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Privacy Notice

Guild Global

Last Updated: January 10, 2025.

This Privacy Notice ("Privacy Notice") sets out how Guild Education, Inc. ("Guild," "we" or "us") collects, uses, and discloses ("processes") your personal data in connection with our website, global.guildeducation.com and its subdomains (the "Website"), our mobile applications (each an "Application") and the services we offer to you, including through our Website and Applications (together our "Services"). "Personal data" is data that identifies, relates to, or could reasonably be associated with an individual.

We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you (for example, by email or website notice) of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page.

Guild will act as a controller of your personal data in relation to the activities set out in this Privacy Notice. If you want to submit a request to exercise a privacy right, please submit your request via our privacy rights submission webform (see Section 8). If you otherwise want to contact us about the processing of your personal data, we can be reached at the following details:

Guild Education, Inc.
Republic Plaza
370 17th Street
Denver, Colorado 80202
United States of America
[email protected]

In some instances, your employer or an applicable educational or learning institution will also act as a controller of personal data that is shared between us and them pursuant to the Services. If you have any queries in relation to your employer's or an applicable educational or learning institution's processing of your personal data, we would encourage you to contact them in the first instance.

We may provide different privacy notices to you at the time we collect personal data for specific services or in specific contexts (e.g., applying for a job with Guild, or accessing other products or services). Such privacy notice will govern how we may process your personal data in connection with that service or context.

To the extent permitted by law, Guild processes your personal data on various legal bases described in Section 2. While we rely primarily on those bases to process your personal data (in the jurisdictions in which those bases are available), your use of our Website, Application and Services, or your acknowledgement and acceptance of this Notice, constitute your consent to Guild's processing of your personal data as described herein. Your access to and use of our Services is subject at all times to our Terms of Use, which we also encourage you to read.

For Mexico and Mexican users specifically:

This notice has been prepared pursuant to Federal Law for the Protection of Data Privacy held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares or the "Law"), the Regulations of the Law (the "Regulations"), as well as any other applicable legislation (and the provisions that supersedes such legislation). Acceptance of this notice constitutes your express and informed consent to Guild's processing of your personal data as described herein, and this will continue until your consent is revoked pursuant to the Law and in terms of this Notice. Your consent will be deemed granted if Controller provides its privacy notice to User prior the commencement of data processing.

1. How We Collect Personal Data

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We obtain the categories of personal data from a variety of sources, including from the following categories of sources:

  • Personal Data You Provide. Guild collects personal data when you voluntarily submit it to us or access or use our Services. For example, we may collect or receive personal data from Users when a User: creates an Account; edits Registration Information; signs up to receive our newsletters or other marketing materials or contacts; applies to one of our Programs or our partnering educational or learning institutions' Programs; searches for or applies to a job with a partnering employer; posts a review; submits a request to our customer service or member support team; interacts with our social media pages; volunteers to participate in a research study or otherwise interacts with us or other Users through the Services, at an event, over the phone or video conference, through email or text, through chat functionality, or through other communication channels.
  • Automatically Collected personal data. In addition to personal data that we may receive directly from you, Guild, our service providers, and our advertising partners may automatically log data about you, your computer or mobile device (such as the internet and network activity information described in Section 2 below), and your activity over time on our Services and other websites and online services. Like many online services, Guild uses cookies, pixels, or other online tracking technologies to facilitate some of this automatic data collection, such as:
    • Cookies, which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
    • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
    • Local storage, which is used to save data on a visitor's device. We use data from local storage to turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Services, remember your preferences, and measure advertisement effectiveness.
    • Session-replay technologies, which are third-party software used to record a video replay of Users' interactions with a Website or Application and may also be used to analyze online activity information (as further described in Section 2). The video replay may include Users' clicks, mouse movements, scrolls, mobile app touches, typing, site navigation and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with a Website or Application, understand how Users interact with and use a Website or Application, and identify areas for improvement.
    • Software development kits, or SDKs, are third-party computer codes used in connection with an Application. SDKs may enable third parties to collect information directly via an Application.
  • Personal Data Obtained from Third Parties. In addition to the personal data that we collect from you directly and automatically, Guild may receive personal data about you from other third party sources, such as our service providers, advertising partners, data analytics providers, government entities, operating systems and platforms, event sponsors, publicly available sources, or data licensors/providers. For example, we receive personal data from partnering employers, our partnering educational or learning institutions, social media sites, and educational reporting and research providers (such as National Student Clearinghouse). We may merge or combine such personal data with the personal data we collect from you directly or automatically.
  • Referrals. Users may recommend Guild Services to colleagues by providing us with their colleague's contact information. Please do not provide us with someone's contact information unless you have their permission to do so.

2. What Personal Data We Collect and Why

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The following table describes the categories (with non-exhaustive examples) of personal data we may collect about you. We may also collect other personal data that is not specifically listed here, which we will process as described in this Privacy Notice or as otherwise disclosed at the time of collection.

Categories Examples Processing Purpose (each further described in Section 3)
A. Individual Identifiers and Demographic Information

Contact information, such as name, alias, postal address, telephone number, email address and social media handle.

Government issued identifiers, such as driver's license or state identification card.

Demographic information, such as age or date of birth, gender identity, native language, nationality, military status, socioeconomic status, race/ethnicity, and disability status.

  • Benefits Eligibility Determination
  • Direct Marketing Campaigns
  • Behavioral-Based Advertising (excludes government issued identifiers)
  • Application and Enrollment Assistance
  • Coaching / User Success Support
  • Career Assessment and Discovery
  • Job Placement
  • Payment/Reimbursement Processes
  • Research and Development
  • Program Success Management
B. Sensory Data Call or video recordings of your communications with us or support/coach staff. We and our service providers may record voice or transcripts of these communications for training, quality assurance, User and customer support, and marketing and demonstration purposes.
  • Coaching / User Success Support
  • Research and Development
C. Commercial Information

Account information, such as your log-in details, information that you store in your Account, and other details about your use of the Services.

Transaction history, such as records of Services and educational or learning programs obtained or considered.

Preferences, such as your interests, and any preferences you set in your Account, and any marketing or communications preferences.

Educational program information, including application information, enrollment status and related information.

Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests.

Communications, such as the information associated with your requests or inquiries to us, and your communications (chat, phone call, text, email, and corresponding notes) with support/coaching staff.

  • Benefits Eligibility Determination
  • Direct Marketing Campaigns
  • Application and Enrollment Assistance
  • Coaching / User Success Support
  • Career Assessment and Discovery
  • Job Placement
  • Payment/Reimbursement Processes
  • Research and Development
  • Providing Credit for Training
  • Program Success Management
D. Internet or Network Activity

Online activity information, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, device ID, unique identifiers, and general location information such as city, state, or geographic area.

  • Direct Marketing Campaigns
  • Behavioral-Based Advertising
  • Research and Development
E. Professional or Employment-Related Information

Employer name, job title, full- or part-time status, training attainment, skill assessments, preferred work environment, qualifications, benefits, business contact information, or information received from a partnering employer or contained in a resume or CV.

  • Benefits Eligibility Determination
  • Direct Marketing Campaigns
  • Application and Enrollment Assistance
  • Providing Credit for Training
  • Coaching / User Success Support
  • Career Assessment and Discovery
  • Job Placement
  • Payment/Reimbursement Processes
  • Research and Development
  • Program Success Management
F. Education Information

Course performance records, such as records of your course selection and attendance, participation, and progress in courses and history about how frequently you attend in-person and online sessions, student ID, course grade(s), cumulative GPA, and transcripts.

Financial information, such as financial aid and reimbursement information, tuition and fees, and information about dependents.

  • Benefits Eligibility Determination
  • Application and Enrollment Assistance
  • Coaching / User Success Support
  • Career Assessment and Discovery
  • Direct Marketing Campaigns
  • Job Placement
  • Payment/Reimbursement Processes
  • Research and Development
  • Program Success Management
G. Inferences Drawn from Personal Information

Profiles reflecting preferences, characteristics, education or career pathways, skills, program aptitudes and success criteria, behavior, attitudes, intelligence, abilities, or aptitudes (including those created through automated processing).

  • Coaching / User Success Support
  • Career Assessment and Discovery
  • Job Placement
  • Research and Development
  • Direct Marketing Campaigns
H. Demographic and diversity information

Demographic and diversity information, such as age or date of birth, gender identity, native language, nationality, military status, socioeconomic status, race/ethnicity, and disability status.

  • Benefits Eligibility Determination
  • Application and Enrollment Assistance
  • Coaching / User Success Support
  • Career Assessment and Discovery
  • Job Placement

All categories of personal data described above may be used for the following purposes as necessary (each as further described in Section 3 below) in addition to other listed purposes: Provide the Services; Secure our Services; Administer your Privacy Rights; and Comply with Laws and Regulations.

We may also collect or create deidentified or aggregate information from personal data. Deidentified Information" means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which Guild has implemented technical safeguards and business processes that prohibit reidentification of the individual. To the extent we classify such information as "deidentified information," we commit to maintain and use the data only in a deidentified fashion and not attempt to re-identify the data (except for purposes permitted by law). "Aggregate Information" means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.

3. How We Use Personal Data We Collect

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Our primary purpose in collecting personal data is to provide the Services that you request. We may also use the personal data we collect from you or about you as set forth below and as otherwise described in this Privacy Notice or at the time of collection.

  • Provide the Services. We use personal data to provide our Services or Content to you and our partnering employers and institutions and to operate our business. For example, we use personal data to:
    • process your transactions;
    • establish, manage, monitor, and maintain your Account;
    • verify your identity or determine your eligibility for Programs or offers;
    • enhance and personalize our Users' experience with the Services;
    • communicate with you, including notifying you about your Account or changes to our Services or Content and responding to any of your requests, feedback, or questions;
    • provide partnering employers visibility into benefit usage and outcomes, and to enable them to support your success and use of the Services;
    • provide surveys or other promotions that you participate in;
    • provide maintenance, technical troubleshooting, and support;
    • provide customer support/resolution; and
    • fulfill any other purpose for which you provide personal data.
  • Benefits Eligibility Determination. We use personal data to verify your identity and determine your eligibility for Account creation, registration, and ongoing funding eligibility. We may also track your participation in Programs in order to fulfill our responsibilities to the partnering employer.
  • Application and Enrollment Assistance. We use personal data to facilitate your application and enrollment process with our partnering educational or learning institutions.
  • Providing Credit for Training. We use personal data to facilitate your receipt of academic credit through our partnering educational or learning institutions for formal training that you have completed with a partnering employer.
  • Coaching / User Success Support. We use personal data to provide you with academic/skill- and employment-related coaching services and to communicate with you about any Programs in which you are enrolled, were previously enrolled, or are considering. We also use personal data to improve and maintain the quality of our coaching services and to provide training to our coaches and specialists. We track your participation in Programs in connection with these coaching services. Guild may present you with an opportunity to share recordings of your coaching sessions or other communications through a release or other form of consent. To the extent you authorize Guild to do so, we may use recordings of our coaching sessions or other communications to market our services to potential and existing Users and customers and to demonstrate how our services work or their value.
  • Career Assessment and Discovery. We use personal data such as matching algorithms and live coaching to help Users explore and select career paths that align with their skills.
  • Job Placement. We use personal data to help Users search for job opportunities or create a resume, and partnering employers find job seekers.
  • Payment/Reimbursement Processes. We use personal data to facilitate tuition payment or reimbursement for Programs or educational materials.
  • Secure Our Services. We use personal data to monitor our Services for security purposes and disclose it to law enforcement, emergency services, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Services and our business, databases, and other technology assets; (b) protect our, your, or others' rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate, deter, and prosecute fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • Comply with Laws and Regulations. We will use personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • Research and Development. We may collect personal data from our Users when performing research studies related to our Programs and Services. We also use personal data to understand and analyze the usage trends and preferences of our Users, including to identify indicators of learner success, to make our Programs and Services better, and to develop new features and functionality. As part of these activities, we may create Deidentified Information or Aggregated Information from personal data we collect. We may use Deidentified Information or Aggregated Information and share it with third parties for our lawful business purposes, including to analyze and improve our Programs and Services and promote our business.
  • Direct Marketing Campaigns. We use personal data to send you marketing communications, updates relating to existing Programs and employment positions, Guild news, or other related information that may be of interest to you.
  • Behavioral-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our Services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above in Section 2) over time across our Services and other websites and services or your interaction with our emails and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting behavioral-based advertising in Section 8.
  • Program Success Measurement. Guild monitors enrollment trends, academic success, and career success metrics across various populations to understand the outcomes being driven by Guild's product and services, or the outcomes driven by our learning institution partners.
  • Administer your privacy rights (described in Section 8 and Section 9 of this Privacy Notice).
  • Consent. We use personal data for any other purpose described when you provide your personal data with your consent.

Please refer to Section 2 of this Privacy Notice for which categories of personal data are used for which of the above purposes.

For Users in the United Kingdom: The below table identifies our legal basis for processing personal data.

Purpose/Use Type of data Legal basis
Benefits Eligibility Determination Individual Identifiers
Commercial Information
Professional or Employment-Related Information
Education Information
Demographic and diversity Information
To deliver a contractual service to our users — where they have signed up to our terms of service and we need to determine what benefits you are eligible for as relevant for our courses and programs.
Application and Enrollment Assistance Individual Identifiers
Commercial Information
Professional or Employment Related Information
Education Information
To deliver a contractual service to our users — where they have signed up to our terms of service and you have selected a course or program and we need to enroll you on this.
Direct Marketing Campaigns Individual Identifiers
Commercial Information
Internet or Network Activity
Professional or Employment Related Information
Education Information
Inferences Drawn from Personal Information
Where you have consented to allow us to provide you advertising based on your preferences.
OR
Where it is our legitimate interest to provide advertising to you about courses and programs that may be of interest to you based on your previous use of our services.
Behavioral-Based Advertising (excludes government issued identifiers) Individual Identifiers
Internet or Network Activity
Where you have consented to allow us to provide you advertising based on your preferences.
Coaching / User Success Support Individual Identifiers
Audio/Visual Data
Commercial Information
Professional or Employment Related Information
Education Information
Inferences Drawn from Personal Information
Demographic and Diversity Information
To deliver a contractual service to our users — where they have signed up to our terms of service and agreed to coaching/user success support as part of the service.
Job Placement Individual Identifiers
Commercial Information
Professional or Employment Related Information
Inferences Drawn from Personal Information
Demographic and Diversity Information
To deliver a contractual service to our users — where they have signed up to our terms of service and agreed to a job placement service.
Research and Development Individual Identifiers
Audio/Visual Data
Commercial Information
Internet or Network Activity
Professional or Employment Related Information
Education Information
Inferences Drawn from Personal Information
Necessary for our legitimate interests — to study how users use our products/services and to help us improve and develop our services.
Payment/Reimbursement Processes Individual Identifiers
Commercial Information
Professional or Employment Related Information
Education Information
To deliver a contractual service to our users — where they have signed up to our terms of services for educational courses and where we offer reimbursement services alongside educational programs.
Providing Credit for Training Individual Identifiers
Professional and Employment Related Information
To deliver a contractual service to our users — where they have signed up to our terms of services for educational courses and where we offer professional credit for training.
Program Success Management Individual Identifiers
Commercial Information
Professional and Employment Related Information
Education Information
Necessary for our legitimate interests to monitor the success of our services and to make further improvements for our users.
Administer Your Privacy Rights Some or All of your Personal Data (depending on the request) To comply with our legal obligation to follow relevant data protection law.
Secure our Services Some or all of your Personal Data as required to comply with laws or make or defend ourselves in a legal claim To comply with a legal obligation.

Where we have a legitimate need to process special categories of personal data for purposes not identified above (such as your diversity and demographic information), we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

We will always treat special categories of personal data as confidential and we will only share such data internally where there is a specific and legitimate purpose for sharing the data. As set out below, we have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure.

We will only retain special categories of personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.

4. How We Secure Personal Data

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We maintain reasonable and appropriate administrative, technical, and physical safeguards designed to secure your personal data against unauthorized access or acquisition. Please keep in mind that no electronic data transmission or storage of information can be guaranteed to be completely secure or error free, and we cannot warrant or ensure the security of any information that you transmit to us.

We implement a combination of policies and technical and organizational measures to protect your personal data, including:

  1. A designated privacy representative tasked to monitor our compliance with applicable privacy laws;
  2. Internal policies and procedures that provide a framework for the keeping and destruction of personal data, and that define the roles and responsibilities of our employees throughout the life cycle of the personal data we process and limit their access to that information on a "need-to-know" basis;
  3. Appropriate password protections implemented throughout our systems;
  4. Personal data is kept encrypted or pseudo-anonymized where appropriate;
  5. Procedures for responding to complaints or inquiries related to personal data;
  6. If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;
  7. Contractual protections and other measures to ensure that service providers with whom we share personal data maintain adequate protections and security standards; and
  8. Employee training in privacy and information security.

5. How We Share Personal Data

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In addition to the specific situations discussed elsewhere in this Privacy Notice, Guild may share your personal data with the below categories of third parties in the following circumstances:

  • Service Providers. We engage service providers to perform functions on our behalf such as supporting our Services, conducting our business, processing payment transactions, website hosting, maintenance services, database management, analytics, fraud protection, customer relationship management, financial account management, managing our marketing communications, tracking student enrollment and student performance, or otherwise providing the Services to you.
  • Advertising Partners. We may share personal data with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in "Behavioral-Based Advertising" in Section 3.
  • Joint Marketing or Ecosystem Partners. We may share your personal data with other partners that provide complementary products or services or an ecosystem to which Guild is a member in order to provide you with Content and other features through the Services, and such partners may send you promotional materials or otherwise contact you regarding products and services that they offer.
  • Partnering Educational or Learning Institutions. When you apply to a Program offered by one of our partnering educational or learning institutions, we may transfer your personal data to such partnering institution in connection with providing Programs and Services to you, including to facilitate the application, admissions, and enrollment process, apply for academic credit for you, track your participation in Programs, or fulfill our contracted responsibilities to a partnering institution or partnering employer. Guild's catalog of partnering institutions does include some institutions located outside of the United States. If you apply to or enroll in a program with international institutions, your data may be transferred outside of the United States.
  • Partnering Employers. We may transfer personal data to a partnering employer in connection with providing Programs and Services to you, including to assess benefits eligibility, facilitate the application or enrollment process, provide information on your academic achievements and progress, enable you to receive tuition assistance and reimbursement (including sharing information, such as your communications with us, in connection with any related disputes with your employer), direct your application to a partnering employer, inform your employer about your usage of your benefit and Guild Services (including product usage) and enable them to conduct outreach to you, provide testimonial(s) regarding the service, and facilitate your application to a job opportunity.
  • Related Companies and M&A Transactions. We may share your personal data with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). We reserve the right to disclose and transfer your personal data to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
  • Professional Advisors. We may share personal data with persons, companies, or professional firms providing Guild with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, audit/security, and other matters.
  • Law Enforcement. Under certain circumstances, we may share personal data with law enforcement, emergency services, government authorities, and other parties if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request or is necessary for the purposes of Securing Our Services (as described in Section 3).
  • Authorities and Others for Legal Compliance and Security. We may also disclose your personal data in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in Section 3 titled "Secure Our Services," or as otherwise required by law.
  • Other Users of the Services and the Public. We may provide functionality that enables you to disclose personal data to other Users of the Services or the public. For instance, you may be able to participate in groups or forums related to your Program and share information about yourself or your use of the Services or Program that you can make available to other Users or the public. You may also be able to submit content to the Services (such as comments, questions, stories, reviews, surveys, blogs, photos, and videos), and we will identify you by displaying information such as your name, username, social media handle, or a link to your user profile along with the content you submit. We do not control how other Users or third parties use any personal data that you make available to other Users or the public.
  • Third Parties You or Your Employer Arrange. Our partnering employers sometimes arrange for third party involvement in the Services, generally to facilitate your use of the Services (for example, translators or other providers of related services). If you use any such third parties in your use of the Services, or if you permit a third party to participate in your interactions with the Services (for example, family members), Guild may engage with such third parties and share your personal data with them.
  • Consent. We may ask if you would like us to share your personal data with other unaffiliated third parties who are not described elsewhere in this Privacy Notice, and we may do so with your consent.

Even where the use and disclosure of your personal data is already covered by this Privacy Notice, we may provide you specific notice at the time of a particular transaction that your data will be shared with a third party if you continue — this will provide you a reminder of data sharing practices described in this Privacy Notice to ensure you wish to continue, however the disclosure is often necessary for us to provide the Services to you, and if you choose not to continue we may not be able to provide the Services to you.

6. Children Under the Age of 14

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Our Services are not intended for or targeted toward children under 14 years of age. We do not knowingly collect personal data from children under 14. If you believe we may have inadvertently collected any personal data from or about a child under 14, please contact us at [email protected]. Users under the age of 18 in Mexico or India should consult with their parents or legal guardians, who should provide their verifiable consent as prescribed under applicable law, prior to using any Services or providing your personal data to Guild pursuant to this Privacy Notice.

7. Your Choices and Cookies

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You may make the following choices regarding your personal data and we will comply with your request as required by applicable law:

  • Delete or Update Your Account Information. We may rely on you to update and correct the personal data contained in your Account, which you can do by logging into your account and adjusting your information or submitting a privacy rights request. Note that we may keep historical information in our backup files as permitted by law.
  • Marketing Communications. You may opt in to receiving email or text message marketing communications through our Website, at the time that you register for our Programs or Services, or at any time thereafter through your Account. We may also have your implied consent to send you such marketing communications under applicable laws. If at any time you would like to unsubscribe from receiving future emails or text messages from Guild, you may opt-out of such future marketing emails and text messages by following the unsubscribe instructions provided to you or by adjusting your communication preferences within your account. If you would like to stop receiving phone calls, you may ask the representative calling you to stop at any time. If you would like to stop seeing our content on a social media site, you may follow the relevant instructions and policies provided for that site to opt-out of receiving our content. Please note that if you are enrolled in one of our Programs or have an Account, we may need to send you certain communications relating to your enrollment, your Account or your use of the Services, and you may continue to receive these transactional messages even if you choose to opt-out of marketing communications. Please note that it may take some time for all of our records to reflect changes in your preferences (for example, your preference may not be captured for a marketing campaign already in progress).
  • Cookies. Cookies are small data files stored on a visitor's computer or internet-enabled device that perform various functions. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser's settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. Guild may use the following types of cookies:
    • Strictly-necessary / essential cookies: These cookies are necessary for the Website or Services to function and cannot be switched off in our systems.
    • Analytics cookies: These cookies help us analyze how the Services are being accessed and used, enable us to track performance, and secure the Websites. For example, we use cookies to get insights regarding users and Website performance, such as page speed or to help us customize our Websites and Services for you in order to enhance your experience.
    • Advertising cookies: These cookies are used to make advertising messages more relevant to you and your interests. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited our Websites. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after we receive it. This process helps us manage and track the effectiveness of our marketing efforts.
    • Social media cookies: These cookies are used when you share information using a social media sharing button or "like" button on the Websites or you link your account or engage with our content on or through a social network. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
    Please visit our preference center for additional information and to exercise choices with respect to non-essential cookies.
  • Behavioral-Based Advertising. We participate in behavioral-based advertising. You can limit the use of your information for behavioral-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of behavioral-based ads from companies participating in the following industry opt-out programs by visiting the Digital Advertising Alliance or Network Advertising Initiative. Users of an Application may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user's choices. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here. Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE DIRECT/FIRST-PARTY ADVERTISING WHILE USING GUILD'S WEBSITE. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS. Further, some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive behavioral-based advertisements from other companies. If you opt-out of behavioral-based advertisements, you will still see advertisements online but they may be less relevant to you.
  • Do-Not-Track. Some web browsers may be configured to broadcast "Do Not Track" signals to the online services that you visit. At this time, we do not modify your experience based upon whether such a signal is broadcast. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

8. Additional Information and Rights Under Applicable Country-Specific Privacy Laws

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Certain countries (or jurisdictions within countries) may also provide Users residing in such countries with additional rights under their privacy laws. To the extent such laws apply to Guild, this section provides additional information regarding how we process personal data of such residents, and their privacy rights under applicable law. For purposes of this section, "personal data" means "personal data" or "personal information" as such term is defined under applicable privacy law but does not include information exempted from the scope of such law.

You may have the following rights under applicable law and under certain circumstances:

  • Access the following information:
    • Confirm whether we process your personal data.
    • The purposes of processing your personal data.
    • The categories of personal data that we have collected.
    • The categories of sources from which we collected personal data.
    • The categories of third parties with whom we disclose personal data (including recipients in third countries and appropriate safeguards relating to such transfer).
    • A copy of the personal data undergoing processing.
  • Rectify/Correct inaccurate personal data that we maintain about you, including to complete incomplete information, and obligate recipients to whom we have transferred your personal data to do the same unless it is impossible or involves disproportionate effort.
  • Erase, Cancel, or Delete the personal data that we have collected from or about you, and tell recipients to whom we have transferred your personal data to do the same unless it is impossible or involves disproportionate effort. Note that this right does not apply in all circumstances (such as where we rely on your information to supply a contractual service you have asked for, where the information is still needed for the purpose for which it was collected, or where we are required to retain it to comply with a legal obligation). However, where we are not able to erase all personal data you requested, we will provide you with our reasons.
  • Right to Withdraw Consent, to the extent Guild's only legal basis for processing your personal data is consent; if you withdraw your consent to Guild processing your personal data, a consent exception may apply and Guild may continue to process your information on that basis.

Additional Rights. Residents of the below countries may have the following additional rights under applicable law:

United Kingdom:

  • Right to Restrict Processing to legally permissible uses where you contest the accuracy of the personal data, you oppose erasure of unlawfully processed personal data, you require retention of the personal data associated with a legal claim or defense and Guild no longer needs the personal data for the purpose of processing, or you have objected to Guild's processing of data supported solely on the basis of legitimate interest, and obligate recipients to whom we have transferred your personal data to do the same unless it is impossible or involves disproportionate effort. This right does not apply in all circumstances (such as where we rely on your information to supply a contractual service you have asked for, or where we are required to retain it to comply with a legal obligation). However, where we are not able to restrict processing all personal data you requested, we will provide you with our reasons.
  • Right to Data Portability of data you provided Guild in a structured, commonly used, and machine-readable format, where we use your personal data on the basis of your consent or performance of a contract and where our use of your data is carried out by automated means.
  • Right to Object to Processing of personal data about you based on the grounds of necessity for a task carried out in the public interest or Guild's legitimate interest or for direct marketing. This right does not apply in all circumstances (such as where we rely on your information to supply a contractual service you have asked for, or where we are required to retain it to comply with a legal obligation). However, where we are not able to stop processing all personal data you requested, we will provide you with our reasons.
  • Right Not to be Subject to Solely Automated Decisions Producing Legal Effects without your consent or other legal basis, and to access information about the existence of any solely automated decision-making that produces a legal effect, as well as information about the logic involved and the consequences of such processing..
  • Right to Complain to the Information Commissioner if you believe Guild's processing of your personal data violates applicable law. The information commissioner can be contacted at https://ico.org.uk/make-a-complaint/, however, if you contact us via our privacy rights request submission form or at [email protected] with any questions or complaints, we will try to resolve this with you.

India:

  • Right to Grievance Redressal in respect of any act or omission on our part regarding the performance of our obligations towards your personal data or the exercising of your privacy rights under applicable laws.
  • Right to Nominate an Agent authorized to exercise data privacy rights under applicable laws in the event of your incapacity to do the same.

Mexico:

  • Right to Object to the processing of your personal data for a legitimate reason, to use of your personal data for marketing purposes, to processing of your personal data by any mechanism including automated decision-making, and to withdraw your consent to any processing based solely on that basis.

Canada:

  • For residents of Quebec, the right to be informed of a decision made by an exclusively automatic process no later than when we inform you of the decision, and a right to make further inquiries and submit observations.

Exercising Your Privacy Rights. To exercise your rights under applicable law, or if you are acting as an authorized agent on behalf of an individual, please follow the instructions provided below. These rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your residency or identity or, if an authorized agent, your authority to act on behalf of the individual.

  • To request to exercise any of your rights, please complete our privacy rights request submission form.
  • To adjust your preferences, opt-out, or withdraw consent to the automatic collection of data on the Website by cookies and similar technologies, please update your cookie preferences as provided through our Website. Due to technological limitations, if you visit our Website from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences.

We will comply with required requests as soon as reasonably practicable and in accordance with applicable laws. We may ask you (and your authorized agent, where applicable) to verify your identity before we can act on your request. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. If your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or decline to comply with your request.

We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to resolve disputes, enforce our agreements, facilitate your employer's education benefits to you for both current and prior transactions, complete any transactions that you began prior to requesting such change or access, or for another purpose to the extent permitted by applicable law. Please note that we may be unable to provide Services to you, in whole or part, if you request deletion of personal data that is required to provide the Services.

9. Retention of Personal Data

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We will retain personal data, including sensitive personal data, for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, and for fraud prevention purposes. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. International Transfers

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Guild is based in and operated from the United States. If you are visiting our website or using our services from outside of the United States, please be aware that the personal data we collect about you will be transferred to, processed in, and stored in the United States and other countries where we and our service providers operate. As a result, when your personal data is processed or stored in a jurisdiction other than where you are residing, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. By using our Services, or providing us with any personal data, where applicable law permits, you understand that your personal data will be processed and stored of your personal data in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside.

Residents of the United Kingdom or European Economic Area: If we provide any personal information about you to non-UK and non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following:

  • ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data; or
  • where we have in place standard model contractual arrangements with the recipient which have been approved by the European Commission (or the UK Government for transfers out of the UK in due course). These model contractual clauses include certain safeguards to protect the personal data.

You may request further details on the steps we take to protect your personal information by contacting us by email at [email protected] at any time.

11. Links to Other Websites

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While using our Services you may be directed to other websites or services that are operated by third parties. We have no control over these third parties and we are not responsible for the privacy practices of such third parties. This Privacy Notice does not apply to information collected by any other website or third party, or to any information collected by third parties through any application or content (including advertising) that may link to or be accessible from our Services. You should carefully review the privacy policy for any third party sites that you visit.

12. Changes to Our Privacy Notice

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We reserve the right to update this Privacy Notice at any time. The date this Privacy Notice was last revised is identified at the top of the page. If we make material changes to this Privacy Notice, we may notify you by e-mail to the primary e-mail address specified in your Account or through a notice on the Services, or other means as may be required by applicable law. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you and for periodically visiting our Website and this Privacy Notice to keep up to date on our most current policies and practices. In all cases, your continued use of our Services following posting or other notification of changes constitutes your acknowledgement of such changes.

13. Contact Us

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If there are any questions regarding this Privacy Notice, you may contact our Privacy representative at [email protected].