1. Introduction and Scope

TDA Trust, doing business as CL Trust Solutions ("CL Trust Solutions," "Company," "we," "us," or "our"), is a private-based organization operating at cltsondemand.com, cltrustsolutions.com, and all associated subdomains. This Privacy Policy governs the collection, use, storage, disclosure, and protection of information obtained from visitors, users, subscribers, and members (collectively, "you" or "User") who access or interact with our website, platforms, communications, and services (collectively, the "Services").

By accessing or using any part of our Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree, you must immediately discontinue use of the Services. This Policy is incorporated by reference into our Terms of Use and any applicable membership or subscription agreement.

This Privacy Policy applies to all Services operated by CL Trust Solutions regardless of the device, platform, or method through which you access them.

2. Our Data Minimization Commitment

We do not build advertising profiles. We do not engage in behavioral tracking for commercial purposes. We do not operate data brokerages. We do not share your identity, contact information, financial data, or usage patterns with any entity for monetization purposes.

3. Information We May Collect

We collect limited categories of information solely to operate and improve our Services. This may include:

• Account and Registration Information: Name, email address, and password provided when you create an account or subscribe to a membership package.
• Billing and Payment Information: Payment is processed exclusively by third-party payment processors. We do not store, log, or have access to full credit card numbers, bank account details, or other sensitive financial credentials.
• Communication Data: Information you voluntarily provide when submitting a support ticket, referral form, or contacting us directly via any channel.
• Usage and Log Data: Standard server log information including IP address, browser type, referring URL, pages visited, and timestamps. This data is used for security, diagnostics, and platform improvement only.
• Form Submission Data: Information submitted through HubSpot-powered forms embedded on our platform, governed additionally by HubSpot's privacy policy.
• AI Platform Interaction Data: Queries and inputs submitted to AI-powered features of the Services. See Section 7 for full disclosure regarding AI data handling.

4. How We Use Your Information

We use the information we collect strictly for the following purposes:

• To create and manage your member account and deliver the Services you have subscribed to.
• To process payments and verify subscription status through authorized third-party processors.
• To respond to support inquiries, technical issues, and member communications.
• To deliver weekly call recordings, AI archive access, and other subscribed content.
• To send transactional communications including receipts, access credentials, and service updates.
• To maintain the security, integrity, and availability of our platform infrastructure.
• To comply with applicable legal obligations, regulatory requirements, or lawful government requests.

We do not use your information for unsolicited commercial marketing to third parties, automated decision-making that produces legal or similarly significant effects without human review, or any purpose not disclosed in this Policy.

5. Cookies and Tracking Technologies

Our website may use cookies and similar technologies to support basic site functionality, session management, and platform performance. We do not use third-party advertising cookies, cross-site tracking pixels, or persistent behavioral profiling technologies.

You may configure your browser to refuse cookies or to notify you when cookies are being sent. Disabling cookies may limit certain functionality of the Services. We do not respond to "Do Not Track" browser signals at this time, as no industry standard for such signals has been established.

6. Third-Party Service Providers

CL Trust Solutions utilizes certain third-party service providers to operate the Services. These providers may process limited personal data solely on our behalf and are contractually prohibited from using your data for their own independent purposes. Current third-party providers include, without limitation:

• Payment Processing: Stripe and/or other PCI-DSS compliant payment processors for subscription billing.
• Learning Management System: Kajabi (courses.cltsondemand.com) for member portal access and content delivery.
• CRM and Form Services: HubSpot for contact forms, support tickets, and referral submissions.
• Video Hosting: Vimeo for delivery of recorded call content and demonstration videos.
• Artificial Intelligence Services: OpenAI, LLC. See Section 7 for complete disclosure.

Each third-party provider maintains its own privacy policy and data practices. CL Trust Solutions is not responsible for the data practices of third-party providers beyond our contractual agreements with them. We encourage you to review the privacy policies of any third-party service you interact with through our platform.

7. Artificial Intelligence Platform Disclosure (OpenAI)

CL Trust Solutions does not control, and expressly disclaims responsibility for, the data retention, storage, model training, or privacy practices of OpenAI with respect to data processed through OpenAI's infrastructure. By using any AI-powered feature of our Services, you acknowledge and agree that:

• Your queries and prompts may be transmitted to OpenAI's servers located in the United States or other jurisdictions.
• OpenAI may process, analyze, and in some configurations retain such data pursuant to its own policies.
• CL Trust Solutions makes no warranty or representation regarding OpenAI's data handling practices.
• Any concerns, disputes, or claims arising from OpenAI's handling of your data must be directed to OpenAI directly at openai.com/policies/privacy-policy.
• You assume all risk associated with submitting sensitive, confidential, or personally identifiable information to any AI-powered feature.

We strongly advise Users not to submit sensitive personal information, confidential business details, or legally privileged information through any AI-powered query interface. The AI Archive Intelligence Platform is designed to retrieve and interpret content from CLTS educational call recordings. It is not a secure legal or financial advisory channel.

8. Data Security

CL Trust Solutions implements commercially reasonable technical and organizational measures to protect the information we hold from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (TLS/SSL), access controls limiting data access to authorized personnel only, and regular security review of our platform infrastructure.

However, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your information. In the event of a data breach that materially affects your rights, we will notify affected Users in accordance with applicable law.

9. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, to maintain your active account, or to comply with applicable legal, regulatory, tax, or accounting obligations. When data is no longer required, we delete or anonymize it using reasonable means.

If you cancel your subscription or close your account, we may retain certain limited information (such as billing records and correspondence) as required by applicable financial and legal record-keeping requirements.

10. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including the right to access, correct, or request deletion of information we hold about you. To exercise any such rights, please contact us using the information in Section 14. We will respond to verifiable requests within the timeframe required by applicable law.

Residents of California may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to delete, and the right to opt out of sale of personal information. We do not sell personal information, and therefore the opt-out right is not applicable to our current practices.

11. Children's Privacy

Our Services are intended solely for individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that a minor has provided us with personal information without verifiable parental consent, we will take immediate steps to delete that information. If you believe a minor has submitted information to us, please contact us immediately.

12. International Users

CL Trust Solutions is operated from the United States. If you are accessing our Services from outside the United States, you acknowledge that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your home jurisdiction. By using our Services, you consent to such transfer and processing.

13. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we do, we will revise the "Last Updated" date at the top of this page. Where changes are material, we will make reasonable efforts to provide notice to active members via email or platform notification. Continued use of the Services following notice of changes constitutes your acceptance of the revised Policy.

It is your responsibility to review this Privacy Policy periodically. We recommend checking this page whenever you access the Services if you are concerned about how your information is being used.

14. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal information, please contact us through our official support channel:

We do not accept privacy-related requests via social media, third-party platforms, or unofficial channels. All inquiries must be submitted through our official support portal to be processed.