TRAILBLAZER CONSULTING, LLC, AND TRAILBLAZER LEARNING ACADEMY, INC.

Effective date: 9/3/2026. Last updated: 9/3/2026.

Policy Overview

This Privacy Policy is issued jointly by TrailBlazer Consulting, LLC, a Delaware limited liability company (“TrailBlazer Consulting”), and TrailBlazer Learning Academy, Inc., a Delaware corporation (“TrailBlazer Learning Academy” or the “Academy”), together with their affiliates (collectively, “TrailBlazer,” “we,” “us,” or “our”). TrailBlazer Consulting operates the TrailBlazer Consulting website (trailblazer.us.com). TrailBlazer Learning Academy operates the TrailBlazer Learning Academy platform (trailblazerlearningacademy.com), including its Courses, Materials, Coaching, Community, and Assessment Tools such as the TrailBlazer Governance Accelerator™. The two entities are separately organized; TrailBlazer Consulting owns the intellectual property made available through the Academy platform and licenses it to the Academy. Personal data collected through either site may be shared between the two entities as described in this Policy, and each entity is responsible for the personal data it collects through the site it operates.

TrailBlazer understands and appreciates the responsibility to secure and protect the personal data of its clients, customers, business partners, vendors, and users of its websites and platform. This Policy sets out our practices for the collection, use, maintenance, storage, disclosure, protection, and disposition of personally identifiable information (PII[1]), payment card industry (PCI[2]) information, and business and assessment data acquired through our online resources (collectively, the “Services”).

This Policy operates in conjunction with the TrailBlazer Consulting Website Terms of Use, the TrailBlazer Learning Academy Terms of Use, and the TrailBlazer Cookies Policy. Where the TrailBlazer Learning Academy Terms of Use address Assessment Inputs, Assessment Results, or Client Profile information (each as defined there), Article 26 of those Terms controls as to that data.

TrailBlazer leverages commercial platforms[3] including Go Daddy™, Kajabi®, Stripe™, WordPress™, Lovable, and Supabase to host parts of the websites, platform, Courses, Services, Materials, Downloads, Coaching, Assessment Tools, and payment processing. Backup and security of content are provided by these commercial platforms in accordance with their standard terms, data processing agreements, and privacy policies, and subject to internet and web-based commerce standards.

The remainder of this Policy describes:

  • Personal data collection: how we collect personal information and the types of personal information we collect;
  • Business and assessment data;
  • Personal data use, sharing, and transmission: how we use your personal information, sharing your personal information, and storage and security of your personal information;
  • Links to other websites;
  • Administration of this Policy: your rights and choices, and relevant laws and regulations; and
  • Changes to this Policy.

Personal Data Collection

How we collect personal information

TrailBlazer collects personal information from you when you:

  • Submit or choose to provide information to us; for example, by completing or participating in a Contact Form; Coaching Registration or Pre-Qualification Form; Course Purchase or Registration Form; Assessment Tool registration; or a Survey or other optional data collection instrument;
  • Visit or use our online services; participate in a Course; use online handouts or data collection forms where you can store, analyze, or export your data; download handouts or other resources; use an Assessment Tool; or participate in Community activities such as chat; or
  • Participate in TrailBlazer programs or events, including Coaching, Webinars, Surveys, and the Community.

We may also collect information about you from other sources, including third-party service providers or business partners; industry groups; public sources, including social media and other websites that enable social sharing; and government agencies, public databases, and other third-party information sources. We may combine information we collect from a third party with information we already have, and we may combine information collected offline with information collected online.

In circumstances where the information that TrailBlazer obtains is held by a third party, TrailBlazer will take reasonable efforts to acquire the business partner’s, vendor’s, or customer’s consent before it seeks this information from such sources (such permission may be provided directly by the entity or reasonably implied from the entity’s actions).

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

Types of personal information we collect

Information you submit:

  • Personal Identifying Information (PII), including your name, business email address, business address, phone number, job title, and other contact details;
  • Payment Card Industry (PCI) information, including credit card or other payment information provided to complete a purchase. Payment information is collected and processed by our payment processor, Stripe™, and TrailBlazer does not store full payment card numbers on its own systems;
  • The content of correspondence between you and us, including audio or video recordings of Coaching sessions; and
  • Survey or other information provided by you (for example, in a form).

Online usage information for our Services, collected to facilitate access to and use of the websites or platform and to optimize your experience with them:

  • Website, application, and communication usage, including details of your visits to our websites and information collected through cookies and other tracking technologies;
  • IP address and domain name, browser version and operating system, traffic data, location data, device data, web logs, other communication data, and the resources that you access; and
  • Anti-fraud information used to verify your identity, including information that may be available in public databases.

Business and Assessment Data

When you use an Assessment Tool, you enter information about your organization rather than about yourself: for example, organization name, industry, jurisdictions in which you operate, regulated status, systems in use, business function priorities, and answers describing your governance, records, contract, or data practices (“Assessment Inputs”). The Assessment Tool generates scores, findings, playbooks, and recommendations from those inputs (“Assessment Results”), and organization-level information is stored once as a “Client Profile” shared across versions of the Assessment Tools.

Assessment Inputs, Assessment Results, and Client Profile information are confidential business information of your organization. TrailBlazer uses them only to generate and deliver Assessment Results; to operate, secure, support, and maintain the Assessment Tools; to provide any complimentary practitioner review you request; and, in aggregated and de-identified form that does not identify you or your organization, to analyze, benchmark, improve, and develop the Assessment Tools and related methodology. TrailBlazer does not sell Assessment Inputs, Assessment Results, or Client Profile information, does not disclose them to third parties in identifiable form except as stated in Article 26 of the TrailBlazer Learning Academy Terms of Use and in the “Sharing your personal information” section below, and does not use them to market to any third party.

Assessment Inputs, Assessment Results, and Client Profile information are retained for the life of your account, regardless of inactivity, so that you may return to prior results and complete additional versions of the Assessment Tools without re-entering organization-level information. You may request deletion at any time as described under “Your rights and choices.”

Where your organization is subject to data protection law that treats TrailBlazer as a processor of personal data contained in Assessment Inputs, TrailBlazer will enter into a data processing agreement on request. Contact us at the addresses at the end of this Policy.

Personal Data Use, Sharing, and Transmission

How we use your personal information

We use personal information for the purposes set out below:

  • To conduct our business and provide our goods and services, including administration, management, and fulfilment of our contracts;
  • To communicate with you, including to respond to your queries and to otherwise communicate with you;
  • To investigate and prevent fraud as may be required by applicable law and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them;
  • To monitor certain activities, including queries and transactions; ensure service quality; comply with procedures; and combat fraud;
  • To notify you about changes to our goods and services;
  • To improve and develop our Services, Courses, Materials, and Assessment Tools, including through analysis of usage data and of aggregated and de-identified Assessment Inputs. TrailBlazer does not use personal information or identifiable Assessment Inputs to train any artificial intelligence or machine-learning model;
  • To reorganize or make changes to our business. In the event that we (i) are subject to negotiations for the sale of our business or part thereof, including the Academy or the Assessment Tools, to a third party; (ii) are sold to a third party; or (iii) undergo a reorganization, we may need to transfer some or all of your personal data and business and assessment data to the relevant third party (or its advisers) as part of any due diligence process for the purpose of analyzing any proposed sale or reorganization, subject to obligations of confidentiality. We may also need to transfer your personal data and business and assessment data to that reorganized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this Policy; and
  • To comply with legal or regulatory obligations to disclose your personal data to third parties, the courts, regulators, or law enforcement agencies in connection with enquiries, proceedings, or investigations by such parties anywhere in the world, or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding, unless to do so would prejudice the prevention or detection of a crime.

Sharing your personal information

TrailBlazer may share your information between TrailBlazer Consulting, LLC and TrailBlazer Learning Academy, Inc., and with their affiliates, for the purposes described in this Policy.

TrailBlazer shares personal information with the service providers that host and support our Services, listed above, under their data processing agreements and privacy policies. These providers process personal information on our behalf and are not permitted to use it for their own purposes.

We may also transfer or assign your personal data and business and assessment data to third parties as a result of or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation, as described above.

TrailBlazer may disclose aggregate or de-identified data that is not personally identifiable and does not identify any organization to third parties for any lawful purpose, except that aggregated or de-identified Assessment Inputs are used only as stated under “Business and Assessment Data.”

TrailBlazer does not sell personal information and has not sold personal information in the preceding twelve (12) months. TrailBlazer does not share personal information with third parties for their own direct marketing purposes.

Storage and security of your personal information

Storage limits. Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing and other purposes for which the information was collected, and any other permissible, related purpose, as described in this Policy. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. Assessment Inputs, Assessment Results, and Client Profile information are retained as stated under “Business and Assessment Data.” When personal data is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.

Security. TrailBlazer maintains physical, electronic, and procedural safeguards to protect your personal data in accordance with data protection legislative requirements and technical applicability. However, all such measures are subject to external factors related to the internet and cloud computing, so we cannot guarantee that your personal data will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such data. Users are responsible for maintaining the secrecy of their own passwords.

International data transfers. TrailBlazer is headquartered in the United States, and information you provide is stored and processed in the United States by TrailBlazer and its service providers. The United States may not provide the same level of protection for personal data as the country in which you reside. If you are located in the European Economic Area, the United Kingdom, Switzerland, or Canada, we transfer your personal data to the United States in reliance on the transfer mechanisms made available by our service providers (including standard contractual clauses and, where applicable, the EU-U.S. Data Privacy Framework and its UK and Swiss extensions) and on your consent where you provide it, and we will handle your personal data in accordance with this Policy regardless of where it is stored or accessed. Corporate clients that require a data processing agreement or transfer addendum may request one as described above.

Links to Other Websites

Our online services may contain links or references to third-party websites. These websites are outside of our control, and the privacy policies of these sites may differ from our own. Our Privacy Policy does not apply to such websites. We encourage you to check the terms of use and privacy policies of such websites before disclosing any personal data via such websites.

This Policy applies only to the TrailBlazer websites and platform. They may contain links to other websites not operated or controlled by TrailBlazer[4] (collectively, “Third-Party Sites”), including, but not limited to, Facebook, X (formerly Twitter), Instagram, YouTube, LinkedIn, and TikTok. The policies and procedures we describe here do not apply to Third-Party Sites. Links from our sites do not imply that TrailBlazer endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Administration of the Privacy Policy

Children

Our Services are intended for business users and are not directed to anyone under eighteen (18) years of age. We do not knowingly collect personal data from anyone under eighteen (18). If you believe we have collected such data, contact us and we will delete it.

Your rights and choices

You may have certain rights available when it comes to your personal data collected or processed under this Policy. Depending on your jurisdiction, applicable law may entitle you, with certain limitations and exceptions, to:

  • Know the categories and specific pieces of personal information collected about you, the purposes for which it is used, and the categories of third parties with whom it is shared;
  • Access a copy of the personal information we retain about you;
  • Correct inaccurate personal information;
  • Request deletion of your personal information, including Assessment Inputs, Assessment Results, and Client Profile information associated with your account;
  • Object to or restrict certain processing, or withdraw consent where processing is based on consent; and
  • Lodge a complaint with a supervisory authority in your jurisdiction.

To exercise any of these rights, contact us at the addresses at the end of this Policy. We will respond within the time required by applicable law.

We reserve the right to verify your identity in connection with any request regarding personal information. Verification helps ensure that we provide the information we maintain only to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our goods or services because of choices and requests you make in connection with your personal data. Please note that certain choices may affect our ability to deliver services; for example, deletion of a Client Profile will remove the ability to return to prior Assessment Results.

Relevant laws and regulations

TrailBlazer administers this Policy in accordance with applicable United States federal, state, and local privacy laws, and honors the rights of individuals located in Canada, the United Kingdom, the European Economic Area, and Switzerland under the laws listed below to the extent those laws apply to our processing of their personal data:

  • United States state privacy laws, including, without limitation, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”): cppa.ca.gov
  • Canadian Personal Information Protection and Electronic Documents Act (PIPEDA): priv.gc.ca
  • United Kingdom General Data Protection Regulation and Data Protection Act 2018: ico.org.uk and gov.uk/data-protection
  • European Union General Data Protection Regulation (GDPR): gdpr.eu

Contact

If you have any questions in relation to this Policy or wish to exercise your rights, contact info@trailblazer.us.com (TrailBlazer Consulting, LLC) or support@trailblazerlearningacademy.com (TrailBlazer Learning Academy, Inc.).

Changes to Our Privacy Policy

Our Privacy Policy may change from time to time. The current Privacy Policy, with its effective date, can be found at all times on trailblazer.us.com and trailblazerlearningacademy.com. Where a change materially reduces your rights or materially expands our use of Assessment Inputs, we will give registered account holders reasonable notice by email before the change takes effect.

[1] The term “Personally Identifiable Information (PII)” in this Policy refers to any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PII is defined as information: (i) that directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or (ii) by which an entity intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors.) Additionally, information permitting the physical or online contacting of a specific individual is the same as personally identifiable information. This information can be maintained in paper, electronic, or other media. dol.gov/general/ppii

[2] “The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance payment account data security and facilitate the broad adoption of consistent data security measures globally. PCI DSS provides a baseline of technical and operational requirements designed to protect account data. While specifically designed to focus on environments with payment account data, PCI DSS can also be used to protect against threats and secure other elements in the payment ecosystem.” pcisecuritystandards.org

[3] See the Go Daddy™ Trust Center, Kajabi® Terms and Policies, Stripe™ Privacy Policy, WordPress™ Terms of Use and WordPress™ (Automattic) Privacy Policy, Lovable Terms of Service and Privacy Policy, and Supabase Terms of Service, Privacy Policy, and Data Processing Addendum for more information.

[4] As noted above, TrailBlazer leverages the following commercial platforms: Go Daddy™, Kajabi®, Stripe™, WordPress™, Lovable, and Supabase.