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Privacy Policy

Custom Learning Designs, Inc.

Effective Date: 6/5/2026
Last Updated: 6/5/2026

1. INTRODUCTION AND SCOPE

Custom Learning Designs, LLC. ("CLD," "we," "us," or "our") is committed to protecting the privacy and security of personal information entrusted to us. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit our website at CLDinc.com (the "Website"), submit inquiries or forms, or otherwise interact with us in a business capacity.

This Policy applies to all individuals who interact with CLD through the Website, including visitors, prospective clients, existing clients, and other business contacts. It governs personal information collected online through the Website and through related communications.

CLD is the data controller responsible for your personal information. Our Website is hosted and operated using HubSpot, which acts as a data processor on our behalf in accordance with a Data Processing Agreement we hold with Hubspot and which applies to all visitors to the Website. CLD controls and is responsible for the information processed using that platform and for complying with applicable privacy and data protection laws in connection with that processing. 

As part of our commitment to proactive data compliance, we maintain internal records of the personal information we process, including how it is used, by whom, and how it is stored. These records inform our ongoing compliance practices and are made available to supervisory authorities upon request where required by applicable law.

2. WHAT WE COLLECT

We collect personal information in the following categories:

A. Information You Provide to Us 

We collect information you voluntarily provide when you interact with us, including:

  • Contact information such as name, email address, phone number, job title, and company name, submitted through inquiry forms, job applications, contact forms, or event registrations;
  • Communications you send to us, including emails and support requests; and
  • Any other information you choose to provide when engaging with CLD.

B. Information Collected Automatically

When you visit our Website, we and our service providers automatically collect certain technical and behavioral information, including:

  • Technical data: IP address, browser type and version, operating system, and device type;

  • Usage data: pages visited, time spent on pages, links clicked, and referring URLs;

  • Behavioral data: form submissions, downloads, and interaction patterns; and

  • Cookie and tracking technology data, as further described in our Cookie Policy [LINK]. 

C. Information from Third Parties

We may receive limited information about you from third-party sources, such as data enrichment providers, in order to maintain accurate business records. We use this information only in accordance with this Policy and do not use it for purposes unrelated to our legitimate business activities.

3. HOW WE USE YOUR INFORMATION

We use personal information only for the following purposes:

  • To respond to your inquiries and communicate with you about CLD's services;

  • To deliver, manage, and improve our services and Website;

  • To send marketing and promotional communications, subject to your right to opt out at any time via the unsubscribe option included in all marketing emails;

  • To analyze Website traffic and usage patterns to improve user experience;

  • To maintain and develop our client and prospective client relationships;

  • To process and evaluate job applications submitted to us, including for the purposes of recruitment, candidate assessment, and employment decision-making;

  • To comply with applicable legal obligations and enforce our rights; and

  • To protect the security and integrity of our Website and systems.

We do not sell your personal information to third parties.

4. LEGAL BASIS FOR PROCESSING (EU/UK VISITORS)

If you are located in the European Economic Area ("EEA") or the United Kingdom ("UK"), we process your personal information on the following legal bases:

  • Legitimate Interests: For B2B contact management, Website analytics, and improving our services, where our legitimate business interests are not overridden by your fundamental rights and freedoms;

  • Consent: For marketing communications and the placement of non-essential cookies and tracking technologies;

  • Contract Performance: Where processing is necessary to perform, or to take steps prior to entering into, a contract with you; and

  • Legal Obligation: Where processing is required to comply with applicable law.

Where we rely on legitimate interests as our legal basis, you have the right to object to that processing. See Section 8 (Your Rights) for more information.

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on our Website. These may include strictly necessary cookies, functional cookies, analytics cookies, and marketing cookies.

Our Website uses HubSpot's native cookie and consent management features. We also work with third-party service providers and integrated tools that may use cookies and tracking technologies when you interact with our Website. Some of these technologies are operated by third parties outside our direct control; however, such third-party tools will only insert non-essential cookies where you have provided your consent, which is tracked and recorded once you accept via our consent mechanism. We do not over-represent our ability to control all downstream third-party behavior, but we commit to ensuring consent is a prerequisite for any non-essential tracking.

For full details on the types of cookies we use, the tools that set them, how to manage your preferences, and our consent mechanism, please refer to ourCookie Policy, available here.

6. HOW WE SHARE YOUR INFORMATION

We share personal information only in the following limited circumstances:

A. Service Providers and Data Processors

We disclose personal information to third-party service providers who perform services on our behalf. These providers are permitted to use personal information only as instructed by us and are subject to appropriate data protection obligations, including Data Processing Agreements where required. Categories of service providers include:

  • CRM and Marketing Automation Providers (e.g., HubSpot);

  • Consent and Privacy Compliance Management Providers (e.g., iubenda);

  • Analytics Providers;
  • Email Delivery Providers;

  • Website Hosting and Infrastructure Providers; and

  • Data Enrichment Providers.

Any third-party plugins or tools that integrate with HubSpot and are used in connection with the Website are subject to the same framework and are required to process personal information only in accordance with our instructions.

B. Legal Requirements

We may disclose personal information if required to do so by law, regulation, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to protect our rights, protect the safety of any person, or investigate fraud or a security threat.

C. Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a portion of our assets, personal information may be transferred as part of that transaction. We will provide notice if personal information becomes subject to a materially different privacy policy as a result.

We do not sell, rent, or trade personal information to third parties for their own marketing or commercial purposes.

7. INTERNATIONAL DATA TRANSFERS

CLD is headquartered in the United States, and your personal information is primarily stored and processed in the United States. If you are located in the EEA or UK, your personal information may be transferred to and processed in a country that does not provide the same level of data protection as your home jurisdiction.

Where we transfer personal information from the EEA or UK to the United States or other third countries, we implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or, for UK transfers, the International Data Transfer Agreement approved by the UK Information Commissioner's Office, as applicable.

Our data processors, including HubSpot, may also process data in jurisdictions outside the EEA and UK. We take steps to ensure that such transfers are subject to appropriate protections under applicable data transfer mechanisms.

8. YOUR RIGHTS 

A. Rights for EEA/UK Individuals (GDPR) 

If you are located in the EEA or UK, you have the following rights with respect to your personal information: 

  • Right of access to your personal information; on;

  • Right to erasure ("right to be forgotten") in certain circumstances;

  • Right to restriction of processing;

  • Right to data portability;

  • Right to object to processing based on legitimate interests

  • Right to rectification of inaccurate or incomplete informati or for direct marketing purposes;

  • Right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal; and

  • Right to lodge a complaint with your local data protection supervisory authority. 

B. Rights for California Residents (CCPA/CPRA) 

If you are a California resident, you may have the following rights under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"), subject to applicable thresholds and exemptions: 

  • Right to know what personal information we collect, use, disclose, or otherwise process;

  • Right to delete personal information we hold about you, subject to certain exceptions;

  • Right to correct inaccurate personal information;

  • Right to opt out of the sale or sharing of personal information (we do not sell personal information); and

  • Right to non-discrimination for exercising your privacy rights. 

C. General Rights 

All individuals who interact with us may contact us to: 

  • Update or correct their personal information;

  • Unsubscribe from marketing communications at any time using the unsubscribe option included in all marketing emails; or

  • Request information about our data practices. 

To exercise any of the rights described in this Section, please contact us using the information set out in Section 13. We will respond to verifiable requests in accordance with applicable law and within any legally prescribed timeframes. 

9. DATA RETENTION

We retain personal information for as long as is necessary to fulfill the purposes for which it was collected, to maintain our business relationship with you, and to comply with our legal, regulatory, and contractual obligations. When personal information is no longer needed for these purposes, we take reasonable steps to securely delete or anonymize it.

You may request deletion of your personal information at any time by contacting us using the information set out in Section 13 (Contact and Data Controller Information) of this Policy. We will process deletion requests in accordance with our legal obligations and the capabilities of our data management systems, including through the data deletion tools available in HubSpot.

10. SECURITY

We implement reasonable and appropriate technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. Access to personal information is limited to personnel and service providers who require it to perform their functions.

While we are committed to maintaining the security of your information, no security system is impenetrable and we cannot guarantee the absolute security of information transmitted over the internet or stored in our systems.

11. CHILDREN

Our Website and services are not directed to children under the age of 16 (or 18 where required by applicable law), and we do not knowingly collect personal information from children. If we become aware that personal information has been inadvertently collected from a child below the applicable age threshold, we will take prompt steps to delete such information from our records.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational or business reasons. When we make updates, we will revise the "Last Updated" date at the top of this Policy. We encourage you to review this Policy periodically to stay informed about how we handle your personal information.

Material changes will be communicated by a prominent notice on our Website or, where appropriate, by direct notification.

13. CONTACT AND DATA CONTROLLER INFORMATION

Custom Learning Designs, Inc. is the data controller responsible for your personal information under this Policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Custom Learning Designs, LLC
375 Concord Ave
Belmont, MA 02478
United States

Email:info@cldinc.com
Website: www.cldinc.com

For EEA/UK individuals, if you believe we have not adequately addressed your concern, you have the right to lodge a complaint with your local data protection supervisory authority. For EU residents, a list of national supervisory authorities is available at https://edpb.europa.eu. For UK residents, the relevant authority is the Information Commissioner's Office (ICO) at https://ico.org.uk.