Privacy Notice
Last Updated and Effective Date: October 24, 2024

• Effective Date and Changes to this Privacy Notice
• Personal Information We May Collect about You
• How We Collect Personal Information About You
• How We Use Your Personal Information
• Disclosing Your Personal Information
• Your Rights and Choices
  • US Privacy Rights
  • EEA, UK, and Switzerland Privacy Rights
• Data Retention
• Children’s Data Protection and Parental Responsibility
• Data Security
• Contact Information

This Privacy Notice pertains to Southwestern/Great American, Inc., doing business as Southwestern Family of Companies, its subsidiaries, and other related entities. Those subsidiaries and related entities are:

• Southwesterni Advantage, Inc.
• Southwestern Advantage UK Limited
• Southwestern Consulting, Inc.
• Southwestern Finance Latvia SIA
• Southwestern Inspire Kindness, Inc.
• Southwestern Insurance Group, Inc.
• Southwestern Legacy Financial Services, Inc.
• Southwestern Legacy Insurance Group, Inc.
• Southwestern Life Transitions, LLC
• Southwestern Medicare, Inc.
• Southwestern Publishing House, Inc.
• Southwestern Real Estate, Inc.
• Southwestern Recruitment OÜ
• Southwestern Talent, LLC
• Southwestern Travel, Inc.
• Southwestern Ventures OÜ
• Southwestern Ventures UAB
• Gap Heroes, LLC
• Global Cultural Exchanges
• Global Educational Concepts, Inc.
• Great American Opportunities, Inc.
• Kindness for Kids, Inc.
• Pat Summitt Leadership Group, Inc.
• SBR Consulting Services LTD
• Thinking Ahead, Inc.

Collectively, “Southwestern,” “we,” or other applicable first-person pronouns. The Privacy Notice informs the individuals we interact with (collectively, “user(s),” “you,” or “your”) about how Southwestern may collect, use, and disclose the Personal Information (defined below) and for US users, nonpublic personal information (“NPI”) as defined by financial privacy laws, that you provide us and the rights and choices available to you.

Please read this Privacy Notice carefully. If you do not agree with the policies and practices it describes, please do not use our Site or otherwise provide us with your Personal Information, or you may choose to exercise your rights as discussed in this Privacy Notice.

In some cases, our users may include individuals designated as “children” in their jurisdiction. For more information on how Southwestern complies with children’s data protection regulations, please read the section titled Children’s Data Protection and Parental Responsibility below.

This Privacy Notice applies to information we collect, including when you:

• Visit https://southwestern.com/ and any other websites from our subsidiaries and related entities which link to this Privacy Notice (collectively, our “Site”).
• Use the mobile and desktop applications we operate.
• Access or use our products and services.
• Communicate with us in phone calls, web-conferencing, email, text, and other electronic messages, including interactive chat functions between you and our Site.

This Privacy Notice DOES NOT apply to:

• Information that you provide to or is collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or through our Site. Those third parties have their own privacy notices, which we encourage you to read before providing them information.
• Information we collect regarding employees, contractors, and job applicants. We maintain a separate privacy notice for employees, contractors, and job applicants. Please contact us through the information provided below if you are a Southwestern employee, contractor, or job applicant and would like more information about our privacy practices related to your employment information.

You may be entitled to additional disclosures and able to exercise additional privacy rights that are not listed in this Privacy Notice. The information and rights available to you depend on our reason for processing your Personal Information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located in, for example, the European Union or California). Please select the appliable link below to learn more about the information and rights that may be available to you:

• US Privacy
• EEA, UK, and Switzerland Privacy Notice

Please read this Privacy Notice carefully as it is a legally binding document between Southwestern and you.

Effective Date and Changes to this Privacy Notice

This Privacy Notice is effective as of the “Last Updated and Effective Date” above and will remain in effect except with respect to any provisions that are changed in the future.

Southwestern may make changes to or supplement this Privacy Notice from time to time and will notify you by posting those changes on the Site and the supplemental disclosures linked from this Privacy Notice. Any changes will be effective immediately upon their posting to the Site or upon you being otherwise notified. You are expected to check this page regularly so you are aware of any changes, as they are binding on you. Your continued use of our products, services, or the Site following the posting of a revised privacy notice means that you accept and agree to the changes. We will also revise the date found at the beginning of this Privacy Notice when we post changes to it.

Also, this Privacy Notice may be supplemented by privacy notices tailored to our specific relationships with you or the products or services you are interested in or purchase, including privacy notices that are sent to individuals as required under applicable laws and regulations.

Personal Information We May Collect about You

For purposes of our Privacy Notice, Southwestern defines Personal Information broadly to mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).

Depending on how we interact with you, such as if you are a business contact, customer, prospective customer, dealer, sales agent, coach, claimant, insured, or website visitor, we have collected the following types of Personal Information from individuals within the last 12 months:

• Registration Information: Information you provide during account registration or when purchasing our products or services, such as name, user ID, password, date of birth, contact information (like your email or phone number), billing address, shipping address, or payment information.
• Self-Reported Information: Information you provide to us including your gender, health-related information, your employer or former employers, your education history, or anything else you provide to us within our services.
• User Content: Information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials, other than Self-Reported Information, generated by you and transmitted, whether publicly or privately, to us or through our products and services. For example, User Content includes comments posted on our social media accounts or messages you send through our services.
• Information from External Sources: Information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our products and services, increase the appeal and relevance of advertising, and to prevent or detect fraud. We also may obtain device and browsing information, from third parties for marketing purposes.
• Web-Behavior Information: Information on how you and your devices use our Site and web-based services is collected through log files, cookies, web beacons, and similar technologies (like device information, device identifiers, IP address, browser type, location, domains, page views).

How We Collect Personal Information About You

The information we collect about you comes from a number of sources and in a variety of ways, including information you provide to us, information we obtain from other sources including third parties (described below), information we automatically collect, and information we derive or infer about you. The Personal Information we collect depends on how you interact with us and which products we are providing or services we are performing.

Personal Information You Provide to Us

You may choose to provide Personal Information to us voluntarily, for example:

• You may provide information when you complete forms or surveys; create an account; search for, register for, subscribe to, purchase, or renew a product or service; correspond with us by phone, email, text messaging or through our interactive chat functions, or otherwise; or upload or share photos or post other digital content through one of our Sites, applications, or interactions with our social media accounts.
• You may be required to provide Personal Information if you buy certain products or services or to see if you are eligible for certain services. You may elect not to provide this information under these circumstances, but we may be unable to meet your request for products or services if you do so.

Personal Information Collected from Other Sources

We may also collect Personal Information from our service providers, third parties, or public information sources, including:

• Through marketing, sales generation, and recruiting partners.
• Through social media networks, such as Facebook, YouTube, LinkedIn, and X (the social media platform formerly known as Twitter).
• From our vendors, service providers, and business partners.
• From government agencies and others who release or publish public records.
• From credit bureaus or other similar agencies.
• From professional or industry organizations and certification / licensure agencies that provide or publish Personal Information related to you.

Personal Information Collected Automatically

We may also automatically collect Personal Information by (technologically) observing your interactions with our Site. We collect this information through the use of “cookies” and similar tracking technologies. You can learn more about this at our Cookie Notice.

How We Use Your Personal Information

We may use the Personal Information we collect for one or more of the following purposes:

• Run and manage our business in the ordinary course and keep our records up to date.
• Provide you with products and services.
• Fulfill the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. We may also save your information to facilitate the provision of additional services.
• Process your requests, purchases, and payments, and provide related products or services.
• Provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• Create, maintain, customize, and secure your account with us.
• Provide you with notices about your account/subscription, including expiration and renewal notices.
• Notify you about changes to our Site, products, or services.
• Communicate with you regarding developments within our business or other products or services we or our business partners may offer that may be of interest to you. If you do not want to receive publications or details of events that we consider may be of interest to you, you may let us know by clicking on the unsubscribe link in electronic marketing communications.
• Provide, support, improve, and develop our Site, products, and services.
• Personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
• For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
• Carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collection.
• Help maintain the safety, security, and integrity of our Site, products and services, databases, other technology assets, and business.
• Prevent fraud.
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.
• In any other way we may describe when you provide the Personal Information.

We also may use the Personal Information about your online activities over time and across third-party websites or other online services (behavioral tracking). Visit the Cookie Notice for information on how you can opt out of behavioral tracking on our Site and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

We will not collect additional types of Personal Information or use your information for any materially different, unrelated, or incompatible purposes without providing you notice unless permitted or required by law.

Disclosing Your Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Notice, we may disclose your Personal Information to:

• Any Southwestern subsidiary or related entity.
• Business partners, suppliers, service providers, subcontractors, and other third parties we use to support our business.
• Third parties to market their products or services to you if you have consented to/not opted out of these disclosures.
• Advertisers and advertising networks that require the information to select and serve relevant ads to you and others.
• Credit reference agencies when required to assess your credit score before entering into a contract with you.
• Law enforcement officials or regulatory authorities.
• Any third party with your consent.

We may disclose your Personal Information for the following purposes:

• Provide you with our products and services.
• Fulfill the purpose for which you provide it.
• Comply with any court order, law, subpoena, or other legal process, including to respond to any government or regulatory request.
• Enforce or apply any agreements between Southwestern and you or any other third party.
• Protect and defend our rights, safety, and property, our Site, the users of our Site, our customers, Southwestern, and others.
• When we otherwise believe in good faith that the provision of such information is required or permitted by law, such as in connection with the investigation or assertion of our legal defenses or for our compliance matters.
• Complete a sale or transfer of some or all of our assets or equity, or merger, reorganization, dissolution, or similar event involving our business (including in contemplation of such transactions). Your information may be among the shared or transferred business assets. If such transfer is subject to any mandatory restrictions under applicable laws, we will comply with those restrictions.
• Any other purposes that we disclose when you provide the information or subject to any additional privacy notices we issue.

We disclose some of your Personal Information for cross-context behavioral advertising. You can learn more about this at our Cookie Notice.

Your Rights and Choices

We strive to provide you with choices regarding your Personal Information.

We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. If you would like more information about this, please see our Cookie Notice.
• Marketing, Email, and SMS. Southwestern respects the rights users give us when opting to receive email and SMS communications and enforces internal policies to preserve those rights. It is our objective to retain the long-term ability to continue to communicate with our users. If you do not want Southwestern or Southwestern’s representatives to contact you, you may “opt out” of this preference at any time by unsubscribing or contacting Southwestern directly. Please see the Contact Information section below for instructions on how to reach us. You’ll always have the option to opt back in.
• Opting Not to Provide Personal Information. If you choose not to provide Personal Information, you can still visit most areas of Southwestern’s Site and may be able to obtain certain Southwestern products or services; however, you will not have access to areas of the Site or products or services that require Personal Information.

Depending on your state or country of residence, you may have additional Personal Information rights and choices. Please see the US Privacy Notice and EEA, UK, and Switzerland Privacy Notice for more information.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.

Children’s Data Protection and Parental Responsibility

The age that individuals are treated as minors is not consistent among privacy laws. To streamline our practices, Southwestern offers the additional privacy rights afforded to minors related to their Personal Information to all applicable individuals younger than 16. For more information, see the US Privacy Notice.

As part of our services, Southwestern makes available services, subscription sites, and online stores that may be of interest to children. WE DO NOT ALLOW CHILDREN TO REGISTER THEMSELVES FOR THESE SERVICES AND WILL NEVER ASK CHILDREN UNDER 16 TO DIRECTLY PROVIDE PERSONAL INFORMATION, NOR DO WE INTEND THAT THE SERVICES BE UTILIZED BY CHILDREN UNDER 16 WITHOUT ADULT SUPERVISION. It is solely the responsibility of the child’s parent(s) or lawful guardian(s) to provide Southwestern with Personal Information that we may store and use about their children in registering and maintaining accounts on our Site and using our products and services. Southwestern will never receive or accept Personal Information about a child from any school or educational institution with which we may be partnered.

When we collect Personal Information pertaining to children under 16 years old, we take steps to protect children’s privacy, including:

• In accordance with applicable law and our practices, obtaining confirmation regarding the child’s age and verifiable consent from parents/guardians prior to our collection, use, or disclosure of any Personal Information about children under 16.
• Limiting our collection of Personal Information from children to no more than is reasonably necessary for us to provide our Site, products, or services.
• Giving parents/guardians the ability to request access to Personal Information that we have collected from their children and the ability to request that such Personal Information be changed or deleted.
• Keeping this Privacy Notice updated so that parents/guardians can read about our information practices regarding children’s information, what we collect, and how.

We strongly advise children and parents to never provide any Personal Information in their usernames.

Parents may at any time contact us to request a copy of the Personal Information that we have stored pertaining to their children and may withdraw their consent to our usage of such information and/or the deletion of such information at any time. To register children for our services, parents may be asked to provide correct information about their children, including the child’s name, email address, username, age, telephone number, and password, if necessary to gain access to the subscribed service. IT IS SOLELY THE RESPONSIBILITY OF PARENTS AND/OR GUARDIANS TO MONITOR AND MANAGE THEIR CHILDREN’S USE OF OUR SERVICES.

Data Security

We have implemented measures designed to secure your Personal Information, including NPI, from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you or where you have chosen a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information when it is transferred through or stored on the internet. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site, services, or products.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Southwestern collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under the law, please do not hesitate to contact us at:

Form: here

Phone: (888) 551-5901

Postal Address:

c/o the Vice President of I.T. of the Southwestern Family of Companies
2451 Atrium Way
Nashville, Tennessee 37214

If you need to access this Privacy Notice in an alternative format due to having a disability, please contact us through the form above.