PRIVACY POLICY – EFFECTIVE JULY 1, 2026

Dan Lok Education, Inc., operating as Certainty Engine ("Certainty Engine," "we," "us," or "our"), respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our website, create an account, or otherwise interact with the Certainty Engine platform and related services (collectively, the "Platform").

This Privacy Policy does not apply to personal information that our business Customers (agencies and companies that subscribe to the Platform) collect about their own leads, clients, subscribers, or end users ("Customer Data") through their use of the Platform. When Customers use the Platform to collect and process Customer Data, Certainty Engine acts as a data processor on the Customer's behalf, under the terms of our Customer Data Processing Agreement, and the Customer's own privacy policy — not this one — governs that processing. If you are an individual whose data was submitted to the Platform by a Certainty Engine Customer (for example, because you are a lead, client, or contact of one of our Customers), please contact that Customer directly regarding your personal information.

1. PERSONAL INFORMATION WE COLLECT

We collect personal information in the following ways:

Directly from you. When you create an account, subscribe to our platform, request information, book a demo, or otherwise contact us, we collect information such as your name, email address, phone number, company name, billing information, and account credentials.
Automatically. When you use our website or Platform, we automatically collect technical information such as your IP address, device and browser type, pages visited, and usage patterns, through cookies and similar technologies. See our Cookie practices in Section 7 below.
From third parties. We may receive information about you from marketing partners, affiliate referral partners, payment processors, and publicly available sources.

2. HOW WE USE PERSONAL INFORMATION

We use the personal information we collect to:

provide, operate, maintain, and improve the Platform;
process payments and manage billing;
provide customer support;
communicate with you about your account, security, and service updates;
send marketing communications, where permitted, and in accordance with your preferences;
detect, prevent, and investigate fraud, abuse, or security incidents;
comply with our legal obligations; and
provide AI-enabled features to you as part of the Services you have subscribed to. We do not use your personal information to train generalized, public AI models; our AI features are provided by specialized subprocessors bound by instructions limiting their use of data to providing the specific service requested.

3. LEGAL BASIS FOR PROCESSING (EEA / UK USERS)

Where the GDPR or UK GDPR applies, we rely on the following legal bases to process your personal information: performance of a contract with you; compliance with a legal obligation; our legitimate interests (such as securing the Platform, improving our services, and direct marketing), provided those interests are not overridden by your data protection rights; and, where required, your consent. Certainty Engine acts as the data controller of personal information collected directly from you (e.g., account holders and website visitors) in the EEA and UK, except where we act as a data processor on behalf of our Customers with respect to Customer Data, as described above.

4. HOW WE SHARE PERSONAL INFORMATION

We may disclose personal information to the following categories of recipients:

Service providers and sub-processors, including our underlying platform infrastructure provider (GoHighLevel, Inc. and its affiliate LeadConnector LLC), hosting providers (e.g., Google Cloud Platform, AWS), payment processors, and analytics providers, under contracts that require them to protect your information consistent with this Policy.
Affiliates and subsidiaries of Certainty Engine.
Professional advisors, such as our legal and accounting advisors.
Business transaction parties, in connection with a merger, acquisition, financing, or sale of assets.
Legal and regulatory authorities, where required by law, legal process, or to protect our rights, property, or safety, or that of others.

We do not sell your personal information for monetary consideration.

5. INTERNATIONAL DATA TRANSFERS

Certainty Engine is based in Canada, and our underlying platform infrastructure provider operates data centers and support functions in the United States and other countries. If you are located in the EEA, UK, or Switzerland, your personal information may be transferred to and processed in countries that may not have the same level of data protection as your home jurisdiction. Where required, we rely on appropriate safeguards for such transfers, including Standard Contractual Clauses and our platform infrastructure provider's certification under the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions), as further described in our Customer Data Processing Agreement.

6. DATA RETENTION

We retain personal information for as long as necessary to provide the Platform, comply with our legal obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we securely delete or anonymize it, subject to the retention terms of our Customer Data Processing Agreement where applicable.

7. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar tracking technologies to operate our website, remember your preferences, and analyze usage. You can control cookies through your browser settings; disabling cookies may limit certain features of our website. We do not currently respond to "Do Not Track" browser signals.

8. YOUR PRIVACY RIGHTS

8.1 European Economic Area, UK, and Switzerland

If you are located in the EEA, UK, or Switzerland, you have the right to request access to, correction of, deletion of, or portability of your personal information, and to object to or request restriction of our processing. You may withdraw consent at any time where processing is based on consent. You also have the right to lodge a complaint with your local data protection supervisory authority.

8.2 California and Other U.S. States

If you are a resident of California or another U.S. state with a comprehensive privacy law, you may have the right to know what personal information we collect, request access to or deletion of that information, opt out of the sale or sharing of personal information (we do not sell personal information for money) or targeted advertising, and not be discriminated against for exercising these rights.

8.3 Canada

If you are located in Canada, you have rights under PIPEDA (and, where applicable, provincial legislation such as Quebec's Law 25), including the right to access and request correction of your personal information.

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We may need to verify your identity before fulfilling your request.

9. CHILDREN'S PRIVACY

The Platform is intended for business use by adults and is not directed to children. We do not knowingly collect personal information from individuals under the age of 16. If we learn that we have inadvertently collected such information, we will take steps to delete it.

10. DATA SECURITY

We implement administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, or misuse, including encryption in transit and at rest, access controls, and reliance on our platform infrastructure provider's SOC 2 Type II-audited security program. No system can be guaranteed 100% secure; if you believe your account has been compromised, please contact us immediately.

11. THIRD-PARTY LINKS AND SERVICES

Our Platform may contain links to third-party websites or integrate with third-party services (such as payment gateways or social media platforms). This Privacy Policy does not apply to those third parties, and we encourage you to review their privacy policies.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will post the updated version with a new effective date, and, where required by law, provide additional notice of material changes.