Effective date January 30, 2026
UCT Holding LLC, doing business as Sonderberg Research, together with its websites, landing pages, opt in pages, newsletters, communities, products, calls, consultations, and related services, the Services, respects your privacy.
This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you access or use the Services.
By accessing or using the Services, you acknowledge this Privacy Policy.
The Services are provided by UCT Holding LLC, doing business as Sonderberg Research, the Company, we, us, or our.
Contact email: [email protected]
This Privacy Policy applies to personal information we collect through:
- our websites, landing pages, and opt in pages
- email newsletters and marketing communications
- lead forms, applications, quizzes, surveys, and booking forms
- purchases, subscriptions, and payment flows
- communities, chats, comments, and support channels
- calls, meetings, consultations, trainings, and recordings
- cookies, pixels, tags, APIs, web beacons, and similar technologies
- third party tools we use to run, measure, and improve the Services
Depending on how you interact with us, we may collect the following categories of personal information.
A. Identifiers and contact information
Examples include:
- name
- email address
- phone number
- billing address
- username or account identifier
- IP address
- device identifiers
- browser identifiers
- online identifiers
B. Commercial and transaction information
Examples include:
- products or services purchased
- subscription status
- payment status
- order details
- billing records
- customer history
Payment card details are generally processed by third party payment processors and are not stored by us except as reasonably necessary for records, fraud prevention, customer support, or legal compliance.
C. Internet, device, and usage information
Examples include:
- browser type
- operating system
- device type
- referral URL
- page views
- button clicks
- session data
- engagement data
- time stamps
- ad interactions
- approximate location derived from IP address
- cookie and pixel data
D. Application, profile, and questionnaire information
Examples include:
- information you submit in applications, intake forms, or booking forms
- goals, preferences, interests, and challenges
- your stated experience level
- portfolio range or net worth range if you choose to provide it
- responses relevant to whether our Services are a fit for you
E. Communications and support information
- emails
- direct messages
- support requests
- call notes
- community posts
- comments
- feedback
- testimonials
- survey responses
F. Audio, video, and recorded content
Where permitted by law, we may record calls, sessions, trainings, livestreams, and events in which you participate.
We may collect personal information:
- directly from you
- automatically from your device or browser
- from cookies, pixels, tags, APIs, and analytics tools
- from advertising and social media platforms
- from payment processors, scheduling tools, CRM systems, email platforms, hosting providers, and similar service providers
- from affiliates, referrals, and partners where applicable
- from publicly available sources where permitted by law
We may use personal information to:
- provide, operate, maintain, and improve the Services
- process transactions and subscriptions
- deliver content, products, newsletters, and community access
- schedule and conduct calls, trainings, and consultations
- respond to inquiries and provide customer support
- personalize the user experience
- measure traffic, engagement, campaign performance, and conversions
- run advertising campaigns and retargeting campaigns
- build or refine custom audiences and similar advertising segments
- understand which pages, offers, or campaigns perform best
- detect and prevent fraud, abuse, security incidents, and unauthorized access
- enforce our Terms of Service and other agreements
- comply with legal obligations
- protect our rights, users, property, and Services
We and our service providers may use cookies, pixels, tags, scripts, APIs, local storage, and similar technologies to collect information about your interactions with the Services.
These technologies may be used to:
- keep pages functioning properly
- remember preferences
- understand website traffic and user behavior
- measure ad performance and conversions
- attribute leads and purchases to campaigns
- improve our content, offers, and funnel performance
- retarget ads to people who visited our website or interacted with our pages
- suppress ads for existing customers or segment audiences for more relevant advertising
Meta Pixel and related Meta business tools
We may use Meta Pixel, and where enabled, related Meta business tools such as Conversions API, advanced matching, and custom audience tools.
These tools may collect or receive information such as:
- page visits
- URLs visited
- device and browser data
- IP address
- event data such as page views, lead submissions, registrations, purchases, or other conversion actions
- hashed identifiers, such as hashed email address or hashed phone number, where enabled and permitted
We may use this information to:
- measure the effectiveness of Meta ads
- understand actions taken after someone clicks or views an ad
- retarget visitors on Meta platforms
- create custom audiences
- create lookalike or similar audiences
- optimize campaigns for conversions
Information collected through these tools may be disclosed to Meta in accordance with Meta’s business tools terms and your interactions with our Services.
Consent and control
Where required by law, we will request consent before placing non-essential cookies or using non-essential tracking technologies.
You can manage cookies through:
- our cookie banner or consent tool, where available
- your browser settings
- applicable privacy controls described in the Your Privacy Choices section below
Please note that disabling certain cookies may affect some site functionality.
7. Email marketing and communications
If you opt in, request information, purchase a product, apply for a program, book a call, or otherwise engage with the Services, we may send you:
- transactional messages
- service messages
- newsletters
- educational content
- promotional and marketing emails
- follow up communications
You can unsubscribe from marketing emails at any time by using the unsubscribe link in the email or by contacting us at [email protected].
Even if you opt out of marketing communications, we may still send non-promotional messages related to your purchases, account, support, security, or legal notices.
We may disclose personal information to the following categories of recipients:
Such as providers of:
- hosting
- payments
- email delivery
- CRM and automations
- scheduling
- analytics
- customer support
- community platforms
- data storage
- security and fraud prevention
B. Advertising, analytics, and social media partners
We may disclose identifiers, online identifiers, device data, usage data, event data, and similar information to advertising and analytics partners to help us measure campaigns, attribute conversions, build audiences, retarget ads, and improve performance.
C. Contractors, advisers, and affiliates
We may disclose information to employees, contractors, consultants, accountants, lawyers, and affiliates where reasonably necessary.
We may disclose information if required by law, legal process, court order, regulatory request, or to protect rights, safety, security, or investigate fraud or abuse.
We may disclose information in connection with an actual or proposed merger, financing, acquisition, sale of assets, restructuring, or similar transaction.
However, because we use advertising and analytics tools, including Meta business tools, some disclosures of personal information may be considered sale, sharing, or use for targeted advertising under certain U.S. privacy laws.
This may include disclosure of the following categories:
- identifiers
- online identifiers
- internet or other electronic network activity information
- device information
- approximate geolocation derived from IP address
- commercial information
- inferences
This may be disclosed to categories of third parties such as:
- advertising networks
- social media platforms
- analytics providers
- marketing partners
We do not knowingly sell or share the personal information of consumers under 16 years of age.
We do not seek to collect sensitive personal information unless reasonably necessary for the Services, compliance, billing, fraud prevention, or where you choose to provide it.
Please do not submit highly sensitive information through ordinary web forms or email unless specifically requested and reasonably necessary.
We do not knowingly send prohibited sensitive data to Meta business tools.
If you submit comments, posts, messages, reviews, testimonials, or other content through the Services, we may use that information to operate, improve, and promote the Services, subject to our Terms of Service and applicable law.
12. Recordings
Where permitted by law, we may record calls, sessions, trainings, or events for delivery, quality, training, compliance, recordkeeping, and operational purposes.
By participating, you acknowledge that recordings may occur where lawful.
13. Data retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:
- provide the Services
- maintain business and tax records
- process payments and manage subscriptions
- document consents and privacy choices
- resolve disputes
- enforce agreements
- comply with legal obligations
- investigate fraud, abuse, chargebacks, and security incidents
Retention periods vary depending on the category of information, the nature of the relationship, legal requirements, and operational need.
We use reasonable administrative, technical, and organizational measures designed to protect personal information.
However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We may process and store personal information in the United States and other jurisdictions where we or our service providers operate.
If you access the Services from outside the United States, your information may be transferred to and processed in jurisdictions that may not provide the same level of protection as your home jurisdiction.
If you are located in the EEA, UK, or a similar jurisdiction, we may process personal information on one or more of the following legal bases:
- your consent
- performance of a contract or steps taken at your request before entering a contract
- our legitimate interests, where not overridden by your rights
- compliance with legal obligations
- establishment, exercise, or defense of legal claims
Where processing is based on consent, you may withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
Depending on your jurisdiction, you may have rights to:
- know whether we process your personal information
- access personal information
- correct inaccurate personal information
- delete personal information
- receive a portable copy of certain personal information
- opt out of sale, sharing, or targeted advertising
- object to certain processing
- limit certain uses of sensitive personal information where applicable
- withdraw consent where processing is based on consent
- not be discriminated against for exercising your rights
- appeal a denial of your request where applicable law provides that right
To exercise your rights, email [email protected] with the subject line Privacy Request.
We may need to verify your identity before completing certain requests.
Authorized agents may submit requests on your behalf where permitted by law.
18. Your Privacy Choices
You may exercise privacy choices in the following ways:
- use the cookie banner or consent tool on our website, where available
- adjust your browser settings
- use any available privacy controls on your device or browser
- email us at [email protected]
- use a recognized opt out preference signal where applicable, such as Global Privacy Control
Where required by applicable law, we will process recognized opt out preference signals for sale or sharing and targeted advertising as required.
Do Not Sell or Share My Personal Information
If applicable law gives you the right to opt out of sale or sharing, you may exercise that right by:
- clicking the Your Privacy Choices or Do Not Sell or Share My Personal Information link on our website, where available
- submitting a request to [email protected]
This section applies to residents of California and other states with similar privacy rights, to the extent applicable.
Categories of personal information collected in the preceding 12 months
Depending on how you interact with us, we may have collected the following categories in the last 12 months:
- identifiers
- contact information
- commercial information
- internet or electronic network activity information
- device information
- approximate geolocation derived from IP address
- application and profile information
- communications information
- audio or recorded information
- inferences
Categories of sources
We may collect these categories from:
- you directly
- your device or browser
- cookies, pixels, and analytics tools
- service providers
- advertising and social media partners
- affiliates or referrals
- publicly available sources
Business and commercial purposes
We collect and use personal information for the purposes described in Section 5 above.
Categories of personal information disclosed for business purposes in the preceding 12 months
We may have disclosed the following categories for business purposes:
- identifiers
- contact information
- commercial information
- internet or electronic network activity information
- device information
- application and profile information
- communications information
- audio or recorded information
- inferences
Categories of third parties to whom information may be disclosed
We may disclose relevant categories of personal information to:
- service providers and processors
- analytics providers
- advertising partners
- social media platforms
- payment processors
- scheduling and CRM providers
- legal advisers and compliance recipients
- business transferees in a transaction
Categories of personal information sold or shared in the preceding 12 months
We do not sell personal information for money.
We may have shared or made available the following categories for cross-context behavioral advertising or targeted advertising:
- identifiers
- online identifiers
- internet or electronic network activity information
- device information
- approximate geolocation derived from IP address
- commercial information
- inferences
Sensitive personal information
We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law unless specifically disclosed and permitted.
The Services are not directed to children under 18, and we do not knowingly collect personal information from anyone under 18.
If you believe a minor has provided personal information to us, contact us at [email protected] and we will take appropriate steps.
21. Third party websites and services
The Services may link to third party websites, payment providers, exchanges, brokers, wallets, platforms, software, or other services that we do not control.
We are not responsible for the privacy, security, or practices of third parties. Your use of third party services is subject to their own terms and policies.
We may update this Privacy Policy from time to time. The most current version will be posted on the website with the revised effective date or last updated date.
Questions, concerns, or privacy requests should be sent to:
UCT Holding LLC dba Sonderberg Research