The Elliott Group LLC, elliott247.com, ("The Elliott Group," "us," "we," or "our") thanks you for visiting the online and mobile resources that we publish. We use the words "you" and "your" to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 13. Our privacy statement informs you about from whom and the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it.

Online and mobile resources mean the websites and other internet features we own that allow you to interact with our websites, as well as apps we have created and distributed to let our customers and followers view our online and mobile resources or otherwise interact with the content we provide.

Who We Are

The Elliott Group is a training company. For residents from the GDPR Jurisdictions, as defined below, and some US state privacy laws, The Elliott Group is the data controller responsible for your personal data. For residents of California, The Elliott Group is a "Business."

Who We Collect Personal Information From

We may collect personal information from the following groups of data subjects: visitors to, and users of, our online and mobile resources; our customers; current members of our workforce and those who apply for posted jobs; and third-party vendors and business partners.

Personal information generally means information that can be used to identify you or that can be easily linked to you (for example, your name, address, telephone number, email address, social security number, and date of birth). The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act ("CCPA") or European General Data Protection Regulation ("GDPR"), our use of the phrase "personal information" includes the unique elements required by such laws.

The categories of information we collect from each of these groups, and the ways in which we use it, differ. As you may have noticed, the same person could fall into more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors to and users of our online and mobile resources and our customers.

What We Collect

There are two types of information that we obtain from you online and then store and use: (i) non-personal information that's collected automatically from each visitor, such as your device operating system; and (ii) personal information that you voluntarily provide to us or that is collected automatically.

By using our online and mobile resources or purchasing our products or services, you are signifying that you agree with this section of our privacy statement and that we may use and disclose your information as described.

Voluntarily Submitted Information

If you participate in certain activities via our online and mobile resources, you may be asked to provide us with information about yourself. The types of personal information we collect in those situations include identifiers (such as your name, email address, physical address, and phone number), professional information (such as the business you are in), and financial account information (such as your credit card information). We do not sell, rent, or trade voluntarily submitted personal information with third parties.

If you do not want us to collect this type of personal information, please do not provide it. This means you should not participate in the activities on our online and mobile resources that request or require it. Not participating may limit your ability to take full advantage of the online and mobile resources, but it will not affect your ability to access certain publicly available information.

Some of the ways you voluntarily give us your personal information and how we use it:

• Emails and Online Forms – When you send us an email or fill out an online form, your email address and any other personal information in the content of your message are retained by us and used to respond directly to you and to process your request.
• Registering for an Account – When you register for an account, you submit personal information such as your name and email address, which we use to create and manage your account.
• Registering for Events – When you register for services, webinars, events, conferences, or programs we host, you will be submitting identifiers as described above. If the event requires a fee, we may also ask for credit card or other financial information.
• Becoming a Subscriber – We use any information provided from our customers to perform our contractual obligations and provide the products and services purchased, to manage their accounts and communicate with them.
• Social Media and Community Features – Some of our online and mobile resources may offer community features where users post messages and comments. Information you post will be in the public domain and not covered by this statement.

Automatically Collected Information

When you visit our online and mobile resources, basic information is passively collected through your web browser via use of tracking technologies, such as a "cookie" — a small text file downloaded onto your computer or mobile device that recognizes your device and stores information about your preferences or past actions.

We allow third-party vendors to use cookies or similar technologies to collect information about your browsing activities over time. For example, we use Google Analytics, a web analytics service provided by Google, Inc. For more information on how Google uses this data, visit https://policies.google.com/technologies/partner-sites. You can opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

Internet activity information collected through cookies includes: the domain name and IP address from which you accessed our resources; the type of browser and operating system you use; the date, time, and length of your visit; specific pages visited; graphics viewed; documents downloaded; and links used to or from our resources.

Additionally, if you access our resources from a mobile device, the mobile services provider may transmit uniquely identifiable device information to us. Some vendors also operate systems that pinpoint physical device location, and we may receive this information if location services are enabled on your device. If you do not want us to collect geolocation data, disable location services through your device settings.

User Beware: External Sites, Apps, Links and Social Media

We maintain a presence on external social media platforms such as X, Facebook, Instagram, YouTube, and LinkedIn. Our online and mobile resources may also contain links to websites or apps controlled by third parties. We are not responsible for the content or privacy practices of those platforms, sites, or apps. We encourage you to read their privacy policies carefully.

How We Use Your Information

The Elliott Group may use the information we collect from and about you for a variety of business purposes — in general, to provide services, improve customer experience, and develop the services. We will have a lawful basis for processing your data if:

• We need to process your information in order to provide you with the products or services you have requested or to enter into a contract;
• You have consented to such processing;
• We have a legitimate interest for processing your data — e.g., for fraud prevention, direct marketing, network and information systems security, data analytics, enhancing or improving our services, identifying usage trends, determining the effectiveness of promotional campaigns, and advertising personalization; and/or
• We are legally obligated to process it.

Customer Service & Transaction Purposes

• To provide the requested Services to you.
• To manage your account.
• To personalize your experience.
• To improve our website and customer service.
• To diagnose problems with our servers or Services.
• To process transactions, such as purchases and subscriptions.
• To use and disclose financial information only to process payments and prevent fraud.
• To administer a contest, promotion, survey, or other site feature.
• To develop new products or services and to enhance current products and services.
• To send periodic emails about Services updates, orders, and/or subscriptions.
• To protect the security or integrity of our Services and our business.

Commercial Purposes

• To send you marketing and promotional emails.
• To target prospective customers with our services (only with your permission where consent is required by applicable law).

When / With Whom Do We Share Personal Information

We do not sell or rent your personal information to third-party data vendors or marketing companies. As you might expect, we disclose your information when required by law.

Affiliates

We may share your information within our family of companies. Those companies will use such information in generally the same manner as we do under this privacy statement.

Legally Compelled Disclosures

We may disclose your information to government authorities, and to other third parties when compelled to do so by such government authorities, or as required or permitted by law, including but not limited to responding to court orders and subpoenas.

To Prevent Harm

We may disclose your information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the online and mobile resources, or anyone else that could be harmed by such activities.

Business Transfer

If we or any of our affiliates, or substantially all assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.

Vendors and Business Partners

We may share your information with our vendors and other third parties with whom we have a contractual relationship. We attempt to bind such vendors and business partners to data protection standards via written contracts, ensuring that personal information is used only to the extent necessary to carry out the business purpose for which it was provided.

Please note that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.

Email Communications, Newsletters, and Marketing

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at [email protected].

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS.

Your Rights and Options

You may have to provide personal information to enjoy most of the features of our online and mobile resources. Moreover, you can opt out of certain activities like newsletters and announcements. Residents of California and EU data subjects have certain additional rights.

When you access your account on the Services, you have the option to change certain information about yourself, such as your billing or shipping address and telephone number.

Emails. If you consented to receive direct marketing from The Elliott Group, we provide you with the opportunity to opt out by following a link in the footer of all non-transactional email messages from us or by emailing us at [email protected]. Some communications from us are considered transactional or service communications (for example, account notifications and billing information) and cannot be unsubscribed from.

Some browsers have a "do not track" feature. Currently, we do not specifically respond to browser "do not track" signals.

The California Consumer Privacy Act

When we collect personal information from California residents, we become subject to, and those residents have rights under, the California Consumer Privacy Act ("CCPA"). For purposes of this section, the words "you" and "your" mean only such California residents.

What We Collect From California Residents

We collect the following categories of personal information: identifiers such as name, address, IP address, and other similar identifiers; personal information described under the California customer records statute such as a name, address, telephone number, and credit card number; commercial information such as products or services purchased; internet/electronic activity such as browsing history and search history; geolocation data including geographic coordinates/physical location; and audio, video, electronic or other similar information. We do not sell, and within the last 12 months have not sold, personal information to third parties.

Rights of California Residents

If you are a California resident, you have the right to request the following:

• Access: Up to two times per year, you can request that we disclose (1) the categories and specific pieces of personal information collected from you; (2) the sources of that personal information; (3) the business or commercial purpose for that collection; (4) the categories of personal information we have disclosed for a commercial purpose; and (5) the categories of third parties with whom we have shared your personal information.
• Deletion: You may request that we delete any personal information that we have collected from or about you. There may be instances where we will not be able to fully comply with your request, such as if we need the personal information to complete a transaction, to detect and protect against fraudulent or illegal activity, or to comply with a legal obligation.

If you exercise these rights, we will not "discriminate" against you by treating you differently from other California residents who did not exercise their rights.

To exercise your rights under California law, contact us at [email protected]. We may ask you to fill out a request form and verify your identity before acting on your request.

Virginia Residents

If you are a Virginia resident, you may take advantage of certain privacy rights pursuant to Virginia Code 59.1-577. For example, you may request to access, correct, or delete your personal information. You may also exercise your right to opt-out of "selling" personal information or "targeted advertising" as those terms are defined in Virginia law. You have the right to appeal a denial of your privacy rights.

To exercise your rights under Virginia law, or to submit an appeal, please contact us at [email protected]. We can only act on your request if we can verify your identity.

The EU General Data Protection Regulation

We do collect or otherwise obtain personal information from data subjects located in the GDPR Jurisdictions. We describe below how we comply with the GDPR for personal information collected from visitors to and users of our online and mobile resources while they were in a GDPR Jurisdiction. For purposes of this section, the words "you" and "your" mean only such GDPR Jurisdiction-based visitors and users.

GDPR Jurisdictions means the countries composed of the European Economic Area (including Iceland, Lichtenstein, and Norway) and all EU member states. Additionally, certain countries such as Andorra, Argentina, Canada (commercial organizations), the Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, and Japan have received an "adequacy decision" from the European Commission and adhere to the material terms of the GDPR. Note: GDPR no longer has jurisdiction over the United Kingdom; the UK operates under its own UK-GDPR.

What We Collect & Lawful Basis

We collect from you the categories of personal information already described. The lawful basis on which we rely for such collection, use, and disclosure is what the GDPR refers to as legitimate interest. We do not sell any of your personal information to third parties nor do we use it for automated decision making.

Cross-border Data Transfers and Third-Party Processors

If we transfer personal information from the GDPR Jurisdictions to a location that has not been deemed by the European Commission to have adequate privacy protections, we do so in the manner the GDPR permits.

Rights of Data Subjects in the GDPR Jurisdictions

You have the following rights with respect to personal information collected from you while you were in a GDPR Jurisdiction: transparency, access, correction and deletion, portability, restriction/objection, and the right to know who, what, why, and where your personal information is used.

To exercise any of these rights, please contact [email protected]. Your ability to exercise these rights is subject to certain conditions and exemptions under Articles 12 through 23 of the GDPR. If you are not satisfied with how we use your personal information or respond to your requests, you have the right to complain to your data protection regulator.

Online Tracking Technologies and Advertising

We, certain service providers operating on our behalf, and third parties may collect information about your activity on our sites and applications using tracking technologies such as cookies, pixels, tags, software development kits, application program interfaces, and web beacons.

Types of Cookies We Use

• Analytics and Performance Cookies – These cookies collect information about traffic to our Services and how users use our Services. We use Google Analytics for this purpose. You can prevent the use of Google Analytics by downloading the browser plugin available at tools.google.com/dlpage/gaoptout.
• Essential Cookies – These cookies are essential to provide you with services available through our Services and to enable you to use its features. Without these cookies, the services you have requested cannot be provided.
• Functionality Cookies – These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences and login details.
• Pixel Tags – Small graphic files that allow us and third parties to monitor the use of the Services and collect usage data, including IP address, page URL, time of visit, browser type, and cookie identification information.

Opt-Out Preference Signals and Do Not Track

You or your authorized agent may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control ("GPC"). We will process the GPC signal as a request to opt out.

Do Not Sell or Share My Personal Information

Some states provide residents with the right to opt-out of the "selling" or "sharing" of their personal information, or of "targeted advertising" based on their personal information. To submit a request to opt out, please send an email with the subject line "Do Not Sell or Share My Personal Information" to [email protected] with your contact email, first name, last name, country, and state.

We adhere to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising.

Agent Authorization

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents need to demonstrate that you've authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. The Elliott Group retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request.

Children's Privacy

Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously, and consistent with it, do not intend for our online and mobile resources to be used by children under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to our online and mobile resources, we will delete that information and will not use it for any purpose whatsoever.

If you believe that someone under the age of 18 has submitted personal information to our online and mobile resources, please contact us at [email protected]. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.

How We Protect Collected Personal Information

We will take all reasonable security precautions to protect your personal information. We have adopted a security program that includes technical, organizational, administrative, and other security measures designed to protect against anticipated or actual threats to the security of personal information (the "Security Program"), in a manner consistent with accepted industry standards and applicable law.

We cannot, however, guarantee that your information will be free from unauthorized access, loss, misuse, destruction, or alteration. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information.

Nonetheless, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised. We further require our vendors and business partners to notify us immediately if they have any reason to believe that an incident adversely affecting personal information we provided to them has occurred.

Rights of Data Subjects in Other Jurisdictions

In other jurisdictions with similar data privacy regulations, we may collect from you the categories of personal information already described. We collect and manage (including disclose) such data in compliance with applicable local law(s). As noted, we do not sell any of your personal information to third parties nor do we use it for automated decision making.

Changes to This Privacy Statement

This privacy statement was drafted on July 22, 2025, and is effective as of this date. The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.

We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at that time.

Contacting Us

If you have questions about our privacy statement or privacy practices, please contact us: