Privacy Policy – The UD Project

Effective Date: October 15, 2025

This Privacy Policy describes the policies and procedures of Pruett & Co., LLC, DBA The UD Project, a Limited Liability Company formed in Virginia, United States (“us,” “we,” “our”) on the collection, use and disclosure of your information on universaldesign.org (the “Site”) and the services, features, content or applications we offer (together with the Site, the “Services”).

We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from various third party websites and other services. All defined terms not defined herein shall have the meaning ascribed to them in the Terms of Service, available at universaldesign.org/legal/terms.

1. Coverage

What does our policy cover?

This Privacy Policy covers The UD Project’s processing of Personal Data that The UD Project gathers when you are accessing and using the Services. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

This Privacy Policy also covers The UD Project’s treatment of any Personal Data that The UD Project’s business partners share with The UD Project or The UD Project shares with its business partners. This Privacy Policy does not apply to the practices of third parties, and their sites, services or applications that The UD Project does not own or control, or to individuals that The UD Project does not employ or manage (“Third Parties”). While we attempt to provide access only to those Third Parties that share our respect for your privacy, we cannot take responsibility for the content, actions or privacy policies of those Third Parties. We encourage you to carefully review the privacy policies of any Third Parties you access.

If you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under European Union Regulation (EU) No. 2016/679 of 27 April 2016, also known as the General Data Protection Regulation or GDPR (the “GDPR”) with respect to your Personal Data, as outlined below. The UD Project may be the controller of your Personal Data processed in connection with the Services for purposes of the GDPR. If you have any questions about this Privacy Policy or whether any of the following applies to you, please contact us at [email protected].

Note that we may also process Personal Data of our users’ own customers, end users, or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data for purposes of the GDPR. If we are the processor of your Personal Data (i.e., not the controller) for purposes of the GDPR, please contact the controller of your Personal Data (i.e., the user or individual providing the course, product, or other offering in connection with which you provided your Personal Data) in the first instance to address your rights with respect to such data.

2. Data Collection

2.1 What Personal Data does The UD Project Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you:

We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

First and last name
Email address
Billing zip code and/or country of residence

By providing Personal Data of others to The UD Project, you represent that you have authority to do so. All information that you enter or upload about your non-users will be covered by The UD Project’s Terms of Service, accessible at https://universaldesign.org/legal/terms, this Privacy Policy, and where applicable, the EU Data Processing Addendum, available at https://universaldesign.org/privacy. We disclaim responsibility for the information of others that you provide to us in the course of your use of the Services.

In order to collect payments on your behalf from your customers, and provide payments to you, we, using Stripe and/or PayPal as third-party payment processors, collect payment information from you, your attendees and customers, your vendors, and other parties to whom we provide payments on your behalf and from whom we collect payments on your behalf. This information is used solely to collect and provide payments related to the Services, and is only stored by Stripe.

Information we receive from third party sources:

We have built services from some third parties into the Site, and those third parties provide us with Personal Data about you, such as the following:

Account information for third party services:

If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (for example, signing up for an account with Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

Information from our advertising partners:

We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our Site and Services.

Information from our service providers:

We receive information collected by third parties about your use of the Services. For example, we may use analytics service providers to analyze how you interact and engage with the Services and our advertisements, so we can learn and make enhancements to offer you a better experience. Some of these entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, which may include tracking activity across time and unaffiliated properties, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. Third parties may also help us provide you with customer support, and provide us with information so that we may help you use our Services.

Information we automatically collect when you use our Services:

Some Personal Data is automatically collected when you use our Services, such as the following:

IP address
Device identifiers
Web browser information
Page view statistics
Browsing history
Usage information and click tracking
Transaction information (e.g. transaction amount, date and time such transaction occurred)
Cookies and other tracking technologies (see below for more information)
Log data (e.g. access times, hardware and software information)

2.2 Additional Information about Cookies

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site and Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit our Site. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties.

Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties.

Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies.

2.3 We use the following types of Cookies

Essential Cookies.

Essential Cookies that are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.

Functionality Cookies.

Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies.

Performance/Analytical Cookies allow us to understand how visitors use our Site and Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

Retargeting/Advertising Cookies.

Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Additional information about interest-based advertisements.”

You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new Cookie in various ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.

2.4 Cookie Consent and Management

When you first visit our Site, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies. You can manage your cookie preferences at any time by:

Using the cookie settings link in the footer of our website
Adjusting your browser settings to block or delete cookies
Contacting us at [email protected]

Please note that blocking all cookies, including essential cookies, may prevent you from using certain features of our Services.

2.5 Specific Third-Party Services

We use the following third-party services that may collect and process your Personal Data:

Analytics: Google Analytics, for analyzing website traffic and user behavior
Payment Processing: Stripe, for processing payments
Email Services: For sending transactional and marketing emails
Hosting Services: For website hosting and data storage
Advertising Platforms: For delivering targeted advertisements

Each of these third-party services has its own privacy policy governing how they process your Personal Data. We encourage you to review their privacy policies.

3. Data Usage

3.1 How Do We Use Your Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

Communicate with you about the Services
Protect against or deter fraudulent, illegal or harmful actions
Allow you to create and/or manage your digital storefront, your sales pages, and your online courses
Allow you to create, manage, and/or subscribe to membership software
Allow you to create, manage, and/or sell digital files
Allow you to create, manage, and/or sell digital downloads and online courses
Contact you about Service announcements, updates or offers
Personalize website content and communications based on your preferences
Provide support and assistance for the Services
Discover others who might be interested in the Services
To identify trends and other statistical information that may be useful to our business
Comply with our legal or contractual obligations
Resolve disputes
Enforce our Terms of Service (including, for clarity, the Privacy Policy and, where applicable, the EU Data Processing Addendum)

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

3.2 Automated Decision-Making and Profiling

We do not use your Personal Data for automated decision-making or profiling that produces legal effects or similarly significantly affects you. If we implement such processing in the future, we will update this Privacy Policy and provide you with appropriate notice and, where required, obtain your consent.

3.3 Contractual Necessity

We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

First and last name
Email address
User Content (which can include Personal Data if you include Personal Data in such content)
IP address
Billing zip code and/or country of residence

3.4 Legitimate Interest

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

First and last name
Email address
IP address
Billing zip code and/or country of residence

Examples of these legitimate interests include:

Protection from fraud or security threats
Operation and improvement of our business, products and services
Marketing of our products and services, directly to you and to others
Provision of customer support
Compliance with legal obligations
Completion of corporate transactions

3.5 Consent

In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

3.6 Other Processing Grounds

From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

3.7 How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

Payment processors
Fraud prevention service providers
Analytics service providers
Hosting service providers
Marketing service providers
Email providers
Staff augmentation and contract personnel

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
Social media services (if you interact with them through your use of the Services)
Third party business partners who you access through the Services, including vendors
Other parties authorized by you

We also share Personal Data when we believe it is necessary to:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
Protect us, our business or our users, for example to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Maintain the security of our products and services.

We also share information with third parties when you give us consent to do so. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

3.8 Marketing Communications and Opt-Out

As part of the Services, you will receive from The UD Project email and other communications. You acknowledge and agree that by availing yourself of the Services, you allow The UD Project to send you email and other communication that it determines in its sole discretion relate to your use of the Services.

You may opt out of receiving marketing communications from us at any time by:

Clicking the “unsubscribe” link in any marketing email you receive from us
Adjusting your email preferences in your account settings
Contacting us at [email protected]

Please note that even if you opt out of marketing communications, we will still send you transactional and service-related messages, such as account notifications, security alerts, and messages about your orders or use of the Services.

4. Data Requests

4.1 Requests made by you

You may, at any time, request a copy of your data. We require that these requests come from the same email address that you use for your account. If you no longer have access to this email address, we will need to verify your identity with a phone number we have on record. If we cannot verify your identity, the data will not be released.

4.2 Requests made by others

While rare, other entities may directly request Personal Data that includes more information than listed in sections 2 and 3, such as the records for the courses you have signed up for. The UD Project will not release this data without your explicit written permission. We require your permission to come from the same email address you use for your account. If you no longer have access to this email address, we will need to verify your identity with a phone number we have on record. The data will not be released if we cannot reach you to obtain your permission.

5. Data Storage and Security

5.1 How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Specific retention periods:

Account information: Retained for the duration of your active account, plus 2 years after account closure
Transaction records: Retained for 7 years for tax and accounting purposes
Marketing data: Retained until you opt out or for 3 years from your last interaction with us
Cookie data: Retained for the duration specified in Section 2.2 above

5.2 What Security Measures Do We Use?

We protect and secure Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. These measures include:

Encryption of data in transit and at rest
Regular security assessments and penetration testing
Access controls and authentication requirements
Regular employee training on data protection and security
Secure development practices and code reviews

You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your device and browser by signing off after you have finished accessing your Account.

5.3 Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and, where required by law, the relevant supervisory authority, without undue delay and within 72 hours of becoming aware of the breach. Our notification will include information about the nature of the breach, the categories and approximate number of data subjects affected, the likely consequences, and the measures we have taken or propose to take to address the breach and mitigate its possible adverse effects.

5.4 Do We Store the Personal Data of Children?

We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [email protected].

6. European Union Data Subject Rights

What Do Users in the European Union Need to Know?

By law, users in the European Union, United Kingdom, Lichtenstein, Norway, or Iceland have certain rights with respect to their Personal Data, including those set forth below. For more information about these rights, or to submit a request, please visit your Account settings or email us at [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access:

You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

Rectification:

If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You may also be able to correct some of this information directly by making updates to your account.

Erasure:

You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent:

If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Portability:

You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Objection:

You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Restriction of Processing:

You can ask us to restrict further processing of your Personal Data.

Right to File Complaint:

You have the right to lodge a complaint about The UD Project’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of supervisory authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en.

7. U.S. State Privacy Rights

7.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

Right to Know:

You have the right to request that we disclose what Personal Data we collect, use, disclose, and sell about you. This includes:

The categories of Personal Data we have collected about you
The categories of sources from which we collected your Personal Data
Our business or commercial purpose for collecting or selling your Personal Data
The categories of third parties with whom we share your Personal Data
The specific pieces of Personal Data we have collected about you

Right to Delete:

You have the right to request that we delete the Personal Data we have collected from you, subject to certain exceptions.

Right to Correct:

You have the right to request that we correct inaccurate Personal Data that we maintain about you.

Right to Opt-Out of Sale/Sharing:

You have the right to opt-out of the “sale” or “sharing” of your Personal Data. We do not sell your Personal Data in the traditional sense. However, we may share your Personal Data with advertising partners for targeted advertising purposes, which may be considered a “sale” or “sharing” under the CCPA. To opt-out of this sharing, please use the “Do Not Sell or Share My Personal Information” link in the footer of our website or contact us at [email protected].

Right to Limit Use of Sensitive Personal Data:

You have the right to limit our use of your sensitive Personal Data to that which is necessary to perform the Services or provide the goods reasonably expected by an average consumer. We do not currently collect or process sensitive Personal Data beyond what is necessary to provide our Services.

Right to Non-Discrimination:

You have the right not to receive discriminatory treatment for exercising your privacy rights under the CCPA.

How to Exercise Your Rights:

To exercise any of these rights, please:

Email us at [email protected]
Use the “Do Not Sell or Share My Personal Information” link in the footer of our website
Visit your account settings to update or delete your information

We will verify your identity before processing your request. You may designate an authorized agent to make a request on your behalf by providing written authorization signed by you.

Shine the Light Law:

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected].

7.2 Virginia Residents (VCDPA)

If you are a Virginia resident, you have the following rights under the Virginia Consumer Data Protection Act (VCDPA):

Right to access your Personal Data
Right to correct inaccuracies in your Personal Data
Right to delete your Personal Data
Right to obtain a copy of your Personal Data in a portable format
Right to opt-out of the processing of your Personal Data for purposes of targeted advertising, sale of Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects

To exercise these rights, please contact us at [email protected]. If we decline to take action on your request, you have the right to appeal our decision by contacting us at the same email address.

7.3 Other U.S. State Privacy Rights

If you are a resident of Colorado, Connecticut, Utah, or another U.S. state with comprehensive privacy legislation, you may have rights similar to those described above for California and Virginia residents. Please contact us at [email protected] to exercise your rights or for more information about how your state’s privacy laws apply to our processing of your Personal Data.

8. International Data Transfers

8.1 Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through The UD Project and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to The UD Project in the U.S. and will be hosted on U.S. servers, and you authorize The UD Project to transfer, store and process your information to and in the U.S., and possibly other countries.

If you live in the European Union, United Kingdom, Iceland, Liechtenstein, or Norway, you hereby consent to the transfer of your data. Where required by law, we use Standard Contractual Clauses approved by the European Commission or other appropriate safeguards to ensure that your Personal Data is protected when transferred outside of the European Economic Area.

8.2 Data Protection Officer and EU Representative

For questions about our data protection practices or to exercise your rights under the GDPR, please contact us at [email protected]. If required by law, we will appoint a Data Protection Officer and/or EU Representative, and their contact information will be provided here.

9. Additional Provisions

9.1 What If You Have Questions Regarding Your Personal Data?

If you have any questions about this Privacy Policy or our data practices generally, please contact us at [email protected].

9.2 Changes to this Privacy Policy

The UD Project may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we use Personal Data, we will notify you by posting an announcement on our Site or Services or sending you an email. Users are bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted. We will indicate at the top of this Privacy Policy when it was last updated.

9.3 Supervisory Authority Contact Information

If you are located in the European Economic Area and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority. You can find contact information for your supervisory authority at: https://edpb.europa.eu/about-edpb/board/members_en