
THE CULTIVATE CODE, LLC
PRIVACY POLICY
Last Updated: July 27, 2026
The Cultivate Code, LLC (“The Cultivate Code,” “TCC,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit our websites, communicate with us, apply for or enroll in a program, make a purchase, participate in a class or event, join a community, or otherwise use our products and services (collectively, the “Services”).
The Services include, without limitation, cultivatecode.co and related webpages; TCC Studio; fixed-term coaching and training programs such as Fast Track, Fast Track Express, Sideline Ready, Sideline Sprint, and The Prep Year; subscription or membership offerings such as Choreo Club; workshops, masterclasses, audition-preparation events, choreography classes, and drop-in classes; live, virtual, and prerecorded training; digital courses, templates, e-books, guides, and downloads; online communities; and coaching or support provided by email, text message, videoconference, or other communication channels.
This Privacy Policy applies to information we process as the business responsible for deciding how and why the information is used. It does not apply to a third-party website, platform, product, or service that has its own privacy policy.
By using the Services, you acknowledge the practices described in this Privacy Policy. If you do not agree, do not use the Services.
1. PERSONAL INFORMATION WE COLLECT
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household. It does not include information that has been lawfully made public, aggregated information, or information that has been deidentified so it cannot reasonably be linked to you.
Depending on how you interact with TCC, we may collect the following categories of personal information.
1.1 Contact and Identity Information
This may include:
• first and last name;
• email address;
• telephone number;
• mailing or billing address;
• date of birth or age range;
• social-media username or profile information; and
• parent or legal guardian information for an eligible participant who is 16 or 17.
1.2 Account and Registration Information
This may include:
• username, password, and account identifiers;
• program applications, registration forms, intake forms, questionnaires, and surveys;
• program, class, workshop, and event selections;
• attendance, participation, progress, and completion information;
• communication and marketing preferences; and
• records showing when and how you agreed to our Terms, waivers, or communication preferences.
1.3 Audition, Training, and Coaching Information
To provide coaching and training, we may collect information you choose to provide about:
• dance education, experience, team history, and audition goals;
• college, school, team, or professional interests;
• performance, choreography, technique, interview, resume, branding, fitness, nutrition, and training goals;
• audition dates, results, feedback, and development progress;
• videos, photographs, recordings, assignments, resumes, biographies, and other materials you submit for feedback; and
• physical limitations, injuries, accessibility needs, dietary considerations, or other circumstances you voluntarily disclose because they are relevant to safe participation or individualized coaching.
TCC is not a healthcare provider. Please do not provide medical information that is not reasonably necessary for your participation. We do not use voluntarily submitted health or physical-limitation information to diagnose or treat a medical condition.
1.4 Payment and Commercial Information
This may include:
• products or Services purchased, considered, or accessed;
• transaction amount, date, status, payment schedule, discounts, and refunds;
• billing address and limited payment-method details, such as card type and the last four digits;
• payment failures, account balances, and collection records; and
• referral or affiliate attribution connected to a purchase.
Payments may be processed by providers such as Stripe, PayPal, or a payment service integrated with GoHighLevel. TCC does not ordinarily receive or store your complete payment-card number.
1.5 Communications and Customer Support
We may collect emails, text messages, form submissions, direct messages, support requests, call notes, survey answers, and other communications between you and TCC.
Calls, virtual sessions, classes, workshops, or coaching sessions may be recorded when disclosed to participants. A recording may capture your name, voice, image, performance, questions, chat messages, and participation.
1.6 User Content, Reviews, and Testimonials
We may collect content you submit, including comments, community posts, photographs, videos, performance footage, reviews, testimonials, success stories, survey answers, and feedback.
We use testimonials or identifiable content for public marketing only when you voluntarily submit the material for that purpose or otherwise authorize the use, as described in our Terms of Service or a separate release.
1.7 SMS and Communication Consent Information
When you choose whether to receive text messages, we may collect:
• your mobile number;
• the date, time, source, webpage, form, or method used to opt in;
• whether you selected marketing messages, non-marketing messages, both, or neither;
• the disclosure presented when you made your selection;
• messages sent and received;
• delivery, error, HELP, STOP, START, and other consent-management records; and
• evidence needed to demonstrate or honor your communication choices.
Marketing text-message consent is not a condition of purchase. We do not treat a phone number alone as consent to receive marketing messages.
1.8 Device, Internet, and Usage Information
When you use our websites or digital Services, we and service providers acting on our behalf may automatically collect:
• IP address;
• browser type, language, version, and settings;
• device type, operating system, device identifiers, and approximate location derived from IP address;
• referring and exit pages;
• pages, links, buttons, forms, videos, and features viewed or used;
• dates, times, session duration, and navigation paths;
• advertising identifiers and campaign-attribution information;
• cookie, pixel, tag, and similar technology data;
• diagnostic, performance, security, and error information; and
• general interaction and website-behavior data.
We do not intend to use photographs or videos to create biometric identifiers or face templates. If that practice changes, we will provide any notice and obtain any consent required by law before doing so.
1.9 Information From Other Sources
We may receive information from:
• payment processors;
• GoHighLevel and other customer-relationship, form, email, and SMS platforms;
• analytics and website-experience providers such as Google Analytics and Hotjar;
• advertising platforms such as Meta, Google, and TikTok;
• automation providers such as Zapier;
• scheduling, videoconferencing, course-hosting, and community platforms;
• social networks when you interact with TCC or choose to connect an account;
• referral partners or individuals who direct you to TCC;
• instructors, contractors, or team members who help deliver the Services; and
• publicly available sources, such as public team rosters or social-media profiles, when relevant to a request you make or a Service we provide.
2. HOW WE USE PERSONAL INFORMATION
We may use personal information to:
• provide, personalize, administer, and improve the Services;
• review applications and determine program fit or eligibility;
• create and manage accounts;
• enroll participants and deliver programs, coaching, classes, workshops, recordings, digital products, communities, and support;
• process and document payments, installments, subscriptions, renewals, refunds, and account balances;
• schedule sessions and send enrollment confirmations, reminders, updates, receipts, and service notices;
• provide individualized feedback and track participation or progress;
• respond to inquiries, applications, and customer-support requests;
• manage preferences for email, SMS, and other communications;
• send marketing communications when permitted by law and consistent with your choices;
• measure campaign performance and understand how people find and use our Services;
• customize content and advertising;
• maintain, troubleshoot, secure, and protect the Services;
• detect, investigate, and prevent fraud, abuse, unauthorized activity, security incidents, or violations of our Terms;
• maintain business, tax, accounting, consent, and legal records;
• establish, exercise, or defend legal claims;
• comply with applicable law, lawful requests, court orders, and regulatory obligations; and
• carry out another purpose disclosed when the information is collected or that you authorize.
We may aggregate or deidentify information and use it for analytics, research, reporting, product development, and business improvement. We will not attempt to reidentify information that has been deidentified except as permitted by law to test whether our deidentification methods are effective.
3. LEGAL BASES FOR PROCESSING
Where a law requires us to identify a legal basis for processing, we rely on one or more of the following:
• Contract: processing necessary to take steps at your request, complete a transaction, or provide a Service you purchased or requested.
• Consent: processing you authorize, such as certain marketing, text messaging, cookies, testimonials, or optional submissions. You may withdraw consent prospectively at any time, although withdrawal will not affect processing that was lawful before withdrawal.
• Legitimate Interests: processing reasonably necessary to operate, improve, secure, market, and understand our Services, provided those interests are not overridden by your rights.
• Legal Obligation: processing necessary to comply with tax, accounting, consumer-protection, safety, law-enforcement, or other legal requirements.
• Protection of Rights and Safety: processing necessary to protect a person’s vital interests or the rights, property, security, and safety of TCC, our participants, or others.
4. COOKIES, PIXELS, ANALYTICS, AND ADVERTISING
We use cookies, pixels, tags, local storage, scripts, and similar technologies to keep websites working, remember preferences, understand website use, measure marketing, detect fraud, and present relevant advertising.
These technologies may be operated by TCC or by service providers such as GoHighLevel, Google Analytics, Hotjar, Meta, TikTok, and other hosting, analytics, advertising, or technology providers.
The technologies we use may include:
• Essential technologies needed for security, checkout, forms, account access, and core website functions;
• Functional technologies that remember preferences or improve convenience;
• Analytics technologies that help us understand traffic, navigation, engagement, and performance; and
• Advertising technologies that measure campaigns, attribute registrations or purchases, build audiences, and display more relevant advertising on other services.
You can control cookies through your browser settings and, when available, our cookie or consent-management tool. Blocking some technologies may prevent portions of the Services from working properly.
Some browsers transmit “Do Not Track” signals. Because no uniform standard governs these signals, our websites may not respond to every Do Not Track signal. Where required by applicable law and technically supported, we recognize legally valid opt-out preference signals, such as Global Privacy Control, for the browser or device sending the signal.
Visitors in the European Economic Area, United Kingdom, or another location requiring prior consent may be asked to make cookie choices before non-essential technologies are activated.
5. HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose personal information to the categories of recipients below for the purposes described in this Privacy Policy.
5.1 Service Providers and Contractors
We may provide information to companies and individuals that perform services for TCC, such as:
• website, cloud-storage, and software providers;
• GoHighLevel and other CRM, form, email, and SMS providers;
• Stripe, PayPal, and other payment processors;
• course, member-portal, videoconferencing, scheduling, and community platforms;
• analytics and website-experience providers;
• marketing, advertising, and campaign-measurement providers;
• automation and integration providers;
• instructors, coaches, contractors, and customer-support providers;
• accountants, attorneys, insurers, auditors, and professional advisers; and
• security, fraud-prevention, collection, and compliance providers.
These recipients may process information only for the services they provide to us or as otherwise permitted by their agreements and applicable law.
5.2 Advertising and Analytics Partners
We may allow analytics and advertising partners to collect online identifiers, device information, browsing activity, and campaign-interaction information through cookies, pixels, and similar technologies. They may use this information to measure advertising, attribute registrations or purchases, create audiences, limit repetitive advertisements, or show advertisements based on activity across websites or services.
Under some U.S. state privacy laws, these disclosures may be considered “sharing,” targeted advertising, or a “sale” even when no money is exchanged. Where applicable, you may opt out as described in Section 11.
5.3 Referral and Affiliate Administration
If you arrive through a referral or affiliate link, we may provide the referring party with limited information needed to confirm attribution and calculate a commission, such as whether an eligible purchase occurred and the associated order value. We do not provide that party with your text-message opt-in data or consent.
5.4 Legal, Safety, and Rights Protection
We may disclose information if we reasonably believe it is necessary to:
• comply with law, regulation, subpoena, court order, or other valid legal process;
• respond to a lawful request from a government or law-enforcement authority;
• enforce our Terms, contracts, payment rights, or other agreements;
• detect, prevent, or investigate fraud, security incidents, abuse, or unlawful conduct;
• protect the rights, property, health, safety, and security of TCC, our participants, or others; or
• establish, exercise, or defend legal claims.
5.5 Business Transfers
Information may be disclosed or transferred as part of a proposed or completed merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar business transaction. The recipient will be required to handle personal information consistently with applicable law.
5.6 At Your Direction or With Your Consent
We may disclose information to another person or organization when you direct us to do so, request an integration or introduction, or otherwise provide valid consent.
6. MOBILE INFORMATION AND TEXT-MESSAGE CONSENT
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We do not sell, rent, trade, or transfer your mobile number or SMS consent to another business for that business’s own marketing.
If you opt in to receive text messages from The Cultivate Code, message frequency varies and message and data rates may apply. You may opt out at any time by replying STOP to 1-925-401-3543 or to the number from which you received a message. For assistance, reply HELP or email [email protected]. Wireless carriers are not liable for delayed or undelivered messages.
After you opt out, we may retain a suppression record so that we can honor your request. You may opt in again through an authorized TCC sign-up method or by replying START when available.
For the complete SMS Program terms, review our Terms of Service at:
https://www.cultivatecode.co/terms-and-conditions
7. WE DO NOT SELL PERSONAL INFORMATION FOR MONEY
TCC does not sell personal information for monetary compensation.
As explained in Section 5.2, certain online advertising or analytics disclosures may be classified as “sharing,” targeted advertising, or a “sale” under a particular state law even though TCC does not receive money in exchange for the information. Where an applicable law gives you the right to opt out, you may exercise that right as described in Section 11.
We do not knowingly sell or share for cross-context behavioral advertising the personal information of anyone under 16.
8. DATA RETENTION
We retain personal information for no longer than reasonably necessary for the purposes described in this Privacy Policy, including to provide Services, maintain business and transaction records, honor communication preferences, resolve disputes, enforce agreements, and comply with legal, tax, accounting, and regulatory obligations.
Retention periods depend on the type of information and why it was collected. For example:
• account and program records may be retained while your account is active and for a reasonable period afterward;
• transaction, tax, payment, and contract records may be retained for the period required by tax, accounting, collection, and legal rules;
• coaching submissions, recordings, and community content may be retained for the applicable access period and a reasonable operational period afterward;
• consent and opt-out records may be retained as needed to demonstrate and honor your choices;
• customer-support and dispute records may be retained until the matter is resolved and for an appropriate legal period afterward; and
• cookie and analytics information is retained according to the settings and policies of the relevant technology provider.
When information is no longer reasonably needed, we may delete, deidentify, or aggregate it. Backup copies may remain for a limited period until overwritten through ordinary processes.
9. DATA SECURITY
We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. These measures may include access controls, account authentication, encryption in transit, secure third-party payment processing, vendor management, and monitoring.
No website, network, transmission, or storage system is completely secure. We cannot guarantee absolute security. You are responsible for protecting your login credentials and promptly notifying us if you suspect unauthorized account activity.
Email and ordinary text messages may not be secure. Do not send highly sensitive medical, financial, identity, or payment information through email or SMS.
10. YOUR COMMUNICATION AND PRIVACY CHOICES
10.1 Email
You may unsubscribe from marketing emails by using the unsubscribe link in the message or contacting us. We may continue to send transactional or service communications, such as receipts, account notices, schedule changes, enrollment information, or responses to your requests.
10.2 Text Messages
You may opt out of text messages by replying STOP. For help, reply HELP or contact [email protected].
10.3 Cookies and Targeted Advertising
You may manage cookies through your browser or our consent tool when available. You may also use legally recognized browser-based opt-out signals where applicable. Choices made in one browser or device may not automatically apply to another.
You can also adjust advertising preferences directly with providers such as Google, Meta, or TikTok through their account or advertising settings.
10.4 Account Information
You may update certain information through your account or by contacting us. We may need to retain prior transaction, contract, consent, or compliance records.
11. U.S. STATE PRIVACY RIGHTS
Depending on where you live and whether an applicable law covers TCC’s processing, you may have rights to:
• confirm whether we process your personal information;
• access or obtain a copy of personal information;
• correct inaccurate personal information;
• delete personal information, subject to legal exceptions;
• obtain certain information in a portable format;
• opt out of targeted advertising, the sale of personal information, or certain profiling;
• limit certain uses or disclosures of sensitive personal information;
• withdraw consent where processing is based on consent;
• receive information about categories of personal information, sources, purposes, and recipients;
• appeal a decision we make about your privacy request; and
• exercise privacy rights without unlawful discrimination.
These rights may apply under laws in California, Colorado, Connecticut, Delaware, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, or another state as laws become effective and apply to TCC.
To submit a request, email [email protected] with the subject line “Privacy Request” or write to the address in Section 17. Describe the right you wish to exercise and the state where you reside.
We may request information reasonably necessary to verify your identity and authority. If we cannot verify a request, we may be unable to fulfill it. An authorized agent may submit a request where permitted by law, but we may require proof of authorization and direct identity verification.
We will respond within the period required by applicable law. If we deny a request, you may appeal by replying to our decision and stating that you wish to appeal. We will provide any additional complaint or regulatory information required by your state.
Rights are subject to exceptions. For example, we may retain information needed to complete a transaction, provide a requested Service, protect security, prevent fraud, maintain legal claims, comply with law, honor an opt-out, or exercise another lawful exemption.
12. CALIFORNIA PRIVACY NOTICE
This section supplements the rest of this Privacy Policy for California residents. It applies only if and to the extent TCC is subject to the California Consumer Privacy Act, as amended (“CCPA”).
During the preceding twelve (12) months, TCC may have collected the following CCPA categories:
• Identifiers, such as name, email address, telephone number, mailing address, IP address, account identifier, and social-media handle;
• Customer-record information, such as contact, billing, and payment-related information;
• Characteristics of protected classifications, such as age and information that may be apparent from or voluntarily disclosed in an application, photograph, video, or testimonial;
• Commercial information, such as purchases, subscriptions, payment schedules, transaction history, and Services considered;
• Internet or electronic-network activity, such as browsing, interaction, device, cookie, and analytics information;
• Geolocation information, limited primarily to approximate location derived from IP address;
• Audio, electronic, and visual information, such as calls, session recordings, audition videos, photographs, and testimonials;
• Professional, employment, or education information, such as team history, dance experience, college, resume, or audition background;
• Inferences drawn from the information above, such as program interests, engagement, preferences, or likely marketing interests; and
• Sensitive personal information you voluntarily provide, such as account credentials, payment information processed by payment providers, or information about health, injury, or physical limitations relevant to participation.
We collect these categories from you, your device, service providers, payment processors, analytics and advertising platforms, referral sources, public sources, and the other sources described in Section 1.
We use and disclose these categories for the business and commercial purposes described in Sections 2 and 5.
TCC does not use sensitive personal information to infer characteristics about you beyond purposes permitted by law. We do not offer a financial incentive in exchange for personal information unless the material terms are disclosed to you before you participate.
California residents may have the right to know, access, correct, or delete personal information; receive information about our practices; opt out of sale or sharing; limit certain uses of sensitive personal information; and be free from unlawful discrimination. Instructions for exercising these rights appear in Section 11.
13. NEVADA PRIVACY RIGHTS
Nevada residents may submit a verified request to review or correct certain covered information and, where applicable, opt out of a covered operator’s sale of covered information as defined by Nevada law. TCC does not sell covered information for monetary consideration as “sale” is defined under Nevada law.
Submit a Nevada privacy request to [email protected] with the subject line “Nevada Privacy Request.”
14. EUROPEAN, UNITED KINGDOM, AND SWISS PRIVACY RIGHTS
If you are in the European Economic Area, United Kingdom, or Switzerland and applicable data-protection law applies, you may have the right to:
• request access to personal data;
• correct inaccurate or incomplete data;
• request deletion;
• restrict or object to processing;
• receive portable data;
• withdraw consent prospectively;
• object to direct marketing; and
• complain to your local data-protection authority.
TCC is generally the controller of personal data collected directly through the Services. Our service providers may process personal data on our behalf or act as separate controllers for their own purposes.
To exercise a right, contact [email protected]. You may also lodge a complaint with the supervisory authority where you live, work, or believe a violation occurred.
TCC is based in the United States. We do not claim certification under the EU-U.S., UK Extension, or Swiss-U.S. Data Privacy Framework. When required, international transfers may be supported by consent, contractual protections implemented by service providers, or another lawful transfer mechanism.
15. INTERNATIONAL USERS
TCC is located in the United States. If you access the Services from another country, your information may be collected, processed, stored, or transferred in the United States or another location where TCC’s service providers operate. Those locations may have privacy laws different from the laws in your country.
Where required, we take steps designed to provide an appropriate legal basis or safeguard for international transfers.
16. CHILDREN AND MINORS
The Services are not directed to children under 16, and TCC does not knowingly collect personal information directly from anyone under 16.
Participants who are 16 or 17 may use eligible Services only with the involvement and consent of a parent or legal guardian. The parent or guardian should provide registration, payment, waiver, and consent information on the minor’s behalf where requested.
If you believe a child under 16 has provided personal information to TCC, contact [email protected]. We will review the report and delete the information where required.
We do not knowingly sell or share for cross-context behavioral advertising the personal information of anyone under 16.
17. THIRD-PARTY WEBSITES AND SERVICES
The Services may contain links to or integrations with third-party websites, social networks, payment processors, music services, videoconferencing tools, member portals, scheduling systems, or other services.
TCC does not control the privacy or security practices of those parties. This Privacy Policy does not govern information a third party collects for its own purposes. Review the privacy policy of a third-party service before providing information to it.
18. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our Services, technology, legal requirements, or practices. We will post the revised policy and update the “Last Updated” date.
If a change materially affects how we use information already collected, we will provide additional notice or obtain consent where required by law.
19. CONTACT US
For privacy questions, requests, or concerns, contact:
The Cultivate Code, LLC
9205 W Russell Rd, Building 3, Ste 240
Las Vegas, Nevada 89148
Email: [email protected]
SMS Support: 1-925-401-3543
Website: https://www.cultivatecode.co
Terms of Service: https://www.cultivatecode.co/terms-and-conditions