Cookie Policy

1. INTRODUCTION

This Cookie Policy explains how Custom Learning Designs, LLC. ("CLD," "we," "us," or "our") uses cookies and similar tracking technologies when you visit our website at cldinc.com (the "Website"). This Policy is intended to be read alongside our Privacy Policy, which governs our broader data collection and processing practices. By continuing to use our Website, you acknowledge and accept the use of cookies as described in this Policy.

2. WHAT ARE COOKIES

Cookies are small text files placed on your device (computer, tablet, or mobile) when you visit a website. They allow the website to recognize your device, remember your preferences, and collect information about how you interact with the site. In addition to cookies, we may use web beacons, pixels, scripts, and similar tracking technologies that serve comparable functions. Collectively, these are referred to in this Policy as "cookies."

3. CATEGORIES OF COOKIES WE USE

a. Strictly Necessary Cookies. These cookies are required for the Website to function and cannot be disabled. They are typically set in response to actions you take that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block these cookies, but know that parts of the Website may not function as intended. No consent is required for these cookies.

b. Functional Cookies. These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings across visits. They may be set by us or by third-party providers whose services we have integrated into our Website. If you do not allow these cookies, some features may not function as expected.

c. Analytics and Performance Cookies. These cookies are set by our Analytics Providers and allow us to count visits and understand how visitors interact with our Website - including which pages are most frequently visited, how users navigate the site, and whether errors occur. The information collected is aggregated and does not directly identify individual users. We use this information to improve Website performance and user experience.

d. Marketing and Targeting Cookies. These cookies may be set through our Website by our Marketing Automation Providers and Advertising Partners. They track your browsing habits and activity to build a profile of your interests and to serve relevant content and advertisements on and off our Website. They do not store directly personal information but work by uniquely identifying your browser and device. If you do not permit these cookies, you may experience less targeted advertising. These cookies are only activated upon your consent where required by applicable law.

4. THIRD-PARTY TOOLS AND INTEGRATIONS

Our Website is hosted and managed using HubSpot, a third-party platform that provides CRM, marketing automation, and website infrastructure services. HubSpot acts as a data processor on our behalf when it processes personal data in connection with your interactions on our Website. We have a Data Processing Agreement ("DPA") in place with HubSpot governing such processing. In addition, certain other third-party plugins, integrations, and tools may be embedded in or connected to our Website from time to time. These providers may independently set cookies on your device when you visit our Website. While we take steps to ensure that third-party tools only set non-essential cookies with your consent (where required), we do not have direct control over the cookies set by these third parties. You are encouraged to review the privacy and cookie policies of those providers directly. Categories of third-party service providers that may set cookies through our Website include:
- CRM and Marketing Automation Providers (e.g., HubSpot)\n- Analytics Providers\n- Email Delivery Providers\n- Consent Management Providers (e.g., iubenda)\n- Advertising and Remarketing Providers\n- Embedded Content Providers[KT1]

5. CONSENT AND COOKIE MANAGEMENT

When you first visit our Website, you will be presented with a cookie consent banner that allows you to accept or manage your cookie preferences. Strictly necessary cookies will be active by default. All other categories of cookies will only be activated upon your affirmative consent where required by law (including, without limitation, for visitors from the European Union, the United Kingdom, and California). We use a consent management platform to capture and store records of consent. You may withdraw or adjust your consent at any time by accessing the cookie preference settings available on our Website. Please note that withdrawing consent for certain cookies may affect your experience on our Website.
In addition to our on-site consent tools, you may manage or disable cookies through your browser settings. Most browsers allow you to block or delete cookies. Instructions for managing cookies in commonly used browsers are available through your browser's help resources. Please note that blocking certain cookies may impair the functionality of our Website.

6. INFORMATION FOR VISITORS IN THE EUROPEAN UNION AND UNITED KINGDOM

If you are located in the European Union or the United Kingdom, our use of non-essential cookies is subject to your prior consent in accordance with the General Data Protection Regulation ("GDPR") and the UK GDPR. The legal basis for processing personal data via strictly necessary cookies is our legitimate interest in providing a functioning website. For all other cookie categories, the legal basis is your consent. You have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. For the purposes of GDPR, CLD is the data controller for data collected through this Website. Where data is transferred to third parties located outside the European Economic Area ("EEA") or the United Kingdom, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission or applicable UK authorities.

7. INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you may have certain rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA/CPRA"), with respect to personal information collected through cookies and tracking technologies. We do not sell your personal information as that term is defined under the CCPA/CPRA. To the extent our use of certain analytics or advertising cookies may constitute "sharing" of personal information for cross-context behavioral advertising purposes under applicable California law, you may opt out by adjusting your cookie preferences via our consent management tool or by submitting a request to us using the contact information below. For broader rights under California law (including access, deletion, and correction), please refer to our Privacy Policy.

8. DATA RETENTION

Cookies remain on your device for varying durations depending on their type. Session cookies are deleted when you close your browser. Persistent cookies remain on your device until they expire or are deleted. The specific duration of each cookie depends on its function and the third-party provider that sets it. We retain data collected through cookies for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law or by our contractual obligations.

9. UPDATES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to reflect changes in our practices, the tools we use, or applicable legal requirements. Because our technology stack and third-party integrations may evolve as our business grows, we reserve the right to modify this Policy at any time. When we make material changes, we will update the effective date at the top of this Policy. We encourage you to review this Policy periodically. Continued use of our Website following any update constitutes your acknowledgment of the revised Policy.

10. CONTACT US

If you have any questions about this Cookie Policy, wish to exercise your rights under applicable law, or wish to submit a data subject access or deletion request, please contact us at:

Custom Learning Designs, LLC.

cldinc.com
Email: info@cldinc.com

For all data subject access requests, we will follow the appropriate guidelines established in our Data Processing Agreement with HubSpot. Please contact our Data Protection Officer at [INSERT DPO EMAIL ADDRESS].