Privacy Policy

Cumbo, Inc., a New York corporation doing business as Message & Method (“Message & Method,” “we,” “us,” or “our”), provides public-speaking education through self-directed online courses, Guided Cohorts, Private Coaching, and related services. This Privacy Policy explains how we collect, use, disclose, and retain personal information through messageandmethod.co, course and account areas, enrollment and payment processes, support, live services, and related websites, tools, and communications.

1. Information we collect

Depending on how you interact with us, we may collect:

• Contact and account information, such as your name, email address, telephone number, mailing address, username, password-related account records, other authentication information, employer, organization, professional role, and communication preferences.
• Purchase and transaction information, such as the offering purchased, price, payment schedule, billing and order status, receipts, refund records, chargeback or dispute information, and checkout acknowledgments. Payment-card, bank-account, and other payment credentials are processed by the payment provider made available at checkout and are not intended to be stored directly by Message & Method.
• Course and participation information, such as enrollment and activation dates, course-progress and lesson-completion records, assessment results, Learning Plan activity, tool use, written responses, scripts, outlines, plans, reflections, journal entries, and other learner-created work.
• Recordings and live-session information, such as speaking-task recordings submitted for coaching, course participation, or a refund request; recordings of Guided Cohorts or Private Coaching sessions when recording has been disclosed or authorized; attendance; chat; and feedback.
• Support, inquiry, and communications information, including messages, requests, consultation or meeting information, information about your goals or service needs, accessibility requests, survey responses, and records of our response.
• Technical and usage information, such as IP address, browser and device information, log data, referring and visited pages, interactions with site and course features, errors, cookies, local storage, analytics events, and similar information.
• Information provided by another purchaser or organization, such as when an employer, client, or sponsoring organization purchases or arranges access for a participant. We may receive contact, enrollment, role, and administrative information from that organization and rely on it to provide the requested service.

Unless a written agreement and the applicable system expressly permit it, please do not submit payment-card data, government identification numbers, protected health information, export-controlled information, trade secrets, or confidential information belonging to another person or organization.

2. How we use information

We may use personal information to:

• process purchases, activate and administer accounts, and provide the requested offering;
• operate course tools, save learner work, and display prior responses where the program uses them in later activities;
• provide technical support, coaching, feedback, accessibility assistance, and customer service;
• administer payment installments, refunds, disputes, security reviews, and policy compliance;
• review learner-created work when reasonably necessary to provide coaching or support, verify a refund request, troubleshoot or secure the service, administer the program, or identify recurring usability and instructional issues;
• communicate about receipts, access, security, schedules, support, policy changes, and other transactional or administrative matters;
• send marketing communications when you have chosen to receive them or when otherwise permitted by applicable law, subject to available unsubscribe controls;
• understand service use, maintain performance, prevent abuse, secure accounts, and improve content, features, and tools;
• comply with tax, accounting, legal, regulatory, insurance, and recordkeeping obligations; and
• establish, exercise, or defend legal claims and enforce our agreements.

Where practical, we minimize, aggregate, or de-identify learner content used for broader internal evaluation.

Message & Method does not sell personal information or learner-created work. We do not use the substance of learner scripts, journals, assessments, recordings, or other course work for targeted or behavioral advertising.

3. Learner work and authorized access

Authorized administrators, coaches, support personnel, and service providers performing necessary technical functions may be able to access learner-created materials, assessment results, course activity, completion records, scripts, plans, reflections, journal entries, and recordings. Access may occur when reasonably necessary to provide coaching or support, verify a completion-based refund request, administer or secure the service, investigate a problem, maintain data, or improve the operation and usability of course tools. Access is limited to legitimate operational purposes and does not authorize public or promotional use.

Public, testimonial, or marketing use of a learner’s name, image, voice, recording, statement, or work will require separate permission appropriate to the intended use. Declining that permission does not affect ordinary participation.

4. Organizational and sponsored participation

When an employer or other organization purchases or sponsors access, we may provide administrative information such as seat assignment, enrollment status, attendance, course progress, or completion status to the extent disclosed as part of the arrangement.

We do not ordinarily provide the substantive contents of private journals, scripts, assessments, reflections, recordings, or coaching communications to a sponsoring organization unless the participant authorizes the disclosure, the engagement expressly provides otherwise, or disclosure is required or permitted by law.

5. Service providers and other disclosures

We may disclose personal information to service providers that support website hosting, content delivery, course and account administration, payment processing, tax and accounting functions, email and communications, customer relationship management, forms, scheduling, live meetings, video hosting, file storage, analytics, security, customer support, accessibility, professional advice, and other business operations. These providers may receive personal information appropriate to the services they perform and are expected to process it subject to applicable contractual and legal obligations.

We may also disclose personal information:

• to an employer, client, or sponsoring organization as described in this policy and the applicable engagement;
• when you direct or authorize the disclosure;
• to investigate fraud, misuse, infringement, security incidents, or threats;
• when reasonably necessary to protect the rights, safety, or property of Message & Method, our users, another person, or the public;
• to comply with applicable law, legal process, or a valid governmental request; and
• in connection with a merger, financing, reorganization, sale, or transfer of all or part of the business, subject to applicable legal obligations.

During a Guided Cohort, participant names, images, voices, chat messages, spoken contributions, and other material shared in the group may be visible or audible to other participants. When a cohort session is recorded, the recording may be made available to authorized members of that Guided Cohort as disclosed before enrollment or recording. Confidentiality requirements may reduce risk, but we cannot guarantee how another participant will handle information shared during a group experience.

6. Third-party websites and services

Our website, communications, or course materials may contain links to websites or services operated by other organizations. When you follow a link to a third-party website or service, that organization’s privacy practices and terms apply. Message & Method does not control and is not responsible for the privacy, security, content, or practices of third-party websites or services. We encourage you to review the privacy information provided by those organizations.

7. Cookies and similar technologies

We and service providers supporting the website may use cookies, local storage, pixels, embedded scripts, server logs, and similar technologies to operate and secure the website; prevent fraud and automated abuse; maintain sessions and account access; remember settings; support forms, scheduling, payments, and communications; display embedded media; measure performance and usage; identify technical problems; and understand how website and course features are used.

Information collected through these technologies may include IP address, browser and device information, identifiers, referring and visited pages, approximate location derived from IP address, interactions with website features, and dates and times of access.

Third-party services embedded in or connected to the website may set or access their own cookies or similar technologies according to their privacy practices. These services may include hosting and security services, forms and communication tools, video and meeting platforms, learning-management functions, analytics services, and payment services.

We do not intend for advertising, analytics, heatmap, or session-replay technologies to collect the contents of learner scripts, journals, assessments, recordings, refund evidence, private coaching communications, or other substantive learner work. We configure and review such technologies with the goal of limiting collection from authenticated course and account areas.

Most browsers allow you to block or delete certain cookies. Restricting cookies or similar technologies may interfere with login, forms, scheduling, video playback, payment, security checks, saved preferences, or other website functions. Where we provide a privacy-control interface, the choices available through that interface will be described there.

8. Email and other communications

We may use third-party communication providers to deliver transactional, administrative, and marketing messages. These providers may process information such as your name, email address, communication preferences, list membership, message content, delivery status, bounce and complaint information, unsubscribe status, and interactions with messages.

Transactional and administrative communications may include receipts, account and access instructions, security notices, enrollment information, schedules, support responses, accessibility communications, refund administration, and material service or policy changes. These communications may be necessary to provide an offering, respond to a request, or administer an active account or transaction.

Marketing communications are optional. We send marketing email when you have chosen to receive it or when otherwise permitted by applicable law. You may unsubscribe through the link in a promotional message or through another unsubscribe method we provide. Withdrawing from marketing communications does not prevent necessary transactional or administrative messages.

Communication providers may process delivery, bounce, complaint, unsubscribe, open, and link-interaction information to deliver messages, maintain suppression records, troubleshoot delivery, evaluate communications, and operate automated workflows. Open and interaction records may be incomplete or inaccurate because of privacy protections, image blocking, automated security systems, and other email-service behavior.

We may retain records of consent, subscription status, unsubscribe requests, delivery problems, and related communications as reasonably necessary to honor preferences, demonstrate compliance, prevent unwanted messages, and administer our services.

9. Retention and deletion

We retain personal information for periods reasonably necessary to provide the service, administer the relationship, maintain transaction and consent records, comply with tax and legal obligations, resolve disputes, prevent fraud, enforce agreements, and maintain security. Different categories of information may have different retention periods.

The program is not intended to serve as the only backup location for important learner work. Participants should use available export options and retain permitted copies of material they need to preserve. An export function does not guarantee that all information will remain continuously available or recoverable. Backup copies may remain for a limited period after active information is removed and may not be immediately accessible or separately removable.

Requests to delete information may be limited by transaction, tax, accounting, refund, chargeback, consent, security, fraud-prevention, dispute, legal-hold, backup, and other applicable legal or operational requirements. We may also retain information that has been aggregated or de-identified so that it no longer reasonably identifies an individual.

10. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No website, transmission, storage system, or security measure is completely secure. You are responsible for protecting your account credentials and promptly reporting suspected unauthorized access.

If we become aware of a security incident involving personal information, we will investigate and provide notices to affected individuals, regulators, or others when required by applicable law.

11. Your choices and privacy requests

Depending on your location and applicable law, you may have rights to request access to, correction of, deletion of, or portability of personal information; information about how personal information has been collected, used, or disclosed; or an appeal of a decision concerning a privacy request. You may also have the right to opt out of certain sales, sharing, targeted advertising, or profiling activities.

We may take reasonable steps to verify your identity before responding to a request. An authorized agent may be required to provide evidence of authority to act on your behalf.

We will not unlawfully discriminate against you for exercising a privacy right available to you under applicable law.

Submit privacy requests to [email protected]. We will respond as required by applicable law. We may deny or limit a request when an exception applies and will provide an explanation when required.

12. Adults only and geographic availability

The offerings are intended for adults age 18 or older and are not directed to children. Do not create an account, enroll, or submit personal information if you are under 18.

The initial commercial offering is intended for customers located in the United States. If you access the website or provide information from another country, your information may be transferred to and processed in the United States, where privacy laws may differ from those in your location. Availability of an offering in a particular location does not mean that we represent that the offering or our privacy practices satisfy every law outside the United States.

13. Artificial intelligence and automated tools

At the effective date of this policy, participant-facing course tools do not send learner-entered content to a third-party generative-artificial-intelligence service. Certain tools may use programmed logic, rules, or other automated processing to generate or display results.

If we introduce a feature that sends personal information or learner content to an external artificial-intelligence provider, we will provide appropriate notice describing the feature’s purpose, the categories of information involved, the provider’s role, available choices, and relevant confidentiality considerations. We will not use learner content to train a public or shared generative-AI model without separate notice and an appropriate legal basis or permission.

14. Changes to this policy

We may update this Privacy Policy to reflect changes in our services, technology, operations, or legal obligations. We will revise the effective date when the policy changes and provide additional notice of material changes when required by law or when otherwise appropriate.

15. Contact us

Privacy questions and requests may be sent to [email protected].

Legal notices may be sent to [email protected].

Message & Method
Cumbo, Inc.
PO Box 119
Clarence Center, NY 14032-0119