Elegantix, Inc.

Privacy Policy

Last Updated: April 14, 2026

1. Introduction and Scope

Elegantix, Inc. ("Elegantix," "we," "us," or "our") provides AI education programs and related services for mid-market businesses, including cohort-based courses, certifications, diagnostic assessments, educational webinars and briefings, and fractional AI advisory engagements (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our website at https://www.elegantix.com (the "Site"), our business communications, and our provision of the Services. It does not replace any Master Service Agreement, Order Form, Statement of Work, Data Processing Addendum, or other written agreement between Elegantix and a customer. Capitalized terms used but not defined here have the meanings given in our Terms of Service.

2. Our Roles

Elegantix acts in different roles depending on the information involved. For personal information we collect directly from Site visitors, prospective customers, business contacts, and individual course enrollees, Elegantix acts as a business or controller and determines the purposes and means of processing. For identified personal information contained in Customer Data submitted to the Services by or on behalf of a business customer (for example, employee data submitted in connection with a private company program or a fractional engagement), Elegantix generally acts as a service provider or processor on behalf of that customer to provide the Services. Where permitted by contract and law, Elegantix may also create and use De-Identified Data from Customer Data for internal business purposes as described in Section 5.

3. Information We Collect

3.1 Information You Provide Directly

We collect business contact information (name, business email, phone, company name, job title); account credentials and profile information for course enrollment and access to our learning platform; payment and billing information (typically processed through third-party payment processors such as Stripe); information you provide when completing the AI Opportunity Report or other diagnostic assessments; assignments, capstone deliverables, and other course work submitted during a cohort; questions and contributions posted in cohort or alumni communities; applications for Track A cohorts and similar programs; communications you send to us, including support requests, feedback, and testimonials; and information submitted in connection with private company engagements, fractional advisory conversations, onboarding, or integrations.

3.2 Information Collected Through the AI Opportunity Report and Other Assessments

When you complete the AI Opportunity Report or similar diagnostic tool, we collect your responses (which may include descriptions of your business, operational practices, and strategic priorities), generate a personalized written report using third-party artificial intelligence providers (see Section 6), and retain both your input and the generated output to deliver follow-up communications, improve future assessments, and, where applicable, inform our advisory discussions with you.

3.3 Information Collected Through Course Delivery and the Learning Platform

Depending on the Services used, we may process: video and audio of live cohort sessions you choose to participate in; chat messages and Q&A submissions during sessions; quiz and exam responses, including responses submitted for the AI Proficiency Certification; attendance and engagement metrics (sessions attended, assignments submitted, community contributions); and other content you submit through the learning platform or community.

3.4 Information Collected Automatically on the Site

When you use our Site, we and our third-party partners may automatically collect IP address and approximate location, browser and device information, session and log data, and information collected through cookies, pixels, software development kits, and similar tracking technologies used for authentication, security, site functionality, analytics, marketing attribution, and advertising. See Section 8 for details, including partner categories and your choices.

3.5 Information from Third Parties

We may receive information from single sign-on providers, payment processors, integration partners authorized by a customer, marketing and advertising partners, referrers (for example, alumni who introduce you to Elegantix), and company sponsors or administrators who register employees for our programs.

4. How We Use Information

We use personal information to:

• provide, maintain, support, and secure the Site, the learning platform, and the Services;
• authenticate users, manage accounts, and deliver cohort programs;
• process payments and administer enrollments, refunds, and scholarships;
• generate personalized AI Opportunity Reports and other diagnostic outputs;
• deliver, record, and distribute live cohort sessions, webinars, and briefings;
• evaluate course assignments, certification exams, and capstone deliverables;
• facilitate cohort communities, peer discussions, alumni networks, and post-program events;
• provide customer support, onboarding, and follow-up to assessment completers;
• detect and prevent fraud, abuse, academic dishonesty, and security incidents;
• enforce our agreements, protect our legal rights, and maintain educational integrity;
• comply with applicable law and legal process;
• send service-related notices and business communications;
• operate marketing, advertising, attribution, and referral activities on the Site and across marketing channels (subject to Section 8);
• research, analyze, and improve our curricula, facilitation quality, and program outcomes; and
• create and use De-Identified Data as described in Section 5.

We may use business contact information to send marketing communications permitted by law; you may opt out using the unsubscribe link in those messages or by contacting us through our Contact page.

5. De-Identified Data

"De-Identified Data" means information derived from Customer Data, assessment responses, or learning-platform usage that is maintained in a form not reasonably capable of being associated with, linked to, or used to infer information about an identified or identifiable person or household.

When creating De-Identified Data, we use measures reasonably designed for the nature of the data and the foreseeable risks of identification, which may include removing or replacing direct identifiers, generalizing or suppressing metadata, removing account- or response-level references not needed for the intended use, segregating source data from de-identified datasets, restricting access to identified source data, and periodically testing de-identification controls.

Elegantix publicly commits to maintain and use De-Identified Data in de-identified form and not to attempt to re-identify it, except solely to test whether its de-identification processes remain effective. We use De-Identified Data for internal lawful business purposes, including curriculum improvement, research on educational effectiveness, benchmarking across cohorts, safety and abuse prevention, marketing analytics, and program development. We do not sell, license, disclose, or otherwise make available De-Identified Data to third parties in row-level, response-level, or customer-specific form, except to service providers acting on our behalf under written restrictions that prohibit re-identification and unauthorized use.

Because De-Identified Data is not reasonably linked to any individual, we generally cannot respond to a request to access, correct, or delete such data as if it were identified personal information.

6. Use of Third-Party Artificial Intelligence Providers

To deliver certain Services, most notably the AI Opportunity Report and other personalized outputs, we transmit your inputs to third-party artificial intelligence providers, including Anthropic, PBC (provider of the Claude application programming interface). These providers process your inputs to generate the relevant outputs and then return those outputs to Elegantix.

We select AI providers whose commercial terms prohibit the use of customer inputs and outputs for training their general-purpose models absent separate consent. Except where you have expressly authorized a different arrangement or where an applicable business-customer agreement provides otherwise, Elegantix does not authorize any AI provider to use identified inputs or outputs for model training or for purposes outside of providing the requested computation back to Elegantix.

AI-generated outputs such as the AI Opportunity Report are probabilistic, may contain inaccuracies, and are provided for informational and educational purposes only. They do not constitute professional, legal, financial, or business advice.

7. How We Disclose Information

We may disclose personal information:

• to service providers and contractors that help us host, secure, support, and operate the Site, the learning platform, and the Services (including hosting providers, payment processors, email delivery services, video hosting providers, community platforms, and analytics vendors);
• to third-party artificial intelligence providers as described in Section 6;
• to instructors, facilitators, and advisors engaged by Elegantix to deliver programs;
• to other cohort participants, to the limited extent necessary for peer learning (for example, making your name, company, and role visible within the cohort community);
• to advertising, analytics, attribution, and marketing partners in connection with Site and marketing activities as described in Section 8;
• to company sponsors, administrators, or employers who purchased a program on your behalf, for the limited purpose of confirming enrollment, attendance, and completion;
• to professional advisors, including auditors, lawyers, and insurers;
• in connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets;
• to comply with law, legal process, or lawful government requests;
• to protect rights, safety, security, and the integrity of the Services; and
• with your direction or consent.

We may also disclose aggregate statistics and De-Identified Data consistent with Section 5.

Scope of Our No-Sale / No-Share Commitment for Customer Data and Assessment Inputs

Elegantix does not sell or share Customer Data, assessment responses, course assignments, capstone deliverables, or learning-platform usage data for cross-context behavioral advertising, and does not use such data for third-party advertising purposes. Certain Site and marketing activities described in Section 8 may involve sharing limited Site visitor information with advertising and analytics partners in ways that may be considered a "sale" or "sharing" of personal information under California and other U.S. state privacy laws. You may opt out as described in Sections 8 and 10.

8. Cookies, Tracking, and Advertising on the Site

On the Site, we and our third-party partners use cookies, web beacons, pixels, software development kits, and similar tracking technologies for essential Site functionality and authentication; security and abuse prevention; remembering preferences; site analytics and performance measurement; marketing attribution and conversion tracking; and personalized advertising and remarketing across other websites and services. Our partners may include providers of web analytics, advertising networks, social media platforms, and marketing attribution tools, and may set their own cookies or similar identifiers on your device. Their collection and use of information is subject to their own privacy policies.

Some of the Site tracking activities described above may constitute a "sale" or "sharing" of personal information as those terms are broadly defined under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) and similar laws in other U.S. states. The categories of personal information involved are limited to identifiers (such as IP address and online identifiers) and internet or electronic network activity (such as browsing behavior on the Site). These disclosures apply only to information collected through the Site and our marketing activities; they do not apply to identified course enrollment data, assessment responses, course assignments, capstone deliverables, or learning-platform activity.

You can manage cookies and tracking by:

• adjusting your browser settings to block or delete cookies;
• using the "Do Not Sell or Share My Personal Information" link on our Site, which applies to Site tracking activities;
• enabling Global Privacy Control (GPC) in your browser; we honor GPC signals as a valid opt-out of sale/sharing for the browser and device from which the signal is received;
• opting out of interest-based advertising through industry tools such as the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org);
• installing the Google Analytics Opt-Out Browser Add-on for Google Analytics; and
• adjusting mobile device advertising settings (Limit Ad Tracking / Opt Out of Ads Personalization).

Some cookies are necessary for Site and learning-platform functionality and cannot be disabled without affecting your ability to use the Services.

9. Data Retention

Site and Business Contact Data

We retain Site visitor, business contact, and marketing-list information for as long as reasonably necessary for lead management, contractual performance, marketing activities you have not opted out of, legal compliance, and legitimate business recordkeeping.

Account, Enrollment, and Learning-Platform Data

We retain identified account and enrollment records, including course rosters, attendance, assignments, exam results, and certification records, for as long as your account is active, plus a reasonable period thereafter to verify credentials, support alumni services, and comply with legal and tax obligations. Unless required by law or expressly agreed otherwise, we retain certification and completion records for a minimum of seven (7) years to support credential verification.

AI Opportunity Report Inputs and Outputs

We retain your assessment responses and the corresponding personalized report for up to twenty-four (24) months to support follow-up communications and advisory conversations, unless you request earlier deletion or a longer period is needed for legal, security, or operational reasons.

Live Session Recordings

Recordings of live cohort sessions are generally retained for the duration of the cohort and made available to enrolled participants for a period of time consistent with the program's access window. Selected recordings may be retained longer for alumni access, instructor training, and curriculum improvement. We may redact, edit, or remove portions of recordings to protect participant confidentiality.

Business Customer Data

For Customer Data processed on behalf of a business customer in a private company engagement or fractional advisory relationship, we retain data for the period set by the applicable Order Form, MSA, or documented retention setting. If no specific retention period is agreed, we may retain identified data for up to ninety (90) days after the engagement ends, unless the customer requests earlier deletion or a longer period is needed for legal, security, or operational reasons.

Post-Termination

After a customer relationship ends, we may retain identified data for up to thirty (30) days to permit export, then delete it from production systems within a commercially reasonable period, subject to legal retention requirements and legal holds, backup and disaster-recovery cycles, audit and security logs, and data already maintained only in de-identified form.

De-Identified and Aggregate Data

We may retain De-Identified Data and aggregate data for longer periods, including after termination, so long as it is maintained in de-identified or aggregate form.

10. Your U.S. Privacy Rights

Depending on your U.S. state of residence, you may have rights to request access to, correction of, or deletion of certain personal information; to opt out of the sale or sharing of personal information; to limit the use and disclosure of sensitive personal information; and to appeal certain decisions relating to such requests. If you are a California resident, you have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including the rights listed above and the right to receive information about the categories and specific pieces of personal information we collected, the sources, the purposes of collection and disclosure, and the categories of third parties to whom we disclosed personal information.

10.1 Opt Out of Sale or Sharing

To exercise your right to opt out of the sale or sharing of your personal information as described in Sections 7 and 8, you may click the "Do Not Sell or Share My Personal Information" link on our Site, contact us through our Contact page with the subject line "Do Not Sell or Share," or enable Global Privacy Control (GPC) in your browser, which we honor as a valid opt-out signal for that browser and device.

10.2 Limit Use of Sensitive Personal Information

Elegantix does not routinely collect Sensitive Personal Information as defined under CCPA/CPRA. If you believe we have collected Sensitive Personal Information about you and wish to limit our use and disclosure of such information, contact us through our Contact page with the subject line "Limit Use of Sensitive PI."

10.3 Requests Involving Business Customer Data

If your information was submitted to the Services by an Elegantix business customer (for example, your employer registered you for a private company program), we may direct your request to that customer because Elegantix generally processes that information on the customer's behalf. We may not be able to provide access to or delete information maintained only in de-identified form because it is not reasonably linked to you.

10.4 Financial Incentives and Non-Discrimination

From time to time we offer scholarships, alumni discounts, referral rewards, or similar incentives that may be considered financial incentives under state privacy law. The material terms of any such program will be disclosed when offered. You are not required to participate, and we will not unlawfully discriminate against you for exercising privacy rights.

10.5 How to Submit a Request

You may submit a privacy request through our Contact page or using any privacy request form we make available on our Site. We may need to verify your identity before responding. We will respond to verifiable requests within the timeframes required by applicable law, generally within forty-five (45) days.

11. Security

Elegantix maintains reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. These measures may include encryption in transit and at rest where appropriate, role-based access controls, logging, vulnerability management, secure development practices, and incident response procedures. We will notify affected customers without unreasonable delay after confirming a security incident involving their data in Elegantix's systems, consistent with applicable law. No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

12. Children's Privacy

The Site and Services are directed to business professionals and are not intended for children. We do not knowingly collect personal information from children under the age of sixteen (16). If we learn that we collected such information without appropriate authorization, we will take reasonable steps to delete it.

13. U.S.-Only Processing

The Services are operated from the United States, and data submitted through the public offering of the Services is intended to be stored and processed in the United States. Because the Services are U.S.-only, you should not submit personal information subject to non-U.S. comprehensive privacy regimes through the public Services unless we have expressly agreed otherwise in a signed written agreement.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make a material change, we will post the revised version and update the "Last Updated" date. Where appropriate, we may also provide additional notice by email, in-product message, or website notice.

15. Contact Us

Elegantix, Inc.
Attn: Privacy Team
Privacy requests and questions: use our Contact page.
Website: https://www.elegantix.com
Address: [ASSUMPTION: insert business mailing address]

This document was generated with AI assistance and is intended as a starting point for legal review. It does not constitute legal advice. Laws and regulations change frequently, and the applicability of specific provisions depends on your company's unique circumstances. This document should be reviewed and customized by a licensed attorney before being published or relied upon. Elegantix, Inc. bears sole responsibility for ensuring its legal documents comply with all applicable laws.