Privacy Policy

Streamline. Unify. Scale.

Part I — Breakthrough Advancement Website

This Privacy Policy describes how Breakthrough Advancement LLC (“BA,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you access or use the website located at breakthroughadvancement.com, including any subdomains, member areas, forms, downloadable resources, and online services made available through it (collectively, the “Site”).

BA is the data controller for personal information collected through the Site. BA is an Arizona limited liability company with its principal place of business at One South Church Ave, Suite 1200, Tucson, AZ 85701.

This Privacy Policy applies only to the Site. It does not apply to BreakTruVerify (BTV), our SaaS product, which is governed by the separate BTV Privacy Policy.

1. Scope and definitions

1.1 Personal Information (or Personal Data) means information that identifies, relates to, describes, or could reasonably be linked with a particular individual or household.

1.2 Processing means any operation performed on Personal Information, including collection, recording, storage, use, disclosure, and deletion.

1.3 Sensitive Personal Information has the meaning given to it by the California Privacy Rights Act (“CPRA”) and similar state and international laws, including precise geolocation, government identifiers, financial account credentials, racial or ethnic origin, religious beliefs, and health information.

1.4 Site Visitor means any person who accesses the Site, whether or not they submit information or create an Account.

2. Information we collect

2.1 Information you provide directly

2.2 Information we collect automatically

2.3 Information from third-party sources

2.4 Sensitive Personal Information. BA does not knowingly collect Sensitive Personal Information through the Site. You are instructed not to submit such information through general contact forms. If you submit Sensitive Personal Information voluntarily and unsolicited (e.g., in a free-text message field), BA will delete it within a reasonable time unless retention is required for the purpose for which you submitted it.

2.5 Children’s Information. The Site is not directed to and does not knowingly collect Personal Information from individuals under sixteen (16) years of age. If BA learns it has collected such information, BA will delete it. See Section 13.

3. How we use information

BA uses Personal Information for the following purposes:

• Responding to inquiries — fulfilling consultation requests, answering questions, providing requested resources
• Account administration — creating and maintaining member Accounts, authenticating you, providing access to gated content
• Service delivery — where a User has separately engaged BA under an MSA, supporting that engagement
• Payments — processing transactions, issuing invoices, supporting refund and chargeback processes
• Marketing communications — sending newsletters, content updates, and offers to Users who have opted in, in accordance with CAN-SPAM and applicable law
• Analytics and improvement — measuring Site performance, understanding which content is useful, improving user experience
• Security and fraud prevention — detecting and preventing unauthorized access, malicious activity, and abuse
• Legal compliance — responding to lawful requests from authorities, asserting or defending legal claims, complying with tax and recordkeeping obligations
• Business operations — internal reporting, financial planning, and other legitimate business activities consistent with this Privacy Policy

Legal bases for processing (EEA / UK residents)

For Users in the EEA or UK, BA processes Personal Information under one or more of the following legal bases:

• Consent — for marketing communications, non-essential cookies, and certain optional features
• Contract performance — for Account administration, requested services, and processing payments
• Legitimate interests — for analytics, security, fraud prevention, and improving the Site, where those interests are not overridden by your rights
• Legal obligation — for tax records, regulatory compliance, and responding to lawful requests

You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. Cookies and tracking technologies

4.1 What we use

BA and its service providers use cookies, pixels, tags, and similar technologies on the Site. These fall into the following categories:

4.2 Detailed disclosure

A more detailed list of the specific cookies and tracking technologies in use, including their purpose and retention period, is provided in the BA Cookie Policy, which is incorporated by reference into this Privacy Policy.

4.3 Consent and controls

Where required by law, BA requests your consent before setting non-essential cookies through a cookie banner. You may withdraw consent or change your preferences at any time using the cookie-preferences link in the Site footer. You may also block or delete cookies using your browser settings, though doing so may impair functionality.

4.4 Do not track and Global Privacy Control

The Site honors the Global Privacy Control (“GPC”) signal for visitors in jurisdictions where GPC is recognized as a valid opt-out (including California). When BA detects a GPC signal, BA treats it as a request to opt out of the sale or sharing of Personal Information and the use of Personal Information for cross-context behavioral advertising. BA does not currently respond to browser “Do Not Track” signals because no industry standard exists for them.

5. How we share information

BA shares Personal Information only as described below. BA does not sell Personal Information for money. Certain disclosures to advertising partners may be considered “sharing” or a “sale” under California and similar state laws (see Sections 10 and 11).

5.1 Categories of recipients

5.2 What we do not do

BA does not rent, trade, or sell Personal Information to data brokers. BA does not disclose contact-form submissions to advertising networks.

6. Sub-processors and service providers

BA engages third-party service providers (sub-processors) to support Site operations and BA’s business. All sub-processors are bound by written agreements requiring confidentiality, security, and use of Personal Information only as directed by BA. Categories of sub-processors include:

A current list of material sub-processors is available on request at privacy@breakthroughadvancement.com.

7. Data retention

BA retains Personal Information only as long as necessary for the purposes described in this Policy, or for longer periods where required or permitted by law. Typical retention windows:

After the applicable retention period, BA either deletes Personal Information or anonymizes it such that it can no longer be associated with an identifiable individual.

8. International data transfers

BA is based in the United States. BA personnel and contractors operate from multiple countries to deliver services and support the Site. As a result, Personal Information may be transferred to, stored in, and processed in countries other than the country in which you are located, including the United States and other jurisdictions whose data protection laws may differ from those of your home jurisdiction.

For transfers from the EEA, UK, or Switzerland to countries that have not received an adequacy decision, BA implements appropriate safeguards, including the European Commission’s Standard Contractual Clauses (“SCCs”), the UK International Data Transfer Addendum, and supplementary measures where required. A copy of the relevant SCCs is available on request at privacy@breakthroughadvancement.com.

9. Your privacy rights — general

Subject to applicable law and verification of your identity, you may have the following rights with respect to your Personal Information:

• Access — request a copy of the Personal Information BA holds about you
• Correction — request correction of inaccurate or incomplete information
• Deletion — request deletion, subject to legal and legitimate-business exceptions
• Portability — receive your information in a structured, commonly used, machine-readable format
• Restriction — request restriction of processing in certain circumstances
• Objection — object to processing based on legitimate interests, including for direct marketing
• Withdraw Consent — where processing is based on consent, withdraw consent at any time
• Opt out of marketing — opt out of marketing emails at any time using the unsubscribe link or by contacting privacy@breakthroughadvancement.com
• Not be retaliated against — for exercising any privacy right

9.1 How to exercise rights

Submit requests to privacy@breakthroughadvancement.com. BA will respond within the timeframes required by applicable law (typically 30–45 days). BA may require verification of identity proportionate to the sensitivity of the data and the nature of the request.

9.2 Authorized agents

You may authorize an agent to submit a request on your behalf. BA may require written documentation of the authorization and may verify the identity of both you and the agent.

9.3 Appeals

Where applicable law provides an appeal right (including under Virginia, Colorado, Connecticut, and other state privacy laws), you may appeal a denial of a privacy request by replying to BA’s response or by contacting privacy@breakthroughadvancement.com with the subject line “Privacy Request Appeal.” BA will respond to appeals within 45 days, or such other period as required by applicable law.

10. California residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), gives you additional rights.

10.1 Categories of personal information collected (CCPA categories)

In the preceding 12 months, BA has collected the following CCPA categories of Personal Information about Site Visitors:

10.2 Sources

Sources of Personal Information include those described in Section 2 of this Policy.

10.3 Business purposes

Personal Information is collected and used for the business purposes described in Section 3.

10.4 California rights

California residents have the right to:

• Know what Personal Information BA has collected, used, disclosed, or shared
• Delete Personal Information, subject to legal exceptions
• Correct inaccurate Personal Information
• Opt out of “sale” or “sharing” of Personal Information for cross-context behavioral advertising — exercise this right using the “Your Privacy Choices” link in the Site footer or by sending a GPC signal
• Limit use of Sensitive Personal Information — BA does not currently use Sensitive Personal Information for purposes that trigger this right
• Non-discrimination — BA will not discriminate against you for exercising California privacy rights
• Authorized agent — designate a representative to act on your behalf

10.5 Retention

Retention periods are described in Section 7.

10.6 Submitting requests

Submit California privacy requests to privacy@breakthroughadvancement.com. BA does not currently operate a toll-free number; given the nature and scale of the Site, written submission is the exclusive method. BA will respond within 45 days, extendable by an additional 45 days as permitted under the CCPA.

10.7 Shine the Light

California Civil Code § 1798.83 entitles California residents to request information about disclosures of Personal Information to third parties for the third parties’ direct marketing purposes. BA does not disclose Personal Information to third parties for their direct marketing purposes.

11. Virginia, Colorado, Connecticut, Utah, and Texas residents

If you are a resident of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), or another U.S. state that has enacted a comparable consumer privacy law, you have the rights enumerated in Section 9 to the extent provided by your state’s law, including:

• the right to access, correct, and delete your Personal Data;
• the right to portability;
• the right to opt out of targeted advertising, the sale of Personal Data, and profiling in furtherance of decisions producing legal or similarly significant effects;
• the right to appeal a denial of a privacy request (Virginia, Colorado, Connecticut, and similar laws).

Submit requests to privacy@breakthroughadvancement.com. BA will respond within the timeframes set by your state’s law (typically 45 days, extendable by 45 days where permitted).

BA does not engage in profiling that produces legal or similarly significant effects, and does not knowingly process Personal Data of consumers under 16 for purposes of targeted advertising or sale.

12. European Union, United Kingdom, and EEA residents (GDPR)

If you are in the European Union, United Kingdom, European Economic Area, or Switzerland, the General Data Protection Regulation (GDPR) and the UK GDPR give you additional rights with respect to your Personal Data.

12.1 Data controller

BA is the data controller for Personal Data collected through the Site. Contact details are in Section 18.

12.2 Legal bases for processing

BA processes Personal Data on the legal bases described in Section 3.

12.3 Rights

You have the rights set out in Section 9, plus the right to lodge a complaint with your local supervisory authority.

12.4 International transfers

International transfer mechanisms are described in Section 8.

12.5 EU / UK representative

BA has not appointed an EU or UK representative under GDPR Article 27 / UK GDPR Article 27 at this time, as BA’s processing does not currently meet the thresholds requiring such appointment. BA will appoint a representative if and when required by law.

12.6 Automated decision-making

BA does not engage in solely automated decision-making that produces legal or similarly significant effects with respect to Personal Data collected through the Site.

13. Children’s privacy

The Site is not directed to children under the age of sixteen (16). BA does not knowingly collect Personal Information from children under 16. If BA learns that it has collected Personal Information from a child under 16 without verified parental consent, BA will promptly delete that information. If you believe BA has collected information from a child under 16, contact privacy@breakthroughadvancement.com.

14. Security measures

BA implements technical and organizational measures designed to protect Personal Information against unauthorized access, alteration, disclosure, and destruction. These measures include:

• encryption of data in transit using TLS 1.2 or higher
• encryption of data at rest where supported by the underlying storage provider
• access controls and least-privilege principles for BA personnel and contractors
• confidentiality obligations and security training for personnel and contractors with access to Personal Information
• sub-processor due diligence and contractual security commitments
• regular review of access logs and security events
• incident response procedures, including data-breach notification protocols

No security measure is perfect or impenetrable. BA cannot guarantee absolute security. You are responsible for keeping your Account credentials confidential.

15. Data breach notification

In the event of a Personal Information security breach that meets the threshold for notification under applicable law (including, where applicable, the GDPR, UK GDPR, CCPA, and U.S. state breach-notification statutes), BA will notify affected individuals and relevant authorities within the timeframes required by such law. Where individual notification is not feasible, BA may provide substitute notice through prominent Site posting or other reasonable means.

16. Do not track and Global Privacy Control

See Section 4.4. BA honors the Global Privacy Control signal in jurisdictions where required and treats it as a valid opt-out request for the sale or sharing of Personal Information. BA does not honor browser “Do Not Track” signals because no industry standard exists for them.

17. Changes to this policy

BA may update this Privacy Policy from time to time. The “Last Updated” date at the top reflects the date of the most recent revision. Material changes will be communicated through reasonable means, which may include email notice to registered Users or a banner on the Site. Continued use of the Site after the effective date of an updated Policy constitutes acceptance of the updated Policy.

18. Contact information

For privacy-related questions, requests, or complaints:

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. Who we are. Breakthrough Advancement LLC operates breakthroughadvancement.com. This Policy covers that site. BTV has its own privacy policy.
2. What we collect. Information you give us through forms (name, email, phone, company), what we learn automatically when you visit (IP, browser type, pages viewed), and limited information from third parties like payment processors and ad platforms.
3. What we do with it. Respond to your inquiries, deliver services you’ve engaged us for, send marketing if you’ve opted in, run analytics to improve the site, process payments, prevent fraud, and meet legal obligations.
4. Cookies and trackers. We use Google Analytics, Microsoft Clarity, Meta Pixel, LinkedIn Insight Tag, and similar tools. See the Cookie Policy for the full list. You can manage preferences through our cookie banner or your browser. We honor the Global Privacy Control signal.
5. Who we share with. Service providers we use to run the business (hosting, CRM, email, payments, analytics), legal authorities when required, and successors if we’re acquired. We don’t sell your data. Some sharing with ad platforms is considered “sharing” under California law — you can opt out.
6. International contractors. We work with contractors in multiple countries. Your data may be processed outside your home country. For EU/UK data, we use Standard Contractual Clauses.
7. Your rights. Access, correct, delete, port, restrict, object, withdraw consent, opt out of marketing. Email privacy@breakthroughadvancement.com to exercise any right. California, Virginia, Colorado, Connecticut, Utah, Texas, EU, and UK residents have additional rights — see the corresponding sections in Part I.
8. How long we keep data. Contact forms 24 months, marketing list until unsubscribe, accounts during their life plus 24 months, tax records 7 years, server logs 90 days. Full schedule in Section 7.
9. Security. TLS encryption, access controls, contractor confidentiality, incident response. No system is 100% secure.
10. Kids. Site isn’t for kids under 16. We don’t knowingly collect their info.
11. Changes. We can update this Policy. The “Last Updated” date at the top tells you when.
12. Contact. privacy@breakthroughadvancement.com for anything privacy-related.

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.