Privacy Policy

Revised and effective September 18, 2026

This is the Privacy Policy of Envorso, LLC, a Delaware limited liability company (“Envorso”). We take your privacy seriously and we know you do too. This Privacy Policy (“Policy”) describes how we collect, process, and share Personal Data, your rights & choices, and other important information about how we handle your Personal Data.

SCOPE OF THIS POLICY

This Policy solely applies to your use of our website located at https://Envorso.com (the “Website”).

CONTROLLER

The party that determines the purposes and means for processing of your Personal Data (“Controller”) under this Policy is Envorso, LLC, who acts as a Controller when you engage with the Website.

Envorso, LLC processes your data for:

• Scheduling purposes, particularly setting up consultations with you, the prospective client;
• Communicating with you to discuss prospective business arrangements;
• Receiving data rights requests and fulfills requests with respect to the above processing controlled by Envorso;
• Establishing data retention periods for global customer records.

CONTACT

For General Inquiries, or to Opt-Out of Data Sharing; Limit uses of Sensitive Personal Data; Data Deletion, please refer to hello@envorso.com.

Otherwise, please contact us as follows:

Envorso, LLC,

4730 University Way NE, Ste 104, Unit 5568,

Seattle, Washington 98105

CATEGORIES AND SOURCES OF PERSONAL DATA

The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”).

Categories of Personal Data we Process

The categories of Personal Data we process may include:

Contact Data - Data we can use to contact you, specifically the email which you provide us.

Identity Data - Information such as your name email address, company name, role within your company, and IP Address.

User Content - Unstructured/free-form data that may include any category of Personal Data, e.g. data that you give us in free text fields such as comment boxes.

Sources of Personal Data We Process

We collect Personal Data from data you provide us, as well as are collected automatically by virtue of your access to the Website:

• Via the Contact Form available on the Website;
• Via communications with any of our public email addresses, e.g. hello@envorso.com, classes@envorso.com; and
• Automatically collected technical data from your visit to our Website.

DATA PROCESSING CONTEXTS / NOTICE AT COLLECTION

Contact us

We collect and process Identity Data, Contact Data, and User Content when you contact us, e.g. through the contact us form available on the Website, or otherwise through email messages sent to either hello@envorso.com, or classes@envorso.com.

We process this Personal Data to respond to your request, communicate with you, and to schedule a consultation.

PROCESSING PURPOSES

Business Purposes

We process Personal Data we hold for numerous business purposes, depending on the context of collection, your Rights & Choices, and our legitimate interests. We generally process Personal Data for the following “Business Purposes.”

Communications

We may process Personal Data with your consent, to communicate with you for the explicit purposes of scheduling consultations and carrying out these meetings.

Analytics and Site Improvement

We may use automatically collected technical about your visit to our Website, such as IP address, browser and device information, pages viewed, and information about how you interact with the Website, to understand how our Website is used, monitor its performance, identify technical issues, and improve its content, functionality and user experience.

Where this information constitutes personal data, we process it on the basis of our legitimate interests in operating, maintaining, securing and improving our Website and services (Article 6(1)(f) UK GDPR / EU GDPR, as applicable). We seek to use this information in a proportionate manner and to minimise the information used for analytics where reasonably possible. We do not use this analytics information to identify or profile individual visitors for advertising purposes.

Security and Incident Detection

We may process Personal Data in connection with our legitimate interest in helping to identify and prevent crime, prevent fraud, and verify or authenticate users/individuals. Similarly, we process Personal Data as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity.

DISCLOSURE/SHARING OF PERSONAL DATA

We may share Personal Data with the following categories of third-party recipients and/or for the following reasons. Note, some parties may be third party controllers who process data subject to their own privacy policy. These third parties are contractually prohibited from using or disclosing the information unless this is necessary to provide services on our behalf or to comply with legal requirements.

Affiliates - We may share your Personal Data with any of our current or future affiliated entities, subsidiaries (e.g., Envorso Ltd), and parent companies in order to streamline certain business operations.

Business Partners - In the legitimate interest of providing the best services possible to you, we may share your Personal Data with Business Partners with whom we share a close long-term relationship (e.g. Empwr AI, Inc.), for the purpose of shared go-to-market activities.

Service Providers - Any Personal Data you provide us with through either the contact form available on our Website, or through our email addresses, will by necessity be accessible by certain specific service providers (e.g. our customer relationship management provider, hosting and analytics provider, or email provider).

Successors - We may share Personal Data if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Lawful Recipients - In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person (such as where we reasonably believe the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety) or in such other circumstances as may be required or permitted by law. These disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

If you are located outside the US, we may transfer or process your Personal Data in the US, UK, European Union (EU) and European Economic Area (EEA), and other jurisdictions where Envorso or our service providers operate. With regard to transfers and processing of Personal Information from the EU and the UK, these transfers are governed by EU standard contractual clauses, UK IDTA to protect the security and confidentiality of personal information.

YOUR RIGHTS & CHOICES

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law.

Your Rights

You may have certain rights and choices regarding the Personal Data we process. See the “Regional Supplement” section below for rights available to you in your jurisdiction. To submit a request, contact our Data Privacy Team at hello@envorso.com. We verify your identity in connection with most requests, as described below.

Verification of Rights Requests

If you submit a request, we typically must verify your identity to ensure that you have the right to make that request, reduce fraud, and to ensure the security of Personal Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

We may require that you match personal information we have on file in order to adequately verify your identity. We may not grant access to certain Personal Data to you if prohibited by law.

Complain to your Local Supervisory Authority

You have the right to lodge a complaint with your local supervisory authority if you have any concerns about how we process your personal information. Though we ask you to first try to clarify your concerns with us, this does not in any way impede on your rights to contact your local supervisory authority at any time.

Your Choices

Request access to your personal data.

This enables you to receive a copy of the personal data we hold about you in a common, portable format, and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

If there is something about your particular situation which makes you want to object to processing as you feel there is an impact on your fundamental rights and freedoms, you have the choice to object to such processing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Withdrawing Your Consent/Opt-Out

You may withdraw any consent you have provided at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you or other services conditioned on your consent or choice not to opt-out.

Although we do not intend to use personal data other than in the manner we have disclosed to you, if personal data is to be used in a way not previously disclosed or shared with external parties not covered in this Privacy Policy, you will be provided the opportunity to opt-out prior to such use or sharing.

DATA SECURITY

We implement and maintain reasonable security measures to secure your Personal Data from unauthorized processing. While we endeavor to protect your Personal Data from unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others. When we process information, we may pseudonymize data (i.e. store or use Personal Data using only a non-identifying number) or anonymize data (i.e. store data in a form that is not linked to or reasonably able to identify you personally) in order to protect your Personal Data during processing.

CHILDREN

Our services are neither directed at nor intended for use by persons under the age of 16. Further, we do not knowingly collect Personal Data from children under such ages. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

DATA RETENTION

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Privacy Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data (without limitation):

• Retention periods established under applicable law;
• Industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• IT systems design considerations/limitations; and
• The costs associated continued processing, retention, and deletion.

We will review retention periods periodically and will either delete or anonymize data held for longer periods.

CHANGES TO OUR POLICY

We may change this Policy from time to time. We will post changes on this page. Your continued use of the Website constitutes your acknowledgement of any revised Policy.

COOKIES

This Website sets no cookies and stores no information on your device. We do not use cookies for analytics, advertising, or personalization, and our analytics operate in a cookieless mode that stores nothing on your device.

Certain third-party features that you actively choose to use — such as our course booking tool or embedded video - load only when you select them, and may then set cookies on their own domains. Those cookies are governed by the individual policies of the third parties providing those features.

REGIONAL SUPPLEMENTS ADDENDUM

US States/California

US State & California Privacy Rights & Choices

Under the California Consumer Privacy Act (“CCPA”) and other state privacy laws, residents of certain US states may have the following rights, subject to regional requirements, exceptions, and limitations.

Confirm - Right to confirm whether we process your Personal Data

Access/Know - Right to request any of following: (1) the categories of Personal Data we have collected, sold/“shared,” or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the purposes for which we collected or sold/“shared” your Personal Data; (4) the categories of third parties to whom we have sold/“shared” your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.

Portability - Right to request that we provide certain Personal Data in a common, portable format

Deletion - Right to delete certain Personal Data that we hold about you.

Correction - Right to correct certain Personal Data that we hold about you.

Opt-Out Sharing - Right to opt-out of the Sharing of your Personal Data with business partners,

Opt-out or Limit Use and Disclosure of Sensitive Personal Data - Right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Data. This right does not apply in cases where we only use Sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law.

Opt-in/Opt-out of Sharing of Minors’ Personal Data - To the extent we have actual knowledge that we collect or maintain personal information of a minor under age 16 in California, those minors must opt in to any sharing of personal information (as defined under CCPA), and minors under the age of 13 must have a parent consent to sharing of personal information. All minors have the right to opt-out later at any time.

Non-Discrimination - California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA

Submission of Requests

You may submit requests, as follows. If you have any questions or wish to appeal any refusal to take action in response to a rights request, contact us at hello@envorso.com. We will respond to any request to appeal within the time period required by law. To Access, Confirm Processing, Portability, Deletion, and Correction, to Opt-Out of “Sharing,” or Opt-out/Limit Use and Disclosure of Sensitive Personal Data, or Opt-in/Opt-out of “Sharing” of Minors’ or to Remove Minors’ User Content, please refer to hello@envorso.com.

Categories of Personal Data Disclosed for Business Purposes

For purposes of the CCPA, we have disclosed to Service Providers for “business purposes” in the preceding 12 months the following categories of Personal Data, to the following categories of recipients:

Categories of Personal Data Sold, Shared, or Disclosed for Commercial Purposes

For purposes of the CCPA, we have disclosed for Commercial Purposes in the preceding 12 months the following categories of Personal Data, to the following third parties:

Categories of Sensitive Personal Data Used or Disclosed

For purposes of CCPA, we do not use or disclose any Sensitive Personal Data for any purposes other than those listed in CCPA section 7027(m).