PRIVACY POLICY

(last updated March 28, 2025)

Breakthrough Careers and its affiliates (collectively,"Breakthrough Careers LLC","www.breakthrough.careers", "we," "our," or "us”) value your privacy. In this Privacy Policy ("Policy"), we describe the information we collect, how we use it, and when and to whom we disclose it. This Policy applies to all of our websites, mobile applications, and other online services (collectively, the "Platform") made available by or through Breakthrough Careers and on which we post this Policy, including through our URL https://www.breakthrough.careers/, and to information we collect offline or through other means. Undefined capitalized terms used herein shall have the definitions as set forth in our Terms of Service. By accessing or using the Platform, you agree to this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.

KEY TERMS

"Breakthrough Careers Content" means all Content Breakthrough Careers makes available on or through the Platform, including any Content licensed from a third-party, but excluding User Content.

"Career Consulting Services" means the services listed, offered, fulfilled, or provided through the Platform.

"Consumer" means a User who seeks careers consulting services on the Platform, makes a booking to purchase acareer consulting service offered on the platform (or receive  information in contemplation thereof), or agrees to these Terms in order to receive, pay for, review, or facilitate career consulting services.

"Content" means text, graphics, images, music, software, audio, video, information or other materials, including but not limited to profile information, and other information or materials available on or through the Platform.

"Platform" has the meaning set forth in the opening paragraph above.

"User" means a person or entity who completes Breakthrough Careers’ account registration process, agrees to these Terms, utilizes any services offered by or through the Platform, or a person or entity who submits or receives a request through Breakthrough Careers.

"User Content" means all Content submitted, posted, uploaded, published, or transmitted on or through the Platform by any User or other user of the Platform, including but not limited to name, address, email, phone number, credit card and other financial information, profile information, and all career related information made through the Platform, but excluding Breakthrough Careers Content.

INFORMATION WE COLLECT

How we collect and store information depends on how you access and use the Platform. We collect information in multiple ways including when you provide information directly to us, when we collect information from affiliates and non-affiliated sources, and when we passively collect information from you, such as information collected from your browser or device. By using our services, you are directly consenting to have your personal data collected and stored in the United States.

Information You Provide Directly to Us

You may provide us with information about you when you use or access the Platform, such as when you register for an account; transmit User Content; you consent to our collection of information, such as when you grant us permission to collect your device’s contact list; or otherwise communicate with us through the Platform. This list is illustrative, not exhaustive; this Policy applies to all your uses of the Platform.

The personal information you provide directly to us may include, but is not limited to: (a) name; (b) zip code; (c) email address; (d) home or business telephone number; (e) home, business or mailing address; (f) demographic information (e.g., gender, age, and other information relevant to User surveys and/or offers); (g) date of birth and/or age verification; (h) in certain circumstances, payment information including credit card or any relevant billing information; (i) any career related information you agree to send us to facilitate services; (j) any other information you include in communications with other Users through the Platform or communications with us. You are not required to provide us with such information, but certain features of the Platform may not be accessible or available, absent the provision of the requested information.

We may utilize a third-party payment provider to process payment information (e.g., credit card information or bank account information).

Data provided will be stored on secure cloud storage. Only authorized personnel will have access to client data.

How Data is Protected

Data provided will be stored on, secure cloud storage. We implement further measures including but not limited to,SSL encryption, two-factor authentication, and a data retention policy where data is deleted upon User request or after a reasonable storage time.

Information from Affiliates, Social Networking Sites, and Other Non-Affiliated Sources

We may collect information about you through Breakthrough Careers affiliates or through non-affiliated sources, including public information sources. For example:

• You may be able to access the Platform through a social networking account, If you access the Platform through your social networking account, you may allow us to have access to certain personal identifying information. This may include your name, profile picture, gender, networks, User IDs, list of friends, location, date of birth, email address, photos, videos, people you follow and/or who follow you, and/or your posts or "likes." Social networking sites have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult those sites' privacy policies.

• To the extent permitted by law, we may, in our sole discretion, ask for and collect supplemental information about you from non-affiliated sourcesto verify your identity or trustworthiness, or for other fraud or safety protection purposes. We may combine information that we collect from you through the Platform with information that we obtain from such sources, including public information sources and information derived from any other products or services we provide.

• If you send text messages in relation to the platform or any services provided we may use a third-party vendor to track these text messages. We track these text messages for fraud prevention, to ensure appropriate charging of fees, to enforce our Terms of Service, and for quality and training purposes. As part of this process, Breakthrough Careers and the third-party vendor will receive in real time and store data about your text message, including the date and time of the text message, your phone number, and the content of the text message.

Please note that we have no control over how any third-party site uses or discloses the information it collects about you.

Information That Is Passively or Automatically Collected Device/Usage Information

We and certain third-party vendors, including ad networks and analytics providers, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Platform. As described further below, we and these third-party vendors may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track and record when and how frequently you access or use the Platform, or how you browse the Platform. We do not, however, collect keystroke information. We use this information (including the information collected by relevant third-party vendors) for Platform analytics (including to determine which portions of the Platform are used most frequently and what our Users like/do not like), to assist in determining relevant advertising (both on and off the Platform), to evaluate the success of our advertising campaigns, and as otherwise described in this Policy.

Location Information

When you use the Platform, we may collect general location information (such as your location as derived from your IP address). We may collect information about your precise geolocation, and we may use that information to improve the Platform, including providing you with location-based features. If you access the device and you do not want your device to provide us with location-tracking information, you may be able to disable the GPS or other location-tracking functions on your device. See your device manufacturer's instructions for further details. If you disable certain functions, you may be unable to use certain parts of the Platform.

Cookies and Other Electronic Technologies

We and our third-party vendors may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand User behavior, personalize preferences, perform research and analytics, and improve the Platform. These technologies, for example, may allow us to tailor the Platform to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about Platform usage. We also use certain of these technologies to deliver advertisements through the Platform that may interest you or to advertise ourselves and the Platform to you on other sites. We or our third-party vendors also may use certain of these technologies in emails to our Users to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Platform, because it may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.

HOW WE USE YOUR INFORMATION

We may use your information for any of the following reasons:

• For the purposes for which you provided it;

• To provide career consulting services

• To send service-related communications including but not limited to scheduling, follow-up messages, and billing

• To share with subcontractors or partners involved in carrying out services for career counseling if the User consents

• For marketing messages if the User opts in

• To enable you to use the services available through the Platform, including registering you for our services and verifying your identity and authority to use our services;

• For customer support and to respond to your inquiries;

• For internal record-keeping purposes;

• To track fees and process billing and payment including sharing with third-party payment gateways and payment vendors in connection with the Platform;

• To improve and maintain the Platform and for product development;

• To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing;

• As permitted under applicable law, to contact you by text message regarding certain services or information you have requested;

• As permitted under applicable law, to contact you by telephone or text message regarding Platform features, improvements, or other products and services that may interest you;

• To contact you with information about your use of the Platform;

• For other research and analytical purposes; and

• To resolve disputes, to protect ourselves and other Users of the Platform, or third parties, including to protect property or safety; and to enforce any legal terms that govern your use of the Platform.

We may combine information that we collect from you through the Platform with information that we obtain from affiliated and non-affiliated sources, and information derived from any other products or services we provide. We may aggregate and/or de-identify information we collect. We may use de-identified or aggregated information for any purpose, including without limitation for research and marketing purposes and may also disclose such information to any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

We may, either directly or through third-party providers review, scan, or analyze your communications via the Platform or as otherwise described in this Policy for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and User support purposes. For example, as part of our fraud prevention efforts, we may scan and analyze messages to prevent fraud or improper actions. We may also scan, review or analyze messages for research and product development purposes, as well as to debug, improve and expand product offerings. By using the Platform or engaging in off-Platform communications tracked by Breakthrough Careers, you consent that Breakthrough Careers, in its sole discretion, may, either directly or through third parties, review, scan, analyze, and store your communications, whether done manually or through automated means.

HOW WE DISCLOSE YOUR INFORMATION

Unless otherwise described in this Policy, we may also disclose the information that we collect as follows:

• Affiliates. We may disclose your information to any Breakthrough Careers affiliates.

• Consent. We may disclose your information based on your consent to do so.

• Vendors. We may provide your information to select third parties who perform services on our behalf. These third parties provide a variety of services to us including without limitation billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, identity verification, fraud and safety protection and legal services.

• Legal Requirements. We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to: (a) comply with subpoenas, court orders, or other legal process we receive; (b) establish or exercise our legal rights including enforcing and administering agreements with Users; or (c) defend Breakthrough Careers against legal claims. While you may challenge the disclosure request, please be advised we may still be legally required to turn over your information.

• Protection of Breakthrough Careers and Others. We may disclose your information when we believe it appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service or any other legal terms governing use of the Platform, and/or to protect our rights and property and the rights and property of others.

• Business Transfers. As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all our assets. In such contemplated or actual transactions or where there is any change of control of Breakthrough Careers, your information may be among the disclosed and/or transferred assets.

You may post Content on or through our Platform, including, but not limited to, your comments, pictures, and other information. However, please be careful and responsible whenever you are online. Some information you provide and/or that we collect may be publicly accessible. For instance, registration for an account requires that you provide us with your name. Depending on the circumstances, your name may be attached to your Content or information, such as scheduling of services, service requests, reviews, participating in discussions or forums, messaging, and profile information.

If you choose to post User Content on or through the Platform (a) may be collected and used by third-parties with or without our knowledge; and (b) may be used by third parties (including other Users) in a manner that may violate this Policy or applicable law.

ONLINE ANALYTICS AND TAILORED ADVERTISING 

Analytics

We may use third-party web analytics services on the Platform. Providers of these services use cookies and similar technologies (as described in the Information That Is Passively or Automatically Collected section above) to help us analyze how Users use the Platform, including by noting the third-party website from which you arrive. The information collected by the technology may be disclosed to or collected directly by these providers.

Tailored Advertising 

We may use advertising services provided by third parties on the Platform, which provide their services using cookies and similar technologies (as described in the Information That Is Passively or Automatically Collected section above). Third parties whose products or services are accessible or marketed via the Platform may also place such technologies on your computer, mobile phone, or other device to collect information about your use of the Platform. We, our providers, and third parties collect information in this way for advertising and marketing purposes.

Certain third-party providers and certain cookies or similar technologies on the Platform enable us and third parties to serve you “tailored” advertising online that is more relevant to you and your interests. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out Link , the Digital Advertising Alliance's Consumer Opt-Out Link  and a Google opt-out link to opt out of receiving tailored advertising from companies that participate in those programs. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites.

Please note that if you opt out of tailored advertising, you may still receive online advertisements about us, the Platform, or third parties on the Platform – however, such advertising is not tailored.

PRIVACY OF MINORS 

Our services are not intended for minors (individuals under 18 years of age). We aim to provide services exclusively to individuals 18 years of age or older, including Platform usage. However, in the event a parent or legal guardian seeks services on behalf of a minor, we require both parental/guardian consent and, where applicable, the minor's assent." If we discover, or if you inform us, that an individual under 18 has provided us with personal information outside the narrow circumstances of parental/guardian seeking services on behalf of the minor, we will close the account and delete that individual’s personal information as required by law, including the Children's Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy.

SECURITY

We employ physical, procedural, and technological security measures to help protect your information from unauthorized access or disclosure. Breakthrough Careersmay use encryption, passwords, and physical security measures to help protect your information against unauthorized access and disclosure. Breakthrough Careersfollows data protection laws like GDPR and CCPA to ensure User data is managed according to legal standards. No security measures, however, are 100% failsafe. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that any information provided or transmitted online is completely secure. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. Breakthrough Careers is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

LINKS TO EXTERNAL PLATFORMS

The Platform may contain links to third-party websites or resources over which Breakthrough Careers does not have any control; please review such other websites’ privacy policies as to their use of personal information. Such links do not constitute an endorsement by Breakthrough Careers of those third-party websites. You acknowledge that Breakthrough Careers is providing these links to you only as a convenience, and further agree that Breakthrough Careers is not responsible in any way for such third-party websites, including without limitation for their content or how they treat information you provide to them.

YOUR CHOICES

You may review, correct, and delete certain information about you through your account. We expect you to promptly update your account information if it changes or is inaccurate. Upon your request, we will close your account and remove your profile information from view as soon as reasonably possible. We may retain information from closed accounts in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any User, enforce our Terms of Service, and/or for any other purposes otherwise permitted by law that we deem necessary in our sole discretion. You should understand, however, that once you transmit User Content through the Platform, it may be acquired by others who may not be required to delete or modify such User Content. Once we have deactivated or removed your account, you agree that Breakthrough Careers will not be responsible for retaining information related to your account.

We may send periodic emails to you. You may opt out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us, transactions, or changes to our Terms of Service, this Policy, or other relevant terms.

We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded.

CHANGES TO THIS POLICY

THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. BREAKTHROUGH CAREERS MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY AT ANY TIME. BREAKTHROUGH CAREERS WILL POST ITS UPDATED POLICY ON THE PLATFORM, SEND YOU A MESSAGE OR OTHERWISE NOTIFY YOU WHEN YOU ARE LOGGED INTO YOUR ACCOUNT. BREAKTHROUGH CAREERS ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY CHANGES. YOUR CONTINUED ACCESS TO OR USE OF THE PLATFORM WILL BE SUBJECT TO THE TERMS OF THE THEN-CURRENT POLICY.

CONSENT TO TRANSFER 

Our computer systems are currently based in the United States, so your information will be processed by us in the United States. Data may be accessible to law enforcement and national security authorities under certain circumstances. If you create an account with the Platform as a visitor from outside the United States, by using the Platform, you agree to this Policy and you consent to the processing of all such information in the United States.

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Privacy Notice for California Residents supplements the information in the Policy above, and except as provided herein, applies solely to California residents (as defined by the California Consumer Privacy Act (as amended, the “CCPA”)). It applies to “personal information” (as defined by the CCPA) that we collect on or through the Platform and through other means (such as information collected offline, in person, and over the telephone). This Supplemental Privacy Notice for California Residents also does not apply to current or former employees of Breakthrough Careers, independent contractors, or job applicants to jobs at Breakthrough Careers.

How We Collect, Use, and Disclose Personal Information 

The CCPA requires us to disclose information regarding the categories of personal information and sensitive personal information that we have collected about California consumers, the categories of sources from which we collect personal information, the business or commercial purposes (as each of those terms is defined by the CCPA) for which we collect personal information, and the categories of parties to whom we disclose personal information.

Throughout this Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also have to provide you with the "categories" of personal information and sensitive personal information we collect and disclose for “business or commercial purposes” (as those terms are defined by the CCPA).

As described further in the Policy above, the following table provides information about our practices in the 12 months leading up to the effective date of this Policy in relation to the categories of personal information that we generally collect from California residents, the sources of the information, the purposes for which we use the information, and the categories of third parties to whom we disclose personal information for a business purpose.