Privacy Policy

Last Revision: July 21st, 2025

1. INTRODUCTION

Sierra Division, Inc. (hereafter referred to as “Sierra Division,” “Company,” “we,” “us,” or “our”) is committed to safeguarding the privacy of our clients, website visitors, and users of our online academy services. This Privacy Policy outlines our practices regarding the collection, use, and sharing of your personal information. By engaging with our Services, including our website and online academy, you consent to the procedures described in this policy. You acknowledge that this Privacy Policy is part of our Terms of Use, and by accessing or using our Services, you agree to be bound by its terms. If you do not agree to these terms, please do not access or use our Services.

We reserve the right to update this Privacy Policy at any time. Changes will be effective immediately upon notice, which may include posting the revised policy on our website or sending an email to registered users. Your continued use of our Services after such modifications constitutes your acknowledgment and agreement to the updated policy.

2. Personal Data

We collect two types of information: Personally Identifiable Information (information that identifies you as an individual) and Non-Personally Identifiable Information (information that does not identify you individually).

Personally Identifiable Information

We collect personal data directly and voluntarily from you when you engage with our Services, such as:

  • Registering for our online academy or other services.
  • Submitting inquiries via our contact form.
  • Signing up for newsletters or product release notifications.
  • Enrolling in courses, submitting content, or participating in discussion forums or public areas.
  • Entering contests, sweepstakes, or completing surveys.
  • Providing feedback or sending us emails.
  • Ordering products or services, which may require payment information (e.g., credit card number).
 

This data may include your name, email address, mailing address (including zip code), phone number, employer, job title, department, payment information, and other relevant details. Some information is mandatory to participate in certain activities (e.g., course enrollment); if you do not provide it, you may not be able to engage in those activities.

Non-Personally Identifiable Information

We collect personal data directly and voluntarily from you when you engage with our Services, such as:

  • Registering for our online academy or other services.
  • Submitting inquiries via our contact form.
  • Signing up for newsletters or product release notifications.
  • Enrolling in courses, submitting content, or participating in discussion forums or public areas.
  • Entering contests, sweepstakes, or completing surveys.
  • Providing feedback or sending us emails.
  • Ordering products or services, which may require payment information (e.g., credit card number).
 
 This information is compiled and analyzed on both an individual and aggregated basis to improve our Services and user experience.
 

3. Data Collection

We collect data when you:

  • Use our contact form to inquire about our business, products, or services.
  • Register for our online academy or other services.
  • Sign up for newsletters or product notifications.
  • Participate in contests, sweepstakes, surveys, or discussion forums.
  • Provide feedback or submit content.
  • Use or view our website via browser cookies.
  • Make purchases or enroll in courses, including providing payment information.
 
 We may also collect data at other points on our Services where we indicate that information is being collected.
 

4. Data Sharing

We do not sell, trade, or rent your Personally Identifiable Information to others. However, we may share your information with:

  • Service Providers: Affiliates, partners, or third parties (e.g., delivery services, or customer service providers) to deliver our Services. We require these parties to comply with this Privacy Policy and maintain appropriate security, except where we lack control (e.g., regulatory authorities).
  • Legal Authorities: When required by law, court order, subpoena, or to cooperate with law enforcement investigations. We may report activities we believe to be unlawful.
  • Third-Party Advertisers: Non-Personally Identifiable Information (e.g., traffic patterns) may be shared with advertisers, but this does not include Personally Identifiable Information.
  • Third-Party Payment Providers: We use Stripe to securely process payments. Stripe may collect and process personal data in accordance with their Privacy Policy. Where available, we also offer payment options through Klarna. If you choose Klarna at checkout, some of your personal data (such as contact and order details) will be shared with Klarna to assess your eligibility and tailor the payment options offered to you. Your personal data is handled in accordance with Klarna’s Privacy Notice.
 
 
We take reasonable steps to ensure third parties process your data in accordance with our obligations, including Privacy Shield requirements where applicable. We may remain liable for third-party handling of data transferred under Privacy Shield if they fail to meet these obligations.
 

5. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by law. Upon request, we will delete your personal information, though some residual data may remain in backups or for past transactions.

6. Data Protection

We implement industry-standard safeguards, such as encryption and password-protected servers, to protect your Personally Identifiable Information from unauthorized access or disclosure. Access to your data is restricted to authorized personnel and contractors. Payment transactions are handled by secure third-party processors. However, no digital transmission or storage is 100% secure, and we cannot guarantee absolute security.

7. Updating or Correcting Your Information

You may access and edit your Personally Identifiable Information through your online account or by contacting us at compliance@sierradivision.com. Please include your name, address, and email address in your request. You may request deletion of your data, but past transaction records or backup data may not be fully removable. We may require identity verification and, in some cases, charge a reasonable fee for access requests.

8. Your Choices

  • Marketing Communications: You may opt out of receiving emails about our products, services, or third-party offers by updating your account preferences or contacting us. If you opt in to third-party offers, only we or our authorized agents will send such communications.
  • Cookies: You can modify your browser settings to accept, reject, or be notified about cookies. Rejecting cookies may affect the functionality of our Services.
  • Global Privacy Controls: You may use user-enabled global privacy controls to opt out of data sharing or sales.

9. Data PrOtection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have the following rights:

  • Right to Access: Request copies of your personal data (a small fee may apply).
  • Right to Rectification: Request correction or completion of inaccurate or incomplete data.
  • Right to Erasure: Request deletion of your data under certain conditions.
  • Right to Restrict Processing: Request restrictions on data processing under certain conditions.
  • Right to Object to Processing: Object to data processing under certain conditions.
  • Right to Data Portability: Request transfer of your data to another organization or directly to you.
 
To exercise these rights, email compliance@sierradivision.com with the subject “GDPR Inquiry.” We will respond within one month.
 

10. California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

California residents have additional rights under the CCPA and CPRA:

  • Right to Know: Request details about the categories, sources, purposes, and third parties involved in your personal information’s collection, use, or sharing (up to twice per year, free of charge).
  • Right to Delete: Request deletion of your personal information, subject to exceptions (e.g., legal requirements).
  • Right to Opt-Out: Request that we stop selling or sharing your personal information.
  • Right to Correct: Request correction of inaccurate information.
  • Right to Limit Use: Direct us to limit the use of sensitive personal information (e.g., social security number, precise geolocation) to specific purposes.
 To exercise these rights, email compliance@sierradivision.com with the subject “CCPA/CPRA Inquiry.” We will respond within one month.
 

11. Children’s Online Privacy Protection Act (COPPA)

We do not knowingly collect personal information from children under 18. If a child has submitted data, parents may request deletion by emailing compliance@sierradivision.com with the subject “COPPA Inquiry.” You must be at least 18 to use our Services.

12. Data Disclosure Terms

Law Enforcement Compliance

We may disclose your personal data when required by legal processes, court orders, or government requests.

Obligations for Legal Compliance

We may share your data to:

  • Fulfill legal duties.
  • Protect our rights or property.
  • Investigate or prevent misconduct.
  • Ensure user or public safety.
  • Avoid legal repercussions.
 

13. Do Not Track

We do not currently respond to “Do Not Track” signals due to the lack of a standardized compliance framework.

14. Cookies

Cookies are text files stored on your computer to collect standard internet log and visitor behavior data. We use cookies to enhance your experience and analyze usage of our Services. You can modify your browser settings to accept, reject, or be notified about cookies, but rejecting cookies may affect functionality. For more information, visit
 

Types of Cookies We Use

  • Functionality: Cookies remember your registration status for newsletters, subscriptions, or online academy accounts, ensuring seamless access to our Services.
  • Technical Analytics: Cookies collect data about your website visits, content viewed, links followed, browser type, device information, and IP address to improve our Services.

Third-Party Analytics and Advertising Tools

We use the following third-party tools to collect and analyze :

  • Google Analytics: Provided by Google, this tool tracks and analyzes website traffic and user behavior. It collects data such as pages visited, time spent on the site, and your IP address to help us understand how our Services are used. Google may use this data to provide other services or personalize ads within its advertising network. To opt out, install the Google Analytics opt-out browser extension, which prevents Google Analytics JavaScript (ga.js, analytics.js, dc.js) from transmitting your visit data. Learn more at tools.google.com/dlpage/gaoptout.
     
  • Meta Pixel: Provided by Meta, this tool measures the effectiveness of our Facebook and Instagram advertising campaigns by tracking actions you take on our website (e.g., page views, course enrollments). It collects data to improve ad performance, build targeted audiences, and remarket to users who have visited our Services. Meta may use this data to personalize ads across its platforms. To opt out, adjust your ad preferences in your Facebook account settings or follow Meta’s instructions for interest-based ads at www.facebook.com/help/109378711834996
  • Hotjar: Provided by Hotjar Ltd., this tool analyzes user behavior through heatmaps, session recordings, and surveys to improve our website’s usability and user experience. It collects data such as mouse movements, clicks, scrolling behavior, and anonymized form inputs (no Personally Identifiable Information is recorded in form fields). Hotjar may use this data to generate aggregated insights. To opt out, visit www.hotjar.com/legal/compliance/opt-out and follow the instructions to disable Hotjar tracking.
We do not share Personally Identifiable Information with these third-party tools, but they may collect Non-Personally Identifiable Information (e.g., IP address, browser type) to provide their services. These tools comply with their respective privacy policies, which we encourage you to review.

15. Third-Party Links

Our Services may link to third-party sites. We are not responsible for their content or privacy practices. Third-party advertisers may collect Non-Personally Identifiable Information via cookies when you interact with their ads. Contact these advertisers directly for questions about their practices.

16. Online Academy-Specific Considerations

When participating in our online academy:

  • Content you submit to discussion forums or public areas may be visible to others and collected by third parties. Such activities are beyond our control, and this policy does not apply to such information.
  • You are responsible for maintaining the secrecy of your account credentials. Do not share your password.
  • We may use your data to customize course content, track progress, and improve educational offerings.
 

Session Recordings and Third-Party Services

As part of our online academy offerings, Sierra Division Academy (“SDA”) records select live sessions, including Q&A events and group classes, for educational, quality assurance, and operational purposes. These recordings may capture audio, video, shared screens, chat messages, and other contributions made during live interactions.

By participating in these sessions, you consent to the collection and use of this data as described in our Terms of Service.

We use the following third-party service providers to facilitate and manage recordings:

 

These vendors may process personal data subject to their own privacy policies and data protection measures. We ensure that all service providers meet appropriate legal and security standards, including data transfer safeguards under GDPR where applicable.

Session recordings and transcripts are retained only as long as necessary to support educational delivery and internal review. They are not publicly available and are accessible only to enrolled participants and authorized SDA personnel. Recordings may also be used in anonymized or redacted form for future instructional materials, training, or internal performance review.

If you have questions or concerns regarding your appearance in recorded sessions, please contact us at compliance@sierradivision.com

17. Privacy Policy Changes

We may update this Privacy Policy to reflect changes in our Services, legal requirements, or business practices. We will provide notice of material changes by posting the updated policy on our website and updating the “Latest Revision” date. Your continued use of our Services constitutes acceptance of the updated policy.

18. How to Contact Us

For questions about this Privacy Policy, your data, or to exercise your data protection rights, contact us at:

  • Email: compliance@sierradivision.com
  • Address: Sierra Division, Inc., Attn: Privacy Compliance Officer, 4023 Kennett Pike Suite 50598 Wilmington Delaware 19807 United States