Privacy Notice

Last Updated: July 7, 2025

This privacy notice (“Privacy Notice”) describes how Guild Education, Inc. (“Guild,” “we,” or “us”) collects, uses, discloses and protects (“Processes”) 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 your use of our websites and subdomains (each, a “Website”), the Guild products (including but not limited to Guild Grow, Guild Global, and Academy (formerly Nomadic Learning)), the Guild Platform and any other digital platforms operated by Guild (each, a “Platform”), through our mobile applications (each an “Application”), or through your online and offline interactions with Guild (together, our “Services” for purposes of this Privacy Notice). “Personal Information” is data that identifies, relates to, or could reasonably be associated with an individual and includes the terms “Personal Data,” and “Personally Identifiable Information.” 

Your access to and use of our Services is subject at all times to our Terms of Use and this Privacy Notice. Capitalized terms not defined in this Privacy Notice shall have the meanings defined in such Terms of Use. 

This Privacy Notice applies to situations where Guild acts a “Controller,” “Business” or other term under applicable data protection law with respect to your Personal Information. This Privacy Notice does not apply to Personal Information that we process at the direction, or on behalf, of our partnering employers ("Employer Partners") 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. 

This Privacy Notice covers the following topics:

1. How We Collect Personal Information

2. What Personal Information We Collect and Why

3. How We Use Personal Information We Collect

4. Our Legal Basis for Processing

5. How We Secure Personal Information

6. How We Share Personal Information

7. Guild’s Use of Artificial Intelligence

8. Rights Under The Family Education Rights and Privacy Act (“FERPA”)

9. Children Under the Age of 13

10. Your Choices

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

12. Retention of Personal Information

13. International Transfers

14. Links to Other Websites

15. Changes to Our Privacy Notice

16. 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 interacts with Guild, for example, when a User: creates a Guild User account on the Guild Platform (“Account”) to explore available learning opportunities; edits registration information; signs up to receive our newsletters or other marketing materials or contacts; or applies to a learning program made available by Guild through the Platform and provided by a partnering educational or learning institutions (“Programs”). The Personal Information we collect may vary depending on the Guild product you interact with.

• 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 an Employer Partner, 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 the National Student Clearinghouse). We may merge or combine such Personal Information with the Personal Information we collect from you directly or automatically. 

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. Where we collect Personal Information that is not specifically listed here, Guild will notify you and process such Personal Information as described at the time of collection and otherwise in accordance with this Privacy Notice. Please note that the Personal Information we collect may vary depending on the Guild product utilized and/or the jurisdiction where you reside.

The categories of Personal Information described above may be used for the purposes set forth in Section 3 below. 

Special Categories of Data/Sensitive Personal Information. 

Some of the Personal Information that we collect about you may include “Sensitive Personal Information,” or other similar term under applicable data protection laws. Specifically, we collect, and have collected in the 12 months preceding the “Last Updated” date of this Privacy Notice, race/ethnicity and gender identity for users based in the United States, where such Users voluntarily elect to provide such information 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. 

Where we have a legitimate need to process Sensitive Personal Information for purposes not identified above, we will only do so after providing you with notice and, if required by law, obtaining your prior, express consent.

Deidentified and Aggregate Information 

Guild may also collect or create deidentified or aggregate information from Personal Information. “Deidentified Information” generally 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. “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; however, please note that these uses do not necessarily apply to all Guild products.

• Provide the Services. We use Personal Information to provide our Services to you and our partnering employers and educational or learning 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 your 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 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 ask you for permission to share or disclose recordings of your coaching sessions or other communications through a release or other form of consent. You will never be required to sign such release, and your decision to grant or withhold consent to disclosure will in no way impact the quality of the Services provided to you. To the extent you authorize Guild to share or otherwise disclose such recordings or other communications, we may use such recordings of our coaching sessions or other communications to market our services to potential and existing Users and customers and to demonstrate the functionality and value of our services,

• 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 improvements to our Programs and Services, 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 10.

• 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 10 and Section 11 of this Privacy Notice).

4. Our Legal Basis for Processing

Where a legal basis for processing Personal Information is required in your jurisdiction, our legal basis for processing Personal Information is either that: (i) such processing is necessary for the performance of a contract where you have engaged Guild to provide Services; (ii) the processing is necessary to meet legal, regulatory, or professional standards obligations; (iii) the processing is needed to perform activities in furtherance of our lawful and legitimate interests (including conducting internal administrative activities, marketing our services and analyzing our marketing efforts, and enhancing our product or member experience, in addition to the purposes described herein), or (iv) you have consented to the practices described in this privacy notice by voluntarily providing your data to us, engaging with our services or otherwise providing your consent. 

The below table identifies our legal basis for processing Personal Information.

5. How We Secure Your Personal Data

We maintain reasonable and appropriate administrative, technical, and physical safeguards designed to secure your Personal Information against unauthorized access or acquisition. We implement a combination of policies and technical and organizational measures to protect your Personal Information including:

• A designated privacy representative tasked to monitor our compliance with applicable privacy laws;

• Internal policies and procedures that provide a framework for the keeping and destruction of Personal Information, and that define the roles and responsibilities of our employees throughout the life cycle of the Personal Information we process and limit their access to that information on a “need-to-know” basis;

• Appropriate password protections implemented throughout our systems;

• Personal Information is kept encrypted or pseudo-anonymized where appropriate;

• Procedures for responding to complaints or inquiries related to Personal Information;

• If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;

• Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain adequate protections and security standards; and

• Employee training in privacy and information security. 

6. How We Share Personal Information

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

• 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 10. We may (or have in the 12 months preceding the “Last Updated” date of this Privacy Notice) “sell” (as defined under applicable laws) the following Personal Information to our Advertising Partners: Individual Identifiers (contact information) and Internet or Network Activity. Guild does not knowingly “sell” or use for “sharing/targeted advertising” the Personal Information of individuals under 16 years of age.

• 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 may include some institutions located outside of your country of residence. If you apply to or enroll in a program outside of your country of residence, your data may be transferred outside of the country where you reside. 

• Partnering Employers. We may transfer Personal Information to an Employer Partner in connection with providing Programs and Services to you, including to assess benefits eligibility, facilitate the application or enrollment process, provide information on your academic achievements and progress, enable you to receive tuition assistance and reimbursement (including sharing information, such as your communications with us, in connection with any related disputes with your employer), direct your application to a partnering employer, inform your employer about your usage of your benefit and Guild Services (including product usage) and enable them to conduct outreach to you, provide testimonial(s) regarding the service, and facilitate your application to a job opportunity. This transfer of Personal Information from Guild to Employer Partners may be considered a “sale” under certain applicable privacy laws. 

• 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 (in compliance with applicable privacy law) 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, Authorities, and Others for Legal Compliance and Security. 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).

• 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.

• Other Third Parties. 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. Additionally, 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 with the transaction. 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.

Guild may also 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. You should, at all times, assume that such content is accessible, searchable, and may be further distributed by other Users and potentially the public.

7. Guild’s Use of Artificial Intelligence

Guild uses artificial intelligence (AI) technologies and machine learning throughout our business to support the delivery of our services, to enhance your user experiences, and for quality assurance and improvement. For example, Guild may use AI within the Services to help you identify education pathways that align with your goals, interests, and market needs; to enhance our outreach and coaching strategies; to identify opportunities for skilling and learning advancements; to improve our services; to help employers forecast workforce needs, identify trends, and assess program effectiveness; and to analyze our customer interactions to help us identify areas where we can improve our customer support and ensure consistent service quality. If and to the extent Guild processes your Personal Information in connection with Guild’s use of AI, we will do so only where we have a lawful basis to do so, with appropriate human oversight, and in a manner otherwise consistent with this Privacy Notice, applicable law, and principles of data minimization.

8. Rights Under The Family Education Rights and Privacy Act (“FERPA”)

Under certain circumstances, if you enroll in a Program offered by one of our United States partnering educational or learning institutions, the information that we may receive about you from such U.S.-based educational or learning institutions 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.

9. Children Under the Age of 13

Our Services are not intended for or targeted toward children under 13 years of age and 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 guildprivacy@guild.com. We may collect Personal Information from children under 18 years of age where permitted by law and where the relevant parent or guardian has consented to such collection prior to using any Services or providing Personal Information to Guild.

10. Your Choices

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

• 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. 

• Marketing Communications. Depending on both the marketing laws in the jurisdiction where you reside and the medium of marketing communication (e.g., email, telephone, or text message), you may either opt-in to or opt-out of receiving such communications either via the Guild Website, at the time that you register for our Programs or Services, or at any time during your member journey through your Guild Account. Regardless of whether applicable laws require opt-in or opt-out consent to marketing, if at any time you would like to unsubscribe from receiving marketing communications from Guild, you may opt-out of such communications 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 transactional communications relating to your enrollment, your Account or your use of the Services, and you will continue to receive these transactional messages even if you choose to opt-out of marketing communications.

• Cookies. Depending on the laws in the jurisdiction where you reside, certain types of cookies (and similar tracking technologies) will only be used subject to your consent (opt-in) to such use. If you do not accept (either via opt-in or opt-out, as appropriate based on your jurisdiction) cookies, you may not be able to use all functionality of the Services and our Website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. Guild may use the following types of cookies: 

  1. Strictly-necessary / essential cookies: These cookies are necessary for the Website or Services to function and cannot be switched off in our systems. 

  2. Analytics cookies: These cookies help us analyze how the Services are being accessed and used, enable us to track performance, and secure the Websites. For example, we use cookies to get insights regarding users and Website performance, such as page speed or to help us customize our Websites and Services for you in order to enhance your experience.

  3. Advertising cookies: These cookies are used to make advertising messages more relevant to you and your interests. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited our Websites. The information provided to third parties is protected so as to not easily identify users. This process helps us manage and track the effectiveness of our marketing efforts. 

  4. Social media cookies: These cookies are used when you share information using a social media sharing button or “like” button on the Websites or you link your account or engage with our content on or through a social network. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

• 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 or, depending on the laws in your jurisdiction, not consenting to, third-party cookies to limit the use of the advertising ID associated with your mobile device. If you are based in the United States, 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-in/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. 

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

Certain countries, jurisdictions within countries, and 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. 

Your Privacy Rights. Depending on where you live, you may have some or all of the following rights under applicable law and under certain circumstances:

• Know/Access including, but not limited to, the following information:

  • Confirm whether we process your Personal Information.

  • The categories of Personal Information that we process.

  • The categories of sources from which we collected Personal Information.

  • The business or commercial purpose for collecting, processing, selling, or sharing Personal Information.

  • The categories of third parties with whom we disclose Personal Information.

• Erase, Cancel, or Delete the Personal Information that we have collected from or about you. Please note these rights are not absolute, and that Guild may lawfully deny such request in certain circumstances, such as where we rely on your information to supply a contractual service you have asked for, where the information is still needed for the purpose for which it was collected, or where we are required to retain it to comply with a legal obligation.

• Rectify/Correct inaccurate Personal Information that we maintain about you or completing incomplete Personal Information, including by means of providing a supplementary statement.

• Data Portability of data you provided Guild in a readily usable format (to the extent technically feasible).

• Limit Use or Disclosure Sensitive Personal Information to only certain business purposes set forth under applicable law.

• Revoke Consent to Process Personal Information, including Sensitive Personal Information where we rely on your consent pursuant to applicable law. 

• Object to Processing of Personal Information about you where such data is processed based on Guild’s legitimate interest.

• Opt-out of “sales” or “sharing/targeted advertising” if we engage in such processing activities under applicable law. 

• Lodge a Complaint with the Relevant Authority if you believe Guild’s processing of Personal Information violates applicable law. If you are in the UK, you can do this online at https://ico.org.uk/make-a-complaint/. If you are in the EU, you can find details about your data protection authority to make a complaint here. 

• Nominate an Agent to exercise your privacy rights on your behalf. 

• Not to be Subject to Solely Automated Decisions Producing Legal Effects without your consent or other legal basis and to access information about the existence of any solely automated decision-making that produces a legal effect, as well as information about the logic involved and the consequences of such processing. 

• 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 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. 

• For all other requests to exercise your privacy rights, 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; submitting your request by completing our interactive webform available by clicking here: Your Privacy Choices; or, if you reside in the EU or UK, by lodging a complaint with the competent supervisory authority.

We will comply with required requests as soon as reasonably practicable and in accordance with applicable laws. 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.

12. Retention of Personal Information

Generally, Guild will retain Personal Information, including sensitive Personal Information, for as long as necessary to fulfill the purpose of collection unless a longer retention period is required by law or if it is reasonably necessary for us to satisfy any legal, accounting, or reporting requirements, to establish and defend legal claims, and for fraud prevention purposes. When retaining 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.

13. International Transfers

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

We may also transfer your Personal Information in accordance with this Privacy Notice to our relevant partnering educational or learning institution, which may be based in a location outside your country of residence. Such transfers are necessary to perform the services that you have requested Guild provide. 

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

• ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such Personal Information; or

• where we have in place standard contractual arrangements with the recipient which have been approved by the European Commission (or the UK Government for transfers out of the UK). These model contractual clauses include certain safeguards to protect the Personal Information.

You may request further details on the steps we take to protect your Personal Information by contacting us by email at guildprivacy@guild.com at any time.

14. 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.

15. 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.

16. Contact Us

If there are any questions regarding this Privacy Notice, you may contact our Privacy representative at guildprivacy@guild.com.