Privacy Policy

Thurman Group Global, Inc. ("TGG," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, store, and protect information when you visit our website, download our guides, enroll in the College Edge program, complete our assessments, schedule a consultation, or otherwise interact with our services.

1. Who We Are

Our website address is https://thurmangroupglobal.com. Thurman Group Global, Inc. is the operator of this site and the College Edge program.

2. Information We Collect

Information You Provide Directly

We collect information you submit through our website forms, guide downloads, program enrollment, scheduling tools, coaching sessions, and assessment intake. This may include:

• Name, email address, phone number, and mailing address
• Student or parent role, school affiliation, and grade level
• Student age, postsecondary enrollment status, and parent involvement preference (collected at debrief booking)
• Payment and billing information (processed securely through Stripe, see Section 5)
• Responses submitted through the EQ-i 2.0 emotional intelligence assessment
• Responses submitted through the Maxwell DISC personality indicator
• Notes, goals, and feedback shared during coaching engagements
• Communications you send to us via email, web form, or other channels
• Scheduling details when you book a consultation through our embedded scheduling tools

Information Collected Automatically

When you visit our website, we may collect technical information such as IP address, browser type, device identifiers, pages viewed, referring URLs, and timestamps. This information is collected through cookies and similar technologies for analytics and site functionality.

3. How We Use Your Information

We use the information we collect to:

• Deliver the guides, assessments, coaching, and program services you request
• Generate and interpret EQ-i 2.0 and Maxwell DISC reports for participants
• Process payments and fulfill enrollment in College Edge or related offerings
• Schedule and conduct consultations and coaching sessions
• Determine the appropriate parent involvement structure based on student age and enrollment status
• Communicate with you about your account, services, scheduling, and program updates
• Send educational content, newsletters, and promotional materials (you may opt out at any time)
• Improve our website, content, and program offerings
• Comply with legal obligations and protect our rights

4. Assessment Data (EQ-i 2.0 and Maxwell DISC)

Assessment responses and resulting reports are treated as sensitive personal information and are handled with heightened care:

• Assessments are administered through licensed third-party platforms (Multi-Health Systems for EQ-i 2.0, and the Maxwell Leadership platform for DISC). Responses are stored on those vendors' secure systems in accordance with their privacy practices.
• Individual results are shared only with the student who is the legal owner of the data, and, in the case of minor students not yet enrolled in college, the enrolling parent or legal guardian.
• We do not sell, rent, or disclose individual assessment results to schools, employers, or any third party without explicit written consent from the data owner.
• Aggregated, de-identified assessment data may be used for research, program improvement, and educational publications.

5. Payment Processing

All payments for College Edge and related programs are processed through Stripe, Inc. We do not store full credit card numbers, CVV codes, or bank account details on our servers. Stripe's handling of your payment information is governed by Stripe's privacy policy, available at stripe.com/privacy.

6. Cookies

Our website uses cookies and similar technologies to enable site functionality, remember your preferences, and analyze site traffic. The cookies on our site fall into the following categories:

Comment Cookies

If you leave a comment on our site, you may opt in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies last for one year.

Login and Session Cookies (Site Administrators)

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When site administrators log in, additional cookies are set to save login information and screen display choices. Login cookies last for two days, and screen options cookies last for a year. If "Remember Me" is selected, the login persists for two weeks. Logging out removes the login cookies. If an administrator edits or publishes an article, an additional cookie is saved that contains no personal data and indicates only the post ID. It expires after one day.

Analytics and Functionality Cookies

We use cookies to understand how visitors use our site and to improve the experience. You can control cookies through your browser settings. Disabling cookies may affect the functionality of certain features.

7. Comments

When visitors leave comments on our site, we collect the data shown in the comment form, along with the visitor's IP address and browser user agent string to help with spam detection.

An anonymized string created from your email address (a hash) may be provided to the Gravatar service to determine whether you are using it. The Gravatar service privacy policy is available at automattic.com/privacy. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Visitor comments may be checked through an automated spam detection service.

8. Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

9. Embedded Content (Calendly and Other Third-Party Services)

Pages on our site may include embedded content such as scheduling widgets (Calendly, HubSpot Meetings), videos, social media posts, or other third-party media. Embedded content from other websites behaves as if you visited the other site directly.

These third parties may collect data about you, set their own cookies, embed additional tracking, and monitor your interaction with the embedded content, including tracking your interaction if you have an account and are logged in to that service.

In particular, when you book a debrief session through our embedded HubSpot scheduling tool, HubSpot collects your name, email address, scheduling preferences, and the information you provide in the booking form. HubSpot's handling of this data is governed by HubSpot's privacy policy, available at legal.hubspot.com/privacy-policy.

10. Service Providers and Third Parties

We share information with trusted third-party service providers who help us operate our business. These include:

• HubSpot, for customer relationship management, email communication, form submissions, and meeting scheduling
• Stripe, for payment processing
• Multi-Health Systems (MHS), for EQ-i 2.0 assessment administration
• Maxwell Leadership, for DISC assessment administration
• WordPress and our website hosting, email delivery, and analytics providers

These providers are contractually obligated to protect your information and use it only for the purposes for which we engage them.

If you request a password reset on our site, your IP address will be included in the reset email.

11. Information About Minors and Data Ownership Transfer

Many of our participants are high school and early college students, including minors under 18. The way we handle student information is governed by the student's age and postsecondary enrollment status. We follow a three-rule framework that aligns with the Family Educational Rights and Privacy Act (FERPA) and applicable state laws.

Rule 1: Students Under 18 and Not Yet Enrolled in College

For minor students who are not yet enrolled in any postsecondary institution, parents or legal guardians hold legal authority over the student's program records and assessment results. Parents are included in the debrief by default, complete the enrollment, sign the consent and disclosure form, and receive a separate Parent Briefing as part of the program.

Rule 2: Students 18 and Older, OR Students Enrolled in College

For students who are 18 or older, OR for students of any age who are enrolled in a postsecondary institution, the student is the legal owner of their own program records and assessment results. This applies even if a parent paid for the program. Under FERPA, educational record rights transfer to the student upon the student's 18th birthday OR upon enrollment in a postsecondary institution, whichever occurs first.

For these students, the debrief and all coaching sessions belong to the student. Parents may participate in the student's program activities only with the student's written consent. Parents who wish to remain involved in their student's college transition without accessing the student's specific assessment data may enroll in the Parent Partner Add-On, which provides parental coaching independently.

Rule 3: Consent and Disclosure Form

Every family completes a consent and disclosure step at enrollment that documents the student's age, postsecondary enrollment status, the legal owner of the data, and the student's parent involvement preference. This documentation is captured electronically with timestamp and version control. The student's preference can be changed in writing at any time by contacting us at privacy@thurmangroupglobal.com.

Children Under 13 (COPPA)

We do not knowingly collect personal information from children under 13 without verifiable parental consent in accordance with the Children's Online Privacy Protection Act (COPPA). Our College Edge program is designed for students age 13 and older.

Parents and Guardians

Parents and legal guardians of students who fall under Rule 1 may review, request deletion of, or refuse further collection of their minor child's information by contacting us at the email above. Parents whose students fall under Rule 2 may not access the student's data without the student's written consent, but may always update their own contact information, billing details, and Parent Partner Add-On records.

12. How Long We Retain Your Data

We retain personal information only as long as necessary to provide our services and meet legitimate business and legal needs. Specific retention practices include:

• Guide download contacts: retained in our CRM until you unsubscribe or request deletion
• Program enrollment and coaching records: retained for the duration of the engagement and for up to seven years afterward to meet financial, tax, and audit obligations
• Assessment results (EQ-i 2.0 and Maxwell DISC): retained for the duration of the participant's program engagement and may be retained longer in de-identified, aggregated form for research and program improvement
• Consent and disclosure form records: retained for at least seven years after the program engagement ends, as documentation of the parent involvement preference and data ownership at the time of enrollment
• Payment records: retained as required by tax and accounting law (typically seven years)
• Comments: retained indefinitely so that follow-up comments can be recognized and approved automatically rather than held for moderation
• Registered user profile information: stored for as long as the user account exists. Users can see, edit, or delete their personal information at any time (except their username). Site administrators can also see and edit that information.
• Website analytics: retained in aggregated form for up to 26 months

13. International Data Transfers

TGG is based in the United States. Some of our service providers (including HubSpot, Stripe, MHS, and Maxwell Leadership) may process or store data in the United States or other countries. If you are accessing our site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or in any other country where our service providers maintain facilities. By using our site or services, you consent to such transfers, subject to applicable law.

14. How We Protect Your Information

We use reasonable administrative, technical, and physical safeguards to protect the information we collect, including encrypted data transmission (HTTPS), access controls, and vendor due diligence. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

15. Your Rights and Choices

Depending on your location and your status as the data owner under Section 11, you may have the right to:

• Request access to the personal information we hold about you, including an exported file of any data you have provided
• Request correction of inaccurate information
• Request deletion of your information, subject to data we are obliged to keep for administrative, legal, or security purposes
• Update your parent involvement preference at any time in writing
• Opt out of marketing communications at any time by clicking "unsubscribe" in any email or by contacting us directly
• Withdraw consent for processing assessment data, subject to limits where assessments have already been administered

If you have an account on this site or have left comments, you can request to receive an exported file of the personal data we hold about you. You can also request that we erase any personal data we hold about you, except data we are required to retain for administrative, legal, or security purposes. To exercise these rights, contact us using the information in Section 17.

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Material changes will be communicated by email or prominent notice on our website where appropriate.

17. Contact Us

This Privacy Policy is provided for informational purposes and reflects our current practices. It is not legal advice. We recommend consulting a qualified attorney to confirm compliance with all applicable laws in jurisdictions where you operate or where your participants reside.