Privacy Notice

Guild Education, Inc. (“Guild,” “we” or “us”) has prepared this privacy notice (“Privacy Notice”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”), how Guild collects, uses, discloses and protects the personal information that we may collect about you and other end users (“Users”) and the choices you have with respect to your personal information, in connection with our Services, which may be accessed through our website, guild.com, and various other digital platforms operated by Guild (each, a “Website”), through our mobile applications (each an “Application”), or through your online and offline interactions with Guild (such interactions, each Application, and each Website are treated as part of the “Services” for purposes of this Privacy Notice).

This Privacy Notice does not apply to personal information that we process at the direction, or on behalf, of our partnering employers or educational or learning institutions. Please contact your employer or the educational or learning institution for more information about how they process and share your information.

We may provide different privacy notices to individuals at the time we collect personal information for specific services or in specific contexts (e.g., applying for a job with Guild). Such privacy notice will govern how we may process an individual’s personal information in connection with that service or context.

Although not part of our Terms of Use, capitalized terms not defined in this Privacy Notice shall have the meanings defined in the Guild Terms of Use.

This Privacy Notice covers the following topics:

How We Collect Personal Information
What Personal Information We Collect and Why
How We Use Personal Information We Collect
How We Secure Personal Information
How We Share Personal Information
Rights Under The Family Education Rights and Privacy Act (“FERPA”)
Children Under the Age of 13
Your Choices
Additional Information and Rights Under Applicable U.S. State Privacy Laws
International Users
Links to Other Websites
Changes to Our Privacy Notice
Contact Us

1. How We Collect Personal Information

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

Personal Information You Provide. Guild collects personal information when you voluntarily submit it to us or access or use our Services. For example, we may collect or receive personal information 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 information. In addition to personal information that we may receive directly from you, Guild, our service providers, and our advertising partners may automatically log information 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 Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, Guild may receive personal information 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 information 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 information with the personal information 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 Information We Collect and Why

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

All categories of personal information 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; and Comply with Laws and Regulations.We may also collect or create deidentified or aggregate information from personal information. “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 Information We Collect

Our primary purpose in collecting personal information is to provide the Services that you request. We may also use the personal information 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 information to provide our Services or Content to you and our partnering employers and institutions and to operate our business. For example, we use personal information 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 information.

Benefits Eligibility Determination. We use personal information 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 information to facilitate your application and enrollment process with our partnering educational or learning institutions.

Providing Credit for Training. We use personal information 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 information 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 information 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 information 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 information to help Users search for job opportunities or create a resume, and partnering employers find job seekers.

Payment/Reimbursement Processes. We use personal information to facilitate tuition payment or reimbursement for Programs or educational materials.

Secure Our Services. We use personal information 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 information 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 information from our Users when performing research studies related to our Programs and Services. We also use personal information 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 information 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 information 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.

Honor your privacy rights (described in Section 8 and Section 9 of this Privacy Notice).

Consent. We use personal information for any other purpose described when you provide your personal information with your consent.

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

4. How We Secure Your Information

We maintain reasonable and appropriate administrative, technical, and physical safeguards designed to secure your personal information 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.

5. How We Disclose Your Personal Data

In addition to the specific situations discussed elsewhere in this Privacy Notice, Guild may share your personal information 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 information 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. With respect to text messaging originator opt-in, personal information will not be shared with any third parties for their own marketing reasons.

Joint Marketing or Ecosystem Partners. We may share your personal information 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 information 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 information 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, 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 information 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 information 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 information 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 information 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 information 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.”

Other Users of the Services and the Public. We may provide functionality that enables you to disclose personal information 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 information 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 information with them.

Consent. We may ask if you would like us to share your personal information 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 information 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. Rights Under The Family Education Rights and Privacy Act (“FERPA”)

Under certain circumstances, if you enroll in a Program offered by one of our partnering educational or learning institutions, the information that we may receive from our partnering educational or learning institutions that pertains to you may be protected under FERPA, if applicable. You may also have specific rights related to accessing and/or updating your personal information when FERPA applies. For more information related to the applicability of FERPA and your rights under it, please contact the partner educational or learning institution in which you are or were enrolled.

7. Children Under the Age of 13

Our Services are not intended for or targeted toward children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we may have inadvertently collected any personal information from or about a child under 13, please contact us at [email protected].

8. Your Choices

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

Delete or Update Your Account Information. We rely on you to update and correct the personal information contained in your Account, which you can do by logging into your account and adjusting your information. Note that we may keep historical information in our backup files as permitted by law.
How to Opt-Out of Future Marketing Communications. 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. 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.
Cookies. 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.
Analytics. The Website uses Google Analytics to help us analyze how the Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.
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.

9. Additional Information and Rights Under Applicable U.S. State Privacy Laws

Certain U.S. states may also provide Users 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 information of such residents, and their privacy rights under applicable law. For purposes of this section, “personal information” means “personal data” or “personal information” as such term is defined under applicable state privacy law but does not include information exempted from the scope of such law.

Personal Information Collected and the Purposes of Collection and Use. We describe:

the categories of sources from which we collect personal information in Section 1;
the categories of personal information we may process, or have processed in the 12 months preceding the “Last Updated” date of this Privacy Notice, in Section 2;
the purposes, including the specific business and commercial purposes, for which we process personal information in Section 3 (and, in Section 2, by reference to the specific category of personal information collected); and
the categories of personal information that we may share with third parties and the categories of third parties with whom we share this information in Section 5.

Personal Information Disclosed, “Sold,” or Used for “Sharing/Targeted Advertising.” All categories of personal information that we process may be disclosed, or may have been disclosed in the 12 months preceding the “Last Updated” date of this Privacy Notice, to third parties to operate our business and for the purposes described in this Privacy Notice or at the time of collection.

We may (or have in the 12 months preceding the “Last Updated” date of this Privacy Notice) “sell” the following categories of personal information for monetary or other valuable consideration or process it for “sharing/targeted advertising” in the manner described in Section 3 under “Behavioral-Based Advertising” to our Advertising Partners: Individual Identifiers (contact information) and Internet or Network Activity. We may also (or have in the 12 months preceding the “Last Updated” date of this Privacy Notice) “sell” Commercial Information (account information and transaction history) with partnering employers.

We do not knowingly “sell” or use for “sharing/targeted advertising” the personal information of individuals under 16 years of age.

Processing Sensitive Personal Information. We collect, and have collected in the 12 months preceding the “Last Updated” date of this Privacy Notice, race/ethnicity and gender identity, for the purposes of “Application and Enrollment Assistance,” “Benefits Eligibility Determination,” “Coaching / User Success Support,” “Program Success Management,” and “Research & Development,” each as described in Section 3. Under certain U.S. state privacy laws, such personal information may be considered “sensitive personal information.” Where applicable law requires, you may have the right to either withdraw your consent to Guild’s processing of such information or to request that we limit the use or disclosure of such sensitive personal information to purposes permitted under applicable law (e.g., to perform the Services, detect security incidents and prevent fraud, and to verify and maintain the quality of the Services). To submit a request to withdraw consent or limit the use and disclosure of such information, please click the following link: Your Privacy Choices.

Your Privacy Rights. Residents of certain states may have the following additional rights under applicable law:

Know/Access the following information:
- Confirm whether we process your personal information.
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting, selling, or sharing personal information.
- The categories of third parties with whom we disclose personal information.
Delete the personal information that we have collected from or about you.
Correct inaccurate personal information that we maintain about you.
Data Portability in a readily usable format (to the extent technically feasible).
Limit Use or Disclosure of Sensitive Personal Information to only certain business purposes set forth under applicable state privacy law.
Revoke Consent to Process Sensitive Personal Information where we rely on your consent pursuant to applicable state privacy law.
Opt-out of “sales” or “sharing/targeted advertising” if we engage in such processing activities according to applicable state privacy law.
Appeal our refusal to take action on your request to exercise the rights described above.
Nondiscrimination for exercising the rights described above.

Exercising Your Privacy Rights. To exercise your rights under applicable law, or if you are acting as an authorized agent on behalf of a consumer, 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 know/access, delete, correct, or port your personal information, or limit the use or revoke consent to processing of sensitive personal information, please submit your request through our interactive webform available by clicking here: Your Privacy Choices, or call us toll-free at 1-888-961-4280.
To request to opt-out your personal information from “selling” and “sharing/targeted advertising” relating 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.
To request to opt-out your personal information from other “sales” or “shares/targeted advertising,” please complete our interactive webform available by clicking here: Your Privacy Choices, or call us toll-free at 1-888-961-4280.
If we decline to take action on your request, where applicable law requires you may appeal such refusal by submitting your request within a reasonable time period after we send you our decision by following the directions provided to you in the Guild communication containing our decision or submitting your request by completing our interactive webform available by clicking here: Your Privacy Choices.

We will comply with required requests as soon as reasonably practicable and in accordance with applicable laws. We may ask you (and the 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 information that is required to provide the Services.

Notice to California Residents (Shine the Light). For California residents, we consider any opt-out of “sale” or “share/targeted advertising” a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

Notice to Nevada Residents. Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Notice and we will comply with your request as required by Nevada law.

Retention of Personal Information. We will retain personal information, including sensitive personal information, 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. International Users

Guild is based in and operated from the United States, and our services are intended for US residents. If you are located in a jurisdiction outside of the United States, please be aware that the personal information we collect about you will be transferred to the United States. By using our Services, or providing us with any personal information, where applicable law permits, you specifically and expressly consent to the transfer, processing and storage of your personal information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside.

11. Links to Other Websites

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

We reserve the right to update this Privacy Notice at any time, without prior notice to you, and any changes will become effective immediately upon posting. The date this Privacy Notice was last revised is identified at the bottom 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

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

Last Updated: June 27, 2024 (effective July 1, 2024).

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