resources;
• Learning pathways;
• Platform features;
• Communications; and
• Relevant content.

Maintain and Improve the Services

Including to:

• Analyze how Services are used;
• Identify technical problems;
• Improve user experience;
• Develop new features;
• Evaluate platform performance;
• Improve assessments and learning resources; and
• Conduct quality assurance.

Protect Engagement Finder® and Its Users

Including to:

• Detect and prevent fraud;
• Protect account security;
• Investigate suspicious activity;
• Prevent platform abuse;
• Enforce our Terms of Service;
• Protect intellectual property;
• Maintain system integrity; and
• Protect the safety and rights of Engagement Finder®, users, and others.

Communicate With You

Including to:

• Respond to questions;
• Provide support;
• Deliver account notifications;
• Send order information;
• Provide assessment or learning notifications;
• Send security notices;
• Communicate Service changes; and
• Provide other administrative communications.

Marketing and Engagement

Where legally permitted, we may use contact information to communicate about:

• Engagement Finder® products;
• New features;
• Events;
• Webinars;
• Educational opportunities;
• Community activities;
• Promotions; or
• Other information we believe may be relevant.

You may opt out of marketing communications as described below.

Legal and Compliance Purposes

Including to:

• Comply with applicable laws;
• Respond to lawful governmental requests;
• Enforce agreements;
• Establish, exercise, or defend legal claims;
• Maintain legally required records; and
• Meet regulatory, tax, accounting, and compliance responsibilities.

6. Assessment Information and Privacy

Engagement Finder® recognizes that assessment responses and results may be personally meaningful to users.

We use assessment information to provide the assessment experience, generate results and recommendations, personalize educational resources, improve the Services, maintain appropriate records, and perform other activities described at the point of collection.

Individual assessment results will not intentionally be made publicly available by Engagement Finder® unless you choose to share them or expressly authorize publication.

We may use aggregated or appropriately deidentified assessment information to understand trends, evaluate assessment performance, conduct research, improve our methodology, develop products, or create statistical insights, provided the information is handled in a manner designed not to identify an individual.

Nothing in this Privacy Policy authorizes another user to obtain, scrape, compile, disclose, sell, or otherwise misuse another user's assessment information.

7. Artificial Intelligence and Automated Processing

Certain Engagement Finder® Services may incorporate artificial intelligence, machine learning, algorithmic processing, or other automated technologies.

These technologies may be used to:

• Analyze assessment responses;
• Generate personalized results;
• Recommend content;
• Generate or animate educational material;
• Assist with customer support;
• Improve platform functionality;
• Identify patterns in platform use; or
• Provide other features described to users.

Personal information submitted to an AI-enabled feature may be processed by Engagement Finder® or by authorized technology providers assisting us in delivering that feature.

Where third-party technology providers process personal information on our behalf, we seek to use appropriate contractual, privacy, confidentiality, and security safeguards consistent with the nature of the Services and applicable law.

Engagement Finder® does not intend to use automated processing as the sole basis for decisions that produce legal or similarly significant effects concerning an individual unless that use is expressly disclosed and permitted by applicable law.

Where applicable law provides rights concerning automated decisionmaking or profiling, Engagement Finder® will provide the notices, access, opt-out mechanisms, or other rights required by that law.

8. Organizational, Employer, and Sponsored Accounts

An organization may purchase, sponsor, or administer access to certain Engagement Finder® Services.

Organizations may include employers, government entities, educational institutions, schools, nonprofits, professional associations, consultants, or other customers.

In these arrangements, designated administrators may be able to access certain information associated with participants, depending upon the Service and the organization's agreement with Engagement Finder®.

Such information may include:

• Participant name;
• Account status;
• Course enrollment;
• Course progress;
• Completion information;
• Assessment participation;
• Assessment results;
• Reports; or
• Other information expressly identified to participants.

Engagement Finder® should provide notice before collection whenever an organizational administrator will have access to individual assessment results or other significant user information.

If your account is provided by an organization, you should review any notices supplied by that organization regarding its use of your information.

An organization's independent use of information it receives from Engagement Finder® may be governed by that organization's own policies and applicable law.

9. Schools and Educational Institutions

Where Engagement Finder® provides Services to or through a school, school district, college, university, teacher, or other educational institution, additional contractual terms and privacy requirements may apply.

Depending upon the arrangement, an educational institution may determine the purposes for which certain student or educational information is processed, while Engagement Finder® may process that information on the institution's behalf.

Where applicable, Engagement Finder® will seek to process student information consistently with contractual requirements and applicable student-privacy laws.

Information collected through a school-sponsored account will not be used for unrelated commercial purposes where such use is prohibited by applicable law or contractual obligations.

Where an educational institution controls the applicable education record, requests concerning that record may need to be directed to the institution.

Nothing in this Privacy Policy expands or reduces rights provided by applicable student-privacy law.

10. When We Disclose Personal Information

Engagement Finder® does not disclose personal information indiscriminately.

We may disclose personal information in the following circumstances.

Service Providers and Processors

We may provide personal information to companies that perform services on our behalf, such as:

• Website and application hosting;
• Cloud storage;
• Database services;
• Payment processing;
• eCommerce services;
• Order fulfillment;
• Print-on-demand services;
• Shipping and logistics;
• Email delivery;
• Customer support;
• Cybersecurity;
• Fraud prevention;
• Analytics;
• Video conferencing;
• Webinar hosting;
• Artificial intelligence technology;
• Marketing technology;
• Professional services; and
• Other operational support.

Service providers receive information reasonably necessary to perform the functions for which they are engaged and are expected to handle information consistently with applicable contractual and legal requirements.

Organizational Customers

If your participation is sponsored or administered by an organization, we may provide information to authorized administrators as disclosed to you and consistent with the applicable arrangement.

At Your Direction

We may disclose information when you direct us to do so or when you use a Service designed to share information with another person.

Public or Community Areas

Content you intentionally post to a public or member-visible community area may be visible to other users according to the applicable settings.

Legal and Safety Requirements

We may disclose personal information when we reasonably believe disclosure is necessary to:

• Comply with law;
• Respond to valid legal process;
• Respond to lawful governmental requests;
• Protect a person's safety;
• Investigate fraud or security incidents;
• Protect Engagement Finder®;
• Protect users or third parties;
• Enforce our agreements; or
• Establish, exercise, or defend legal rights.

Business Transactions

If Engagement Finder® undergoes or evaluates a merger, financing, acquisition, restructuring, bankruptcy, sale of assets, transfer of intellectual property, or similar business transaction, personal information may be disclosed or transferred in connection with that transaction, subject to applicable law.

11. Sale, Sharing, and Targeted Advertising

Engagement Finder® does not sell personal information to third parties for monetary consideration as part of a business model involving the sale of customer information.

However, privacy laws in some jurisdictions define “sale,” “sharing,” or “targeted advertising” more broadly than an exchange of information for money.

For example, certain cookies, pixels, analytics tools, social-media technologies, or advertising services may involve disclosures that are legally classified as “sale,” “sharing,” or processing for targeted advertising even when Engagement Finder® does not receive money in exchange for the information.

Where our use of these technologies creates a legally recognized opt-out right, we will provide an appropriate method to exercise that right.

12. Cookies and Similar Technologies

We and our authorized providers may use cookies, pixels, tags, software development kits, local storage, and similar technologies.

These technologies may be used for:

Strictly Necessary Functions

Such as:

• Maintaining sessions;
• Authenticating users;
• Processing purchases;
• Providing security;
• Remembering essential settings; and
• Maintaining website functionality.

Preferences

Such as remembering settings or choices.

Analytics and Performance

Such as understanding:

• Website traffic;
• Feature usage;
• User interaction;
• Error rates; and
• Platform performance.

Advertising and Marketing

Where used, certain technologies may help:

• Measure advertising;
• Understand campaign effectiveness;
• Reach interested audiences; or
• Provide advertising based upon user interactions.

Where required, non-essential cookies will be subject to appropriate consent or opt-out mechanisms.

Additional information may be provided in our Cookie Policy or cookie preference center.

13. Browser-Based Privacy Signals

Certain jurisdictions require businesses to recognize qualifying browser-based or device-based privacy preference signals.

Where legally required and technically applicable, Engagement Finder® will process recognized opt-out preference signals in accordance with applicable law.

Such signals may include technologies commonly referred to as Global Privacy Control or other legally recognized universal opt-out mechanisms.

A privacy signal may apply only to the browser or device from which it is transmitted unless applicable law requires otherwise.

14. Marketing Communications

You may opt out of promotional email communications by using the unsubscribe link provided in the communication or by contacting Engagement Finder® through the methods described below.

Opting out of marketing communications will not necessarily stop non-promotional communications required to administer your account, deliver a purchase, provide a requested Service, communicate security information, or otherwise maintain our relationship with you.

We will process marketing opt-out requests in accordance with applicable law.

15. Deidentified and Aggregated Information

We may create aggregated, anonymized, statistical, or deidentified information from personal information.

We may use this information for purposes such as:

• Research;
• Platform improvement;
• Assessment development;
• Product development;
• Statistical analysis;
• Reporting;
• Understanding engagement trends;
• Educational research; and
• Business planning.

Where information is maintained as legally recognized deidentified data, Engagement Finder® will not intentionally attempt to reidentify it except where permitted by law for legitimate purposes such as evaluating whether deidentification protections remain effective.

16. Data Minimization

Engagement Finder® seeks to collect personal information that is reasonably relevant to the purposes for which it is collected.

We do not intend to require personal information that is materially unnecessary to provide the requested Service.

Users should avoid providing sensitive or unnecessary personal information in open-text fields, forums, community areas, customer-support communications, or other areas unless it is reasonably necessary.

17. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or as otherwise permitted or required by law.

Retention periods may vary depending upon factors such as:

• The nature of the information;
• The Service provided;
• Whether an account remains active;
• Contractual requirements;
• The duration of a customer relationship;
• Legal, tax, and accounting obligations;
• Fraud-prevention requirements;
• Security needs;
• Intellectual-property protection;
• Dispute resolution;
• Applicable limitation periods; and
• User requests.

When information is no longer reasonably required, we may delete, anonymize, aggregate, or otherwise dispose of it in accordance with applicable requirements.

Backup copies may remain for a limited period as part of standard backup, security, or disaster-recovery processes.

18. Information Security

Engagement Finder® seeks to implement reasonable administrative, technical, and organizational safeguards appropriate to the nature of the personal information we process.

These safeguards may include measures relating to:

• Account authentication;
• Access controls;
• Password security;
• Encryption where appropriate;
• Secure hosting;
• Software updates;
• Monitoring;
• Employee or contractor access;
• Vendor management;
• Data backup;
• Security testing;
• Incident response; and
• Other security controls.

However, no website, application, database, electronic communication, or information-security system can be guaranteed to be completely secure.

You are also responsible for protecting your account credentials and should promptly notify Engagement Finder® if you believe your account has been compromised.

19. Data Incidents

If Engagement Finder® becomes aware of a data-security incident involving personal information, we will investigate and respond based upon the nature and circumstances of the incident.

Where applicable law requires notification to individuals, regulators, law enforcement, business customers, or other parties, we will provide notification in accordance with applicable requirements.

20. Your Privacy Rights

Depending upon where you reside and the laws applicable to Engagement Finder®, you may have some or all of the following rights concerning your personal information:

Right to Know or Access

You may have the right to know whether we process personal information about you and request access to certain personal information.

Right to Correction

You may have the right to request correction of inaccurate personal information.

Right to Deletion

You may have the right to request deletion of personal information, subject to legal exceptions.

Right to Data Portability

You may have the right to receive certain personal information in a portable format.

Right to Opt Out of Sale or Sharing

Where applicable, you may have the right to opt out of the sale or sharing of personal information.

Right to Opt Out of Targeted Advertising

Certain jurisdictions provide the right to opt out of the processing of personal information for targeted advertising.

Right to Opt Out of Certain Profiling

Certain jurisdictions provide rights concerning profiling or automated processing used in connection with decisions that produce legal or similarly significant effects.

Right to Limit Certain Uses of Sensitive Personal Information

Where applicable, you may have the right to limit particular uses or disclosures of sensitive personal information.

Right to Withdraw Consent

Where processing is based upon consent, you may have the right to withdraw that consent.

Withdrawal does not necessarily affect processing that occurred lawfully before the withdrawal.

Right to Appeal

Certain jurisdictions provide the right to appeal a decision concerning a privacy request.

Right to Non-Discrimination

Engagement Finder® will not unlawfully discriminate or retaliate against you because you exercise a privacy right.

These rights are subject to exceptions and limitations under applicable law.

21. How to Exercise Your Privacy Rights

To submit an applicable privacy request, contact:

Email: info@engagementfinder.com

Mail:
Engagement Finder®
Attn: Privacy

Please describe the right you wish to exercise and provide information reasonably necessary for us to identify the relevant records.

We may need to verify your identity before completing certain requests.

We will not request substantially more information than reasonably necessary to verify a request.

For certain opt-out requests, identity verification may not be required or appropriate.

Where legally permitted, an authorized agent may submit a request for you. We may request reasonable evidence that the agent is authorized to act on your behalf.

We will respond within the timeframe required by applicable law.

22. Appeals of Privacy Decisions

If applicable law gives you the right to appeal our decision regarding a privacy request, you may submit an appeal to: info@engagementfinder.com.

Please identify the original request and explain why you believe the decision should be reconsidered.

We will evaluate and respond to qualifying appeals in accordance with applicable law.

23. Additional Information for California Residents

This section applies to California residents to the extent the California Consumer Privacy Act, as amended (“CCPA”), applies to Engagement Finder® and the applicable information.

California residents may have rights concerning:

• Access to personal information;
• Categories of information collected;
• Sources of information;
• Business or commercial purposes for collection;
• Categories of recipients;
• Correction;
• Deletion;
• Sale or sharing;
• Certain sensitive personal information;
• Certain automated decisionmaking activities;
• Non-discrimination; and
• Other rights established by applicable California law.

The categories of information described in Section 3 of this Privacy Policy describe the types of personal information Engagement Finder® may process.

The business purposes described in Section 5 explain our principal purposes for processing that information.

The recipients described in Section 10 explain the categories of entities to which information may be disclosed.

California Sale and Sharing Disclosure

Engagement Finder® does not sell personal information for monetary consideration as part of a business model involving the sale of customer lists or profiles.

Certain online advertising or analytics disclosures may nevertheless constitute “sharing” or “sale” under California law.

We will also process qualifying opt-out preference signals as required by applicable law.

Sensitive Personal Information

If Engagement Finder® uses or discloses sensitive personal information in a manner that creates a California right to limit such use or disclosure, we will provide the legally required method for exercising that right.

California Notice at Collection

At or before points where required personal information is collected, Engagement Finder® may provide a short-form Notice at Collection identifying the applicable categories of information and purposes and linking to this Privacy Policy.

California Requests

California residents may submit qualifying requests through the methods described in Section 21.

24. Other U.S. State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable comprehensive state privacy laws.

Depending upon the jurisdiction and our legal obligations, these rights may include:

• Access;
• Correction;
• Deletion;
• Portability;
• Opt-out of personal-data sales;
• Opt-out of targeted advertising;
• Opt-out of qualifying profiling;
• Consent rights concerning sensitive data;
• Appeal rights; and
• Protection against unlawful discrimination for exercising privacy rights.

Engagement Finder® will process applicable requests according to the law governing the request.

Where a state requires recognition of a universal opt-out mechanism, Engagement Finder® will seek to process qualifying signals as required.

25. Children's Privacy

The general Engagement Finder® Services are not intended to knowingly collect personal information from children under thirteen (13) except through a Service specifically designed and legally configured for children.

If Engagement Finder® offers a child-directed website, application, assessment, educational resource, or other online Service, that Service should be governed by a separate Children's Privacy Policy and appropriate parental notices.

Where the Children's Online Privacy Protection Act (“COPPA”) applies, Engagement Finder® will seek to:

• Provide an appropriate children's privacy notice;
• Provide direct notice to parents where required;
• Obtain verifiable parental consent before collecting personal information from a child where required;
• Collect only information reasonably necessary for the applicable activity;
• Provide parents legally required access and deletion rights;
• Allow parents to prevent further collection or use where required;
• Apply reasonable security protections;
• Limit retention of children's personal information;
• Review third-party technologies operating through the child-directed Service; and
• Apply additional consent requirements to disclosures or advertising practices where required.

A parent or guardian who believes a child has provided personal information through a Service in violation of applicable requirements should contact: info@engagementfinder.com.

26. Users Under 18 and Teen Privacy

Some jurisdictions provide additional privacy protections to teenagers and other minors.

Where applicable, Engagement Finder® will honor legally required age-based protections, consent requirements, advertising restrictions, deletion rights, or other privacy rights.

We do not knowingly sell the personal information of minors in violation of applicable law.

27. International Users

Engagement Finder® is based in the United States.

If you access the Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or other countries where Engagement Finder® or its authorized service providers operate.

Privacy and data-protection laws in those countries may differ from the laws of your jurisdiction.

Where applicable law requires additional protections for international transfers, Engagement Finder® will use an appropriate legal mechanism.

28. European Economic Area, European Union, and United Kingdom

To the extent the European Union General Data Protection Regulation (“GDPR”), UK GDPR, or similar data-protection requirements apply to Engagement Finder®, the following additional provisions apply.

Legal Bases for Processing

Depending upon the circumstances, Engagement Finder® may process personal data because:

• Processing is necessary to perform a contract with you or take requested steps before entering into a contract;
• You have provided consent;
• Processing is necessary for compliance with a legal obligation;
• Processing is necessary for our legitimate interests or those of another party where those interests are not overridden by your rights and interests; or
• Another lawful basis applies.

Our legitimate interests may include operating and improving the Services, maintaining security, preventing fraud, communicating with customers, protecting intellectual property, and conducting appropriate business administration.

EEA and UK Rights

Where applicable, you may have rights including:

• Access;
• Rectification;
• Erasure;
• Restriction;
• Data portability;
• Objection;
• Withdrawal of consent;
• Rights concerning certain automated decisionmaking; and
• The right to lodge a complaint with an applicable supervisory authority.

International Transfers

Where legally required, transfers may be protected through an applicable adequacy decision, approved contractual clauses, or another legally recognized transfer mechanism.

Representative or Data Protection Officer

If Engagement Finder® becomes legally required to appoint a European or UK representative or Data Protection Officer, applicable contact information should be added to this Privacy Policy.

29. Third-Party Websites and Services

The Services may contain links to or integrations with websites, social networks, payment services, video platforms, shipping providers, applications, plugins, or other services controlled by third parties.

Those third parties maintain their own privacy practices.

This Privacy Policy does not govern a third party's independent collection, use, or disclosure of personal information.

You should review the privacy policies of third-party services before providing information to them.

30. Social Media

Engagement Finder® may maintain pages, accounts, channels, or profiles on third-party social-media platforms.

Information you provide directly to a social-media provider is governed by that provider's privacy practices.

If you communicate with Engagement Finder® through social media, we may receive the information you choose to provide and information made available to us under your platform settings.

Social-media plugins, pixels, or embedded content on Engagement Finder® Services may also permit third-party platforms to collect certain information.

Where required, such technologies will be subject to appropriate privacy controls.

31. Research, Analytics, and Product Development

Engagement Finder® may analyze information to understand how individuals interact with our Services and to improve our educational and assessment offerings.

Where reasonably practicable and appropriate, research, analytics, and product-development activities may use aggregated, pseudonymized, or deidentified information.

Nothing in this Privacy Policy authorizes Engagement Finder® to publicly identify an individual research participant without permission or another lawful basis.

Any formal research activity that requires additional notice, authorization, institutional approval, or consent will be handled separately where applicable.

32. Privacy and Intellectual Property Protection

Privacy rights do not provide authorization to obtain information relating to other users or to circumvent Engagement Finder® intellectual-property protections.

When responding to access, portability, or similar requests, Engagement Finder® may take reasonable steps permitted by law to protect:

• Other individuals' privacy;
• Trade secrets;
• Proprietary scoring algorithms;
• Assessment methodologies;
• Copyrighted assessment questions;
• Security information;
• Proprietary software; and
• Other legally protected information.

We will seek to provide legally required personal information without unnecessarily disclosing Engagement Finder® proprietary intellectual property or another person's personal information.

33. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• Changes to our Services;
• New technology;
• New products or features;
• Changes to our data practices;
• Changes in applicable law; or
• Other operational developments.

The “Last Updated” date at the beginning of the Privacy Policy will identify when it was most recently revised.

If a change materially affects the way we process personal information, we will provide additional notice or obtain consent where required by law.

34. Contact Engagement Finder®

Questions, concerns, or requests regarding this Privacy Policy or Engagement Finder® privacy practices may be directed to:

Engagement Finder®
Attn: Privacy
Frye Consulting Group

Privacy Email: info@engagementfinder.com
General Contact: info@engagementfinder.com

Website: engagementfinder.com

For privacy-rights requests:

info@engagementfinder.com

For matters involving child-directed Services:

info@engagementfinder.com

35. Relationship to the Terms of Service

This Privacy Policy forms part of Engagement Finder®'s broader legal and privacy framework.

Your use of the Services is also governed by our Terms of Service and any additional terms applicable to a particular Engagement Finder® product, program, assessment, course, membership, purchase, or application.

If a specialized privacy notice applies to a particular Service, that notice will supplement this Privacy Policy with respect to that Service.

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