LAKESH FOUNDATION PRIVACY POLICY FOR ONLINE COURSES HOSTED ON THINKIFIC

This Privacy Policy governs the collection, use, and disclosure of personal data collected through online courses hosted on the Thinkific platform by or on behalf of the Lakesh Foundation (the "Sponsor") and Peak Performance RDI, LLC ("Peak Performance RDI").

1. Scope and Applicability

This Privacy Policy applies to all users of Lakesh Foundation’s online courses (“Users”), including but not limited to:

• Individuals who access or use any course content via the Thinkific platform.
• Participants in live sessions, webinars, or recorded lectures.
• Those who interact with course materials, assessments, or communication channels within the platform.

This Policy does not apply to third-party websites linked from Lakesh Foundation’s courses or external services not controlled by Peak Performance RDI. Users are encouraged to review such third-party privacy policies before engaging further.

2. Data Collection and Processing

A. Personal Information Collected

The Sponsor and Peak Performance RDI collect the following categories of personal data:

1. Identification and Contact Details

   • Full name, email address, phone number (optional).
   • Mailing address (for physical course materials or shipping if applicable).

2. Demographic Data (Optional for Course Improvement)

   • Age range, occupation, prior education level.
   • Gender identity (only where relevant to inclusion practices in course content).

3. Payment Information

   • Payment processor data (e.g., transaction IDs, last four digits of credit cards) stored by third-party payment gateways (not retained by Lakesh Foundation).
   • Refund-related records if applicable.

4. Interactive Data

   • Course progress and completion status.
   • Engagement metrics (e.g., time spent on modules, quiz scores, video watch history).
   • Live session attendance or participation in discussions.

5. Communication Preferences

   • Consent to receive course updates, marketing materials, or newsletters via email.

6. Technical and Usage Data

   • IP address.
   • Browser type, operating system, device ID (where applicable).
   • Cookies and tracking pixels for platform functionality and analytics.
   • Log data (e.g., error reports, system performance metrics).

B. Lawful Basis for Processing

The Sponsor processes personal data under the following legal bases:

• Performance of a Contract – To deliver course access, track progress, and provide certificates.
• Legitimate Interests – For internal analytics to improve course quality, detect fraud, or enhance user experience (e.g., identifying technical issues).
• Consent – Explicit permission for marketing communications, surveys, or data sharing with third-party service providers.

3. Data Security and Retention

A. Protection of Personal Data

Peak Performance RDI implements reasonable technical and organizational measures to safeguard personal data, including:

• Encryption at rest and in transit (e.g., SSL/TLS for Thinkific platform).
• Access controls limiting internal staff from unnecessary access.
• Regular security audits and penetration testing where feasible.

B. Data Retention Period

Personal data is retained only as long as necessary to fulfill the purposes outlined in this Policy, including:

• Course completion records: 7 years (for tax and compliance purposes).
• User account data: Until request for deletion or cancellation of service.
• Payment data: 24 months post-purchase (or longer where legally required).

After retention periods expire, data is securely destroyed or anonymized.

4. Data Sharing and Disclosures

A. Third-Party Service Providers

The Sponsor may share personal data with trusted third parties to facilitate course operations:

• Payment Processors – For transaction processing (e.g., Stripe).
• Email Marketing Services – To send newsletters or updates (if consent is given).
• Thinkific Platform Support Teams – To troubleshoot technical issues.
• Legal and Financial Auditors – Where legally required (e.g., tax reporting).

B. Legal Compliance

Personal data may be disclosed to law enforcement, government agencies, or courts if:

• Required by law.
• Necessary for public safety or legal defense.

C. Non-Disclosure of Sensitive Information

Peak Performance RDI and the Sponsor do not collect or store sensitive personal data such as:

• Biometric data (e.g., facial recognition).
• Genetic, racial, or ethnic origin.
• Religious beliefs.
• Political opinions.

5. User Rights Over Personal Data

Users retain the following rights regarding their personal information:

6. Data Minimization and Anonymization

Where possible, Peak Performance RDI anonymizes or aggregates user data to:

• Remove direct identifiers (e.g., replacing names with unique IDs).
• Use pseudonymous data for internal analytics.
• Avoid unnecessary collection of personal details.

7. Third-Party Integrations and Cookies

A. Thinkific Platform Features

Thinkific may use:

• Session cookies to maintain logged-in status during a single session.
• Persistent cookies (e.g., Google Analytics) for analytics and marketing purposes (opt-out via browser settings or Google’s Ads Preferences Manager).

B. Opting Out

Users can:

• Disable cookies in their web browser settings.
• Adjust privacy preferences within Thinkific account settings.

8. Changes to the Privacy Policy

This Policy may be updated periodically to reflect changes in laws, technology, or business practices. Users will be notified via email or on-course announcements before material updates are implemented.

9. Contact Information for Inquiries

For questions about this Privacy Policy or personal data requests:

• Email: [email protected]
• Physical Address (for mail-based requests): Lakesh Foundation, 7 Orchard Lane, Nanuet, NY 10954