The following Privacy Policy governs the information collection practices of VANTA VENTURES, LLC, doing business as Symposia ("we" or "us"), including the practices of Symposia Academia, the career school operated by Vanta Ventures, LLC and approved and regulated by the Texas Workforce Commission, Career Schools and Colleges, Austin, Texas, under School Certificate No. 6665.

This policy outlines the types of information that we gather about you while you are using the symposia.com website (the "Site"), and the ways in which we use this information. It also describes, in the "Student Records" section below, how we handle information collected from applicants and enrolled students, including information collected offline in the course of admission, enrollment, and instruction.

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we'll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

Contact for privacy matters — Online Privacy Coordinator:

Symposia AcademiaAttn: Online Privacy Coordinator5900 Balcones Drive #18351Austin, Texas 78731Phone: 1 (713) 367-1783Email: contact@symposia.comHours: Monday – Friday, 8:00 AM – 5:00 PM (Central Time)

How We Collect and Use Information

We may collect and store personal or other information that you voluntarily supply to us online while using the Site (e.g., while on the Site or in responding via email to a feature provided on the Site). We only contact individuals who specifically request that we do so, or in the event that they have signed up to receive our messaging, attended one of our events, inquired about admission, or have purchased one of our programs or products. We collect personally identifying information from our users during online registration, online purchasing, and the admissions and enrollment process. Generally, this information includes name and email address for registration or opt-in purposes; name, postal address, and payment information when registering for our events or purchasing our products; and the additional categories described under "Student Records" below when you apply to or enroll in a program.

We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site. We also may use a standard feature found in browser software called a "cookie" to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before.

The Site also may use web beacons (single-pixel graphic files also known as "transparent GIFs") to access cookies and to count users who visit the Site or open HTML-formatted email messages.

How we use marketing and Site information

We use the information we collect from you while you are using the Site to operate and improve the Site; to respond to your inquiries; to process transactions; to customize features and advertising that appear on the Site; and to make other offers available to you via email, direct mail or otherwise.

We may provide information collected through the Site to third parties acting on our behalf, such as service providers, contractors, payment processors, hosting and analytics providers, and advertising platforms, for the purposes described in this policy. We do not sell student education records, and we do not sell or share information collected in the course of admission or enrollment for third-party marketing purposes.

If you do not wish information collected through the Site to be used for marketing purposes, you may opt out at any time by emailing contact@symposia.com with the subject line "Privacy — Marketing Opt-Out," by writing to the Online Privacy Coordinator at the address above, or by clicking the unsubscribe link in any message we send you. Opting out of marketing does not affect communications necessary to administer your enrollment.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online — for example on message boards, web logs, through email, in student community spaces, or in chat areas — that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Some of our third-party advertisers and ad servers that place and present advertising on the Site also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure and research the advertisements' effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third party's privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party's use of cookies or web beacons or use of your information, you should visit that party's website and review its privacy policy.

The Site also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services.

We may also make some content, products and services available through our Site or by emailing messages to you through cooperative relationships with third-party providers, where the brands of our provider partner appear on the Site in connection with such content, products and/or services. We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which case the privacy policy of our provider partner may apply to the provider partner's use of your information. The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law, to respond to lawful requests from regulators including the Texas Workforce Commission, or to protect the rights, property or safety of users of the Site or the public.

Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets. Student education records transferred in connection with any such transaction remain subject to the protections described in this policy and to applicable law and Texas Workforce Commission requirements.

Student Records

This section applies to applicants and enrolled students of Symposia Academia. It covers information collected both online and offline in the course of admission, enrollment, instruction, and student support.

What we collect

• Admission and eligibility records — application information; proof of age (applicants must be at least 18 years of age at the time of enrollment); high school diploma, GED, or equivalent documentation and transcripts; and the results of any non-binding skills assessment used for cohort placement.
• Enrollment records — the signed Enrollment Agreement, program and modality selected, cohort start date, tuition and fee schedule, and any scholarship award and its terms.
• Financial records — payments made, balance owed, payment method, refund calculations and determinations, and, where applicable, financing arrangements with a third-party lender.
• Academic records — attendance in live sessions and recorded-session views, coursework and assignment submissions, capstone project materials, grades and GPA, progress evaluations, probation and termination notices, leave-of-absence requests, and completion credentials.
• Support and conduct records — Success Coach communications, grievances filed and their resolution, accommodation requests, and conduct or academic integrity matters.
• Learning platform data — login records, module completion, activity in the LMS and simulated GRC platform, and participation in student community spaces.

How we use it

We use student records to deliver instruction and evaluate academic progress; to administer attendance, grading, probation, termination, and graduation decisions; to process tuition, payments, and refunds; to provide Success Coach and career services support; to respond to grievances; to maintain the institutional records required of a Texas career school; and to comply with law and with Texas Workforce Commission reporting and audit obligations.

Who we disclose it to

We disclose student records only as follows:

• To the student, on request.
• To the Texas Workforce Commission, Career Schools and Colleges, and to other regulators, auditors, and accrediting or approving bodies, as required for oversight, reporting, complaint resolution, or audit.
• To a third-party lender, loan servicer, or financing partner where the student has financed tuition through that provider — limited to enrollment status, start and withdrawal dates, program cost, amounts paid, and refund determinations, as required to administer the financing arrangement. The provider's own privacy policy governs its handling of that information.
• To an employer, workforce agency, or other sponsor that is paying for the student's program, limited to enrollment status and progress reporting, as contemplated by Section 9 of the Academic Catalog, and to the extent the student has authorized that reporting.
• To service providers that host the LMS, process payments, deliver email, or otherwise support institutional operations, under contractual obligations to protect the information.
• In response to a subpoena, court order, or other lawful legal process, or where disclosure is necessary to protect the rights, property, or safety of any person.
• Otherwise, with the student's written authorization.

We do not sell student education records. We do not disclose student education records to advertisers or data brokers, and we do not use them to build advertising profiles.

Retention and access

Student records are retained in accordance with the recordkeeping requirements applicable to Texas career schools and colleges and for such additional period as is necessary to respond to transcript requests, verify completion, and resolve disputes. Students may request a copy of their own records, or request correction of factual errors in those records, by writing to contact@symposia.com, Attention: School Director. We will respond within a reasonable period and will confirm identity before releasing records.

Requests to correct an academic evaluation — a grade, a progress determination, or an attendance record — are handled as academic matters under the Student Grievance Policy in Section 14 of the Academic Catalog rather than as privacy requests.

How We Store and Protect Your Information

Marketing and mailing list information is stored at the list server that delivers symposia.com content and messaging, and can be accessed only by those who help manage those lists in order to deliver email to those who would like to receive symposia.com material.

Student records are maintained in the institution's Learning Management System, student information systems, and administrative files, and are accessible only to staff and faculty with a legitimate institutional need for access.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

All of the messaging or emails that are sent to you by symposia.com include an unsubscribe link. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link found in every communication that we send you. Administrative and academic communications relating to an active enrollment are not marketing messages and will continue for the duration of your enrollment.

Google Analytics

We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies or other third-party identifiers together, to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The "Remarketing" feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.

You can opt out of Google's use of cookies by visiting Google's ad settings, and you may opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

We do not use student education records as an audience source for remarketing or advertising.

Facebook

As advertisers on Facebook and through our Facebook page, we (not Facebook) may collect content or information from a Facebook user, and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook's Data Use Restrictions.

Any ad data collected, received or derived from our Facebook ad ("Facebook advertising data") is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit their use of all of that information, and keep it confidential and secure.

We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers' campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.

We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.

We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

Your Privacy Rights — U.S. State Residents

Depending on your state of residence, you may have the right to request access to the personal information we hold about you, to request correction of inaccurate personal information, to request deletion of personal information, to obtain a portable copy of it, and to opt out of targeted advertising or the sale of personal information. You may also have the right to appeal a decision we make regarding such a request.

To exercise any of these rights, contact contact@symposia.com with the subject line "Privacy Rights Request," or write to the Online Privacy Coordinator at the address above. We will confirm your identity before acting on a request. We will not discriminate against you for exercising these rights.

Certain records — including student education records we are required to retain under Texas career school recordkeeping requirements, and records we must keep to comply with tax, audit, or legal-hold obligations — cannot be deleted on request. Where we cannot honor a deletion request for that reason, we will tell you why.

General Data Protection Regulation (GDPR)

The GDPR is intended to protect the data of European Union (EU) citizens.

As a company that markets its site, content, products and/or services online, we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us in the course of your use of our site, content, products and/or services is governed by the GDPR, we will abide by the relevant portions of the Regulation.

If you are a resident of the European Economic Area (EEA), or are accessing this site from within the EEA, you may have the right to request access to, correction of, deletion of, portability of, and restriction of or objection to processing of your personal data. This includes the "right to be forgotten."

To make any of these requests, please contact our GDPR contact at contact@symposia.com.

Children's Privacy Statement

This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.

Symposia Academia programs are open only to applicants who are at least 18 years of age at the time of enrollment. This Site is not directed to children under the age of thirteen, and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Site. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Site, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.

Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third parties.

We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site. Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site's online activities on providing personally identifiable information.

Disclaimer

This policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our website and revise the Effective Date above.

Symposia Academia does not guarantee employment or placement upon completion of any program. Employment outcomes depend on individual factors including qualifications, job market conditions, geographic location, and individual effort. Any student outcomes or testimonials presented on this website reflect the experience of the individuals described and are not a representation of typical results.

Approved and Regulated by the Texas Workforce Commission, Career Schools and Colleges, Austin, Texas. School Certificate No. 6665.

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