Cookie Policy

Streamline. Unify. Scale.

Part I — Breakthrough Advancement Website

This Cookie Policy describes how Breakthrough Advancement LLC (“BA,” “we,” “us,” or “our”) uses cookies, pixels, tags, software development kits, and similar technologies (collectively, “Cookies”) on the website located at breakthroughadvancement.com, including any subdomains, member areas, and online services made available through it (collectively, the “Site”).

This Cookie Policy is incorporated by reference into the BA Website Privacy Policy and the BA Website Terms of Service. Capitalized terms not defined here have the meanings given to them in those documents.

1. What cookies are

A cookie is a small text file that a website places on your device to remember information about your visit. Related technologies include:

• Pixels and beacons — small graphic files that track when you load a page or open an email
• Tags — snippets of code that load additional functionality from a third party
• Software development kits (SDKs) — code libraries integrated into mobile apps that perform similar functions
• Local storage — browser-based storage analogous to cookies

Throughout this Policy, “Cookies” refers to all of the above.

Cookies can be first-party (set by BA) or third-party (set by a service provider or partner BA has integrated with the Site). They can also be session (deleted when you close your browser) or persistent (remain on your device for a defined period).

2. Categories of cookies we use

BA uses Cookies in four categories.

2.1 Strictly necessary

These Cookies are essential for the Site to function. They cannot be disabled in our systems. They support things like authentication, session continuity, security, and load balancing.

Legal basis: Not subject to consent under most laws (GDPR Article 5(3) “strictly necessary” exception).

2.2 Performance and analytics

These Cookies help us understand how Users interact with the Site so we can improve content and navigation. They collect information in aggregated or pseudonymous form.

Legal basis: Consent (where required by law).

2.3 Advertising and retargeting

These Cookies are set by advertising partners to show you relevant ads on third-party platforms, measure ad campaign performance, and limit the number of times you see the same ad. Some of these Cookies involve “sharing” of Personal Information under California law and similar U.S. state privacy laws.

Legal basis: Consent (where required by law).

2.4 Functional

These Cookies remember preferences (e.g., language, dark mode, content you’ve viewed) to provide a more personalized experience.

Legal basis: Consent (where required by law).

3. Specific cookies and tracking technologies

The table below lists the Cookies and tracking technologies BA currently uses or may use on the Site. The specific Cookies in use may vary over time as BA adjusts the Site. The most current list can be inspected through your browser’s developer tools or through the cookie-preferences interface available in the Site footer.

3.1 Strictly necessary

3.2 Performance and analytics

3.3 Advertising and retargeting

3.4 Functional

4. Third-party cookies and trackers

Third-party Cookies are governed by the privacy policies of the respective third parties. BA does not control how third parties collect, use, or share information through their own Cookies. Links to relevant third-party privacy policies:

BA does not transmit form-submitted Personal Information (such as names and email addresses entered into contact forms) to advertising partners as part of standard tracking. Conversion events transmitted to advertising platforms are limited to non-content signals (e.g., “form submitted”) and identifiers necessary for measurement.

5. Your choices

You can manage Cookies in several ways.

5.1 Cookie banner and preferences

The Site displays a cookie banner on your first visit (where required by applicable law). You can change your preferences at any time using the “Cookie Preferences” or “Your Privacy Choices” link in the Site footer.

5.2 Browser settings

Most browsers let you block or delete Cookies, and notify you when Cookies are set. See your browser’s Help section for instructions:

• Chrome: support.google.com/chrome/answer/95647
• Firefox: support.mozilla.org/kb/cookies
• Safari: support.apple.com/guide/safari
• Edge: support.microsoft.com/microsoft-edge

Blocking strictly necessary Cookies may break Site functionality (e.g., logins).

5.3 Opt-out tools

Industry-wide opt-out tools are available for advertising Cookies:

• Digital Advertising Alliance (US): optout.aboutads.info
• Network Advertising Initiative (US): optout.networkadvertising.org
• European Interactive Digital Advertising Alliance: youronlinechoices.eu
• Your Online Choices (UK): youronlinechoices.com

5.4 Mobile device settings

If you access the Site from a mobile device, you can reset your advertising identifier or limit ad tracking through your device settings.

5.5 Google Analytics opt-out

You can opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-on, available at tools.google.com/dlpage/gaoptout.

6. Global Privacy Control and Do Not Track

The Site honors the Global Privacy Control (“GPC”) signal in jurisdictions where GPC is recognized as a valid opt-out (including California). When BA detects a GPC signal, BA treats it as an opt-out of the sale or sharing of Personal Information for cross-context behavioral advertising, and disables advertising Cookies for that session.

The Site does not respond to browser “Do Not Track” signals because no industry standard for “Do Not Track” exists.

7. International considerations

For visitors located in the European Union, United Kingdom, EEA, Switzerland, or other jurisdictions that require opt-in consent for non-essential Cookies, BA does not set non-essential Cookies until you have provided consent through the cookie banner. Strictly necessary Cookies are set without consent because they are essential for Site functionality.

For visitors in California, Virginia, Colorado, Connecticut, Utah, Texas, and other U.S. states with comparable privacy laws, BA honors opt-out signals (including GPC) for the “sale” or “sharing” of Personal Information collected via advertising Cookies. See the BA Website Privacy Policy for additional state-specific rights.

8. Changes to this policy

BA may update this Cookie Policy from time to time as the Site’s Cookies and trackers change. The “Last Updated” date at the top reflects the date of the most recent revision. Continued use of the Site after the effective date of an updated Policy constitutes acceptance.

9. Contact information

Part II — Plain-English summary

This Part II is a plain-language summary of the Policy above. Where the two conflict, Part I controls.

1. What Cookies are. Small files websites place on your device. We use them, and so do some of our service providers.
2. What we use them for. Four categories: (1) strictly necessary for the site to work (logins, security), (2) analytics to understand how the site is used, (3) advertising so we can show relevant ads on Meta, LinkedIn, and Google, and (4) functional for remembering preferences.
3. Who else sets Cookies on our site. Google (Analytics and Ads), Microsoft Clarity, Meta (Facebook/Instagram), LinkedIn, Cloudflare, and payment processors when you check out.
4. How to manage them. Cookie banner on first visit. “Cookie Preferences” link in the footer. Browser settings. Industry opt-out tools (DAA, NAI, EDAA).
5. Global Privacy Control. If your browser sends a GPC signal, we treat it as an opt-out request for the sale or sharing of your data and disable advertising cookies for that session.
6. EU / UK / EEA. We get your consent before setting non-essential cookies.
7. Changes. We can update this Policy. The “Last Updated” date at the top tells you when.
8. Contact. privacy@breakthroughadvancement.com.

Document history

May 28, 2026 — Initial publication. New document as part of the Unified Pack Sweep.

Not legal advice — Counsel review recommended before publication. See BA-Counsel-Review-Notes.docx for outstanding review items.