Privacy policy

Effective Date: October 1, 2026 (Version 1.0)

This Privacy Policy explains how Ciraltos LLC, doing business as My Cloud Coach ("My Cloud Coach," "we," "us," or "our"), collects, uses, shares, and protects personal information when you visit our website at https://mycloud.coach, create an Account, purchase or take a Course, join a Live Session, or receive email from us (together, the "Service").

This Privacy Policy is part of our Terms and Conditions. Capitalized terms that are not defined here, such as Account, Course, Live Course, and Live Session, have the meanings given in the Terms and Conditions. If you do not agree with this Privacy Policy, please do not use the Service.

Ciraltos LLC, doing business as My Cloud Coach, is the controller of the personal information described in this Privacy Policy. This means we decide how and why your personal information is used. You can contact us at any time at mcc@ciraltos.com or at the mailing address in the Contact Us section below.

Our school runs on the LearnWorlds platform, operated by LearnWorlds (CY) Ltd. LearnWorlds acts as our data processor, which means it processes learner information only on our behalf and under our instructions. Please send any privacy questions or requests about your information on the Service to us rather than to LearnWorlds.

Information you provide to us:

• Account information: your name, email address, password, and any optional profile details you choose to add, such as a job title, company, or profile photo, along with your privacy, cookie, and email notification preferences.
• Purchase information: the Courses you buy, the price paid, and billing details such as your billing name, country, and postal code. Payment card details are encrypted in transit and sent directly to our payment processor, Stripe. We do not receive or store your full card number, and Stripe's own privacy policy applies to the payment information you provide to it.
• Learning activity: Course enrollments, lesson progress, completion percentage, quiz and assessment results, and certificates of completion.
• Content you post: comments, discussion posts, questions, reviews, and other User Content you submit to the Service.
• Live Session participation: your name or display name, voice, video image (if your camera is on), and any questions, comments, or chat messages you share during a Live Session, which are captured in session recordings, along with any automatically generated transcripts or captions of the session.
• Communications: messages you send us, including support requests, refund requests, seat transfer requests, and arbitration opt-out notices, along with our replies.
• Marketing preferences: whether you have subscribed to or unsubscribed from our marketing emails.

Information collected automatically: when you use the Service, we and our service providers automatically collect certain technical information, including your IP address, browser type and version, device and operating system type, general location derived from your IP address, pages viewed, links clicked, referring website, and the dates and times of your visits. We collect this information using cookies and similar technologies, as described in Section 7.

Information from third parties: if you choose to sign up or sign in with a Google or LinkedIn account, we receive basic profile information from that service, such as your name, email address, and profile photo, as permitted by your settings with that service. We also receive limited information from our service providers, such as confirmation of payment and fraud screening results from Stripe, and email engagement information (such as whether an email was opened or a link was clicked) from MailerLite.

Please do not share sensitive personal information with us, such as government identification numbers, health information, or financial account details, and do not share confidential information belonging to your employer or clients in discussions or Live Sessions.

We use personal information for the following purposes:

• To create and manage your Account and provide the Courses and Live Sessions you purchase.
• To process payments, refunds, and chargebacks, and to prevent fraud and refund abuse.
• To track your progress, issue certificates of completion, and provide support.
• To send transactional messages, such as order confirmations, Live Session schedule changes, Course retirement notices, and updates to our Terms and Conditions or this Privacy Policy.
• To send marketing emails about new Courses and offers, where you have agreed to receive them or where otherwise permitted by law.
• To understand how the Service is used and to improve our Courses, website, and learner experience.
• To protect the security and integrity of the Service, enforce our Terms and Conditions, and protect our Course Content from unauthorized sharing.
• To comply with legal, tax, and accounting obligations, and to establish, exercise, or defend legal claims.

Legal bases (EEA and UK learners). If you are located in the European Economic Area or the United Kingdom, we rely on the following legal bases: performance of our contract with you (to provide your Account, Courses, and Live Sessions); our legitimate interests (to secure and improve the Service, prevent fraud and abuse, and protect our content), balanced against your rights; your consent (for marketing emails and non-essential cookies, which you may withdraw at any time); and compliance with legal obligations (such as tax and accounting records).

We do not sell your personal information, and we do not use it for targeted advertising based on your activity across other companies' websites. We do not use automated decision-making or profiling that produces legal or similarly significant effects about you.

All Live Sessions are recorded, as described in our Terms and Conditions. Recordings may include your name or display name, voice, video image (if your camera is on), and any questions, comments, or chat messages you share during the session.

Recordings are made available to learners enrolled in that Live Course and to learners who purchase that Course or its recordings in the future. We will not use recordings that include your voice, image, or name in advertising or marketing without your separate permission.

To limit what is captured, you may keep your camera off, use a display name other than your full name, and ask questions through chat. Recordings are retained for as long as the related Course is offered, subject to Section 8.

We share personal information only as described below:

• Service providers. We use trusted third parties to operate the Service. They may process personal information only on our behalf and as needed to provide their services. These include: LearnWorlds (our learning platform, which hosts the website, Accounts, Courses, and learner progress on Google Cloud servers located in Europe and the United States); Stripe (payment processing and fraud prevention); MailerLite (email delivery and marketing email management); Google (Google Analytics for website analytics, Google reCAPTCHA to protect sign-up and login forms from spam and abuse, and Google sign-in if you choose to use it); LinkedIn (sign-in if you choose to use it); Microsoft (Microsoft Teams for Live Sessions and our business email); and our professional advisors, such as accountants and attorneys.
• Other learners. Content you post in discussions or community areas, your display name and profile photo, and your participation in Live Session recordings may be visible to other learners.
• Employers and organizations. If your employer or another organization purchased your Course, transferred a seat to you, or arranged your access, we may share your enrollment status, progress, and completion information with that organization.
• Affiliate partners. If you purchase a Course after following an affiliate partner's link, we share limited information about that purchase, such as the Course purchased and the purchase amount, with the partner so we can pay their commission.
• Certificate verification. If you choose to share a certificate of completion, the certificate details, including your name, the Course name, and the completion date, may be visible to anyone with the certificate link.
• Legal and safety reasons. We may disclose information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, investigate fraud or violations of our Terms and Conditions, or protect the safety of any person.
• Business transfers. If our business, or the part of it that operates the Service, is sold, merged, or transferred, personal information may be transferred to the new owner, who will be required to honor this Privacy Policy. We will notify you by email before your information becomes subject to a different privacy policy.
• With your permission. We may share information for other purposes with your consent.

We send transactional emails that are necessary to provide the Service, such as receipts, Account notices, Live Session updates, and Course retirement or shutdown notices. You cannot opt out of these while you have an Account.

You can choose whether to receive marketing emails when you sign up or through an email signup form on our website. If you subscribe, we will send you information about new Courses, updates, and offers using MailerLite. You can unsubscribe at any time using the link in any marketing email, by updating your email preferences in your Account settings (Notifications & Privacy), or by contacting us. You can also turn off optional email notifications about your activity in the school, such as community mentions and messages, in the same settings. MailerLite may record whether you open our emails or click links in them so we can understand what content is useful.

Cookies are small text files stored on your device. We and our service providers use the following categories of cookies and similar technologies, which are described in more detail in our Cookie Policy:

• Necessary cookies that keep you signed in, process purchases, remember your cookie choices, and keep the Service secure. These are always active because the Service cannot function without them.
• Functional cookies that remember your preferences and settings to improve your experience.
• Analytics cookies, including Google Analytics, that help us understand how visitors use our website, such as which pages are viewed and how visitors arrive at the site. Google processes this information under its own privacy policy, and you can also opt out using the Google Analytics Opt-out Browser Add-on.
• Marketing cookies, limited to a first-party affiliate referral cookie that records when you arrive through an affiliate partner's link so the partner can be credited for a resulting purchase. We do not use advertising or cross-site tracking cookies. If we begin using them, we will update this Privacy Policy and our Cookie Policy and ask for your consent where required.

When you first visit the Service, a cookie banner lets you accept all cookies, reject all non-essential cookies, or choose individual categories. Non-essential cookies are not placed until you give consent where the law requires it. You can change your choices at any time from your Account settings (Notifications & Privacy) or, if you are not signed in, through the cookie preferences option on our website. You can also block or delete cookies through your browser settings, although some features may not work without necessary cookies.

Some browsers offer "Do Not Track" signals. Because there is no common standard for these signals, the Service does not currently respond to them. We do honor Global Privacy Control signals where required by applicable law.

We keep personal information only for as long as needed for the purposes described in this Privacy Policy, including:

• Account and learning data: for as long as your Account is active. If you close your Account or ask us to delete your information, we delete or anonymize it within a reasonable period, except as described below. When an Account is anonymized, your name and contact details are replaced with an anonymous identifier, and any community posts or messages you made are anonymized.
• Purchase, refund, and tax records: for as long as required by applicable tax and accounting laws, generally up to 7 years, or up to 10 years where required by non-U.S. tax laws.
• Live Session recordings: for as long as the related Course is offered, including any retirement or wind-down period described in our Terms and Conditions.
• Marketing email data: until you unsubscribe, after which we keep only the minimum information needed to honor your request.
• Support and legal communications: for as long as needed to resolve the matter and to establish, exercise, or defend legal claims, including records of arbitration opt-out notices.
• Analytics data: according to the retention settings in Google Analytics, which we set to no longer than 14 months.

If the Service is permanently shut down, we will delete or anonymize personal information that we are not required to keep for legal, tax, or accounting purposes within a reasonable period after the end of the Wind-Down Period described in our Terms and Conditions.

We use reasonable administrative, technical, and organizational measures to protect personal information, including relying on established service providers with strong security practices, encrypted connections (HTTPS), and restricted access to learner data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

You are responsible for keeping your password confidential. If we learn of a security incident that affects your personal information, we will notify you and any relevant authorities as required by applicable law.

My Cloud Coach is based in the United States, and our service providers may process personal information in the United States, the European Union, and other countries. These countries may have data protection laws that are different from the laws where you live.

When we or our service providers transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to other countries, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or a provider's certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, where applicable.

Wherever you live, you may contact us to make the following requests about your personal information:

• Access: ask for a copy of the personal information we hold about you.
• Correction: ask us to correct inaccurate or incomplete information. You can also update most Account details yourself.
• Deletion: ask us to delete your personal information, subject to information we must keep for legal, tax, or accounting purposes.
• Portability: ask for a copy of your information in a commonly used, machine-readable format.
• Marketing opt-out: unsubscribe from marketing emails at any time.

Additional rights for EEA and UK learners. You also have the right to object to processing based on our legitimate interests, to ask us to restrict processing, and to withdraw consent at any time without affecting processing that took place before you withdrew it. You have the right to lodge a complaint with the data protection authority in the country where you live or work, although we would appreciate the chance to address your concern first.

Additional rights for U.S. state residents. Depending on the state where you live, you may have additional rights under state privacy laws, including the right to appeal a decision we make about your request. To appeal, reply to our decision with the subject line "Privacy Appeal." We will not discriminate against you for exercising any privacy right.

How to make a request. You can request a copy of your data or ask us to delete your Account from your Account settings (Notifications & Privacy, then Advanced Privacy Settings), using the "Personal data access request" or "Delete my account and forget me" options. You can also email mcc@ciraltos.com with the subject line "Privacy Request" and describe what you are asking for. To protect your information, we will verify your identity, usually by confirming the request comes from the email address on your Account. You may use an authorized agent where permitted by law. We will respond within one month of receiving your request, which may be extended where permitted by applicable law if a request is complex. We will tell you if we need more time. Deleting your personal information may require closing your Account, which ends your access to purchased Courses.

The Service is intended only for people who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us with personal information, please contact us and we will delete it and close the related Account.

The Service may link to third-party websites and services, such as Microsoft Learn documentation, certification exam providers, and Microsoft Teams. Those services are governed by their own privacy policies, and we are not responsible for their privacy practices. We encourage you to review their policies before providing them with personal information.

We may update this Privacy Policy from time to time. When we make material changes, we will update the Effective Date above and notify you by email or through the Service at least 30 days before the changes take effect, unless a change is required sooner by law. Your continued use of the Service after the changes take effect means you accept the updated Privacy Policy.

If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact us:

Ciraltos LLC, doing business as My Cloud Coach
5123 W 98th St #1392
Minneapolis, MN 55437
United States
Email: mcc@ciraltos.com
Website: https://mycloud.coach