Privacy Policy

This Privacy Policy describes how Stem Sales Training ("Stem," "we," "us," or "our"), a Pala company, collects, uses, discloses, and safeguards your information when you visit our website, contact us, or purchase or participate in our sales training, coaching, and related services (collectively, the "Services"). By using our Services, you agree to the practices described in this policy.

1. Information We Collect

We collect information in the following ways:

1.1 Information You Provide Directly

• Contact details — name, email address, phone number, company name, and job title when you complete a form, request information, or contact us.
• Account and program data — information you share when enrolling in training, coaching, or team programs.
• Payment information — billing details processed through our third-party payment providers. We do not store full card numbers on our servers.
• Communications — the content of emails, messages, surveys, and feedback you send to us.

1.2 Information Collected Automatically

• Usage data — pages visited, time spent, links clicked, and referring URLs.
• Device and technical data — IP address, browser type, operating system, and device identifiers.
• Cookies and similar technologies — used to operate the site, remember preferences, and measure performance (see Section 6).

1.3 Information From Third Parties

We may receive information about you from social media platforms, analytics providers, payment processors, and business partners, consistent with their own privacy policies and your settings on those services.

2. How We Use Your Information

We use the information we collect to:

• Provide, operate, deliver, and improve our Services and training programs.
• Process transactions and send related confirmations, invoices, and reminders.
• Respond to inquiries, provide support, and communicate about your account.
• Send administrative updates and, where permitted, marketing communications you can opt out of at any time.
• Personalize content and measure the effectiveness of our programs and website.
• Detect, prevent, and address fraud, security issues, and technical problems.
• Comply with legal obligations and enforce our agreements.

3. Legal Bases for Processing

Where applicable law (such as the GDPR) requires it, we process personal data on the following bases: your consent; performance of a contract with you; compliance with a legal obligation; and our legitimate interests in operating and improving our business, provided those interests are not overridden by your rights.

4. How We Share Your Information

We do not sell your personal information. We may share it with:

• Service providers — vendors who perform services on our behalf, such as payment processing, hosting, email delivery, and analytics, under contractual confidentiality obligations.
• Business transfers — in connection with a merger, acquisition, financing, or sale of assets.
• Legal and safety — when required by law, subpoena, or to protect the rights, property, or safety of Stem, our clients, or others.
• With your consent — when you direct us to share your information.

5. Cookies and Tracking Technologies

We and our partners use cookies, pixels, and similar technologies to keep the site functioning, remember preferences, analyze traffic, and understand engagement. You can control cookies through your browser settings; disabling some cookies may limit certain features. Where required, we will request your consent before placing non-essential cookies.

6. Data Retention

We retain personal information for as long as needed to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When information is no longer required, we securely delete or anonymize it.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your Privacy Rights

Depending on your location, you may have the right to:

• Access, correct, or update the personal information we hold about you.
• Request deletion of your personal information.
• Object to or restrict certain processing, including direct marketing.
• Request portability of your data.
• Withdraw consent where processing is based on consent.

California residents may have additional rights under the CCPA/CPRA, including the right to know, delete, correct, and opt out of the sale or sharing of personal information. We do not sell personal information. To exercise any right, contact us using the details in Section 12. We will not discriminate against you for exercising your rights.

9. International Data Transfers

We operate globally and may transfer, store, and process your information in countries other than your own. Where required, we use appropriate safeguards, such as standard contractual clauses, to protect your information during such transfers.

10. Children's Privacy

Our Services are intended for individuals 18 years of age and older. We do not knowingly collect personal information from children. If you believe a child has provided us information, please contact us and we will take steps to delete it.

11. Third-Party Links

Our website may contain links to third-party sites and social media platforms that we do not control. This policy does not apply to those sites, and we encourage you to review their privacy practices.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. Material changes will be communicated through the website or other appropriate means. Your continued use of the Services after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

If you have questions, requests, or concerns about this Privacy Policy or our data practices, contact us at:

Stem Sales Training (a Pala Company)
818investmentholdings@gmail.com