COLLECTION OF INFORMATION

In connection with your use of the Website, we may collect Personal Information such as your,

• first and last name;
• city;
• country;
• email address;
• phone number;
• gender;
• age;
• about you individually but does not identify you; or
• other information you provide to us in connection with the Services.

For example, we may collect this information when you sign up on a mailing list or use the Website to contact and/or interact with us and access the Services. If you apply for employment with us or to be a program mentor (Program Mentor), you may provide demographic information, such as your name, email address, and information contained in your curriculum vitae and cover letter, including but not limited to your education and employment history. If you are a Program Mentor on our Website, or being recruited to join us, in addition to the above, we may collect certain data to facilitate access to the Website and to enable you to assist in the provision of the Services to our customers.

If contacting us via a form on the Website or at support@somiainternational.com please do not provide any information beyond what is requested in such form or e-mail. In addition, we may collect information regarding your use of the Website through the use of cookies (described below), and information from other sources. Such other information may include, but is not limited to, the date and time of your visit, your IP address, your browser type, your operating system and language, the pages you visited, and the address of the website from which you came.

We do not intend to transfer your Personal Information to any third parties without your consent, except under the limited conditions described under the section entitled “Use and Disclosure of Information” below.

NO COLLECTION OF CHILDREN’S PERSONALLY IDENTIFIABLE INFORMATION

Our Website is intended for adults at least eighteen (18) years old. We do not knowingly collect any Personal Information from children under the age of thirteen (13). If you are under thirteen (13) years of age, then please do not use or access our Website at any time or in any manner. By using the Website you certify that you are at least eighteen (18) years of age or older. We reserve the right to delete any information we believe to be in violation of this Privacy Policy.

USE AND DISCLOSURE OF INFORMATION

Our uses and disclosures of Personal Information may include, but will not be limited to, providing information and Services that you may have requested or for which you have contracted with us, managing and improving our Website, diagnosing problems with our server, assisting with technical problems, and enforcing compliance with this Privacy Policy.

We may use and disclose the Personal Information we collect through the Website in the following ways:

• We may use the Personal Information to provide you with the information or Services you have requested from us.
• We may use the Personal Information to keep you informed about events, services, or publications that may interest you.
• We may use the Personal Information to improve our Website and the Services we provide to you.
• We may disclose your information to the Program Mentors that we contract with to provide you with the Services you have requested from us.
• We may disclose information to comply with any legal or regulatory obligation and to protect our rights or the rights or safety of other

If Somia is involved in a merger, acquisition, or any form of transfer or sale of some or all of Somia, whether as part of a bankruptcy, liquidation, or similar proceeding, Personal Information may be transferred along with the business as part of any such transaction.

We do not sell or share your Personal Information with anyone outside Somia without your consent, unless we are required to do so by law or as provided in this Privacy Policy.

COOKIES

When you access our Website, we may place a “cookie” on your device. A cookie is a file that a website can store on your web browser, computer, or device and later retrieve. A cookie allows our Website to recognize you as a prior user, provide our Website with information regarding your use, and helps us determine the portions of our Website that are best suited for you.

Cookies set by the website you are visiting are normally referred to as “first-party cookies,” and typically only track your activity on that particular site. Cookies set by other sites and companies (i.e., third parties) are called “third-party cookies,” and can be used to track you on other websites that use the same third-party service.

Cookies we use can be categorized as one of the following: (i) Essential Functionality Cookies; and (ii) Statistics Cookies.

• Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing.
• Statistics Cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

In addition to the above, we may employ third-party companies and individuals for our Website— for example, analytics providers. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the Services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by our Privacy Policy.

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our Website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie. If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Our Website is not currently configured to respond to Do Not Track signals. In order to potentially identify cookies on our Website you may use a browser plug-in that scans a website for cookies. We do not guarantee the accuracy, effectiveness and/or security of any such browser plug-in.

WEB BEACONS

We may use pixel tags (also known as pixel gifs or web beacons) and other methods to gather information about the emails we send. Pixel tags are tiny graphic files that are included in our HTML-encoded email messages. When such a message is opened in an HTML-capable email program, the recipient’s computer will access our servers to retrieve the pixel tag file, allowing us to record and store information such as email address, date and time the recipient viewed the email message, if the recipient’s email program is capable of receiving HTML, and other logging information. We may use this information to optimize delivery of future messages to specific recipients.

ONLINE TRACKING / DO NOT TRACK SIGNALS

“Do Not Track” (DNT) signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked. Our Website is not currently set up to respond to these signals. If you choose to block cookies and other trackers, certain features of the Website may not work. On a mobile device, you may also be able to adjust your settings to limit ad tracking.

DATA RETENTION

The Personal Information we collect from you will be stored for no longer than necessary to provide products or services that you requested or as needed for our business purposes, except as may be required by law, or in response to a subpoena or search warrant or other legal process. The length of time we retain said Personal Information will be determined based upon the following criteria: the length of time your Personal Information remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators, professional bodies or associations; the type of contract we have with you, the existence of your consent, our legitimate interest in keeping such information as stated in this Privacy Policy; compliance with laws, or in response to a subpoena or search warrant or other legal process.

LINKS TO OTHER WEBSITES

This Privacy Notice applies only to the Website. This Platform may contain links to other web sites not operated or controlled by us (the “Third Party Sites”), e.g., Kajabi, Calendly, Zoom, Pay Pal, and certain social media sites. The policies and procedures we described here do not apply to the Third Party Sites. The links from this Platform do not imply that we endorse or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

WE OPERATE IN THE UNITED STATES AND INTERNATIONALLY

If you use the Website outside of the United States or are a citizen or resident of a country other than the United States that has laws and policies governing the disclosure and management of your Personal Information, you understand and agree that the information you exchange with the Website may be maintained indefinitely on systems located within the United States or the systems of those third parties with whom we share it as described in this Privacy Policy, such as Kajabi. By using the Website, you understand and consent to the collection, storage, processing, and transfer of your information to Kajabi’s facilities in the United States and may be shared anywhere else in the world where Kajabi and its subprocessors maintain data processing operations. Please review the Kajabi website policies at https://legal.kajabi.com/ and Privacy Policy at https://legal.kajabi.com/policies/privacy for more information.

DATA PROTECTION RIGHTS UNDER THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION AND THE UNITED KINGDOM DATA PROTECTION ACT 2018

This section of the Privacy Policy supplements the information contained in the Privacy Policy and applies solely to users located in the European Economic Area, including Switzerland, (“EEA”) and the United Kingdom (“UK”, such Users are referred to as “EU/UK Consumer” or “you”). We adopt this notice to comply with the European Union General Data Protection Regulation (“EU GDPR”) and the United Kingdom Data Protection Act 2018 (“UK DPA” or “UK GDPR”). Any terms defined in the EU GDPR or UK GDPR have the same meaning when used in this section of the Privacy Policy.

What are your data protection rights?
We would like to make you fully aware of all of your data protection rights. Every EU/UK Consumer is entitled to the following:

• The right to access – You have the right to request for copies of your Personal Information. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request we complete the Personal Information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your Personal Information, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your Personal Information, under certain conditions.
• The right to data portability – You have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions.
• The right to lodge a complaint with a supervisory authority.

If you make a request, we will respond within a reasonable time period as required by law. If you would like to exercise any of these rights, please contact us using the contact information provided at the end of this Privacy Policy.

EU Standard Contractual Clauses and the UK Addendum
The Personal Information you provide through the Website may be maintained and stored within the United States, or the systems of those third parties with whom we share it as described in this Privacy Policy, such as Kajabi. Kajabi’s primary processing facilities are in the United States. Notwithstanding the foregoing, you acknowledge that Kajabi may, in connection with your use of the Website, need to transfer and process your Personal Information to and in the United States and anywhere else in the world where Kajabi and its subprocessors maintain data processing operations. Please review the Kajabi website policies at https://legal.kajabi.com/ and Privacy Policy at https://legal.kajabi.com/policies/privacy for more information.

Under the EU and UK GDPR, we and/or Kajabi may transfer Personal Information to a third country provided the appropriate safeguards are in place. In the EU, such safeguards include the standard contract clauses (“SCCs”), which provide appropriate data protection safeguards to be used as a ground for data transfers from the EU to third countries, and have been pre-approved by the European Commission. To comply with the UK GDPR, we and/or Kajabi may use the International Data Transfer Addendum to the European Commission’s SCCs for international data transfers (the “UK Addendum”). We and/or Kajabi apply the SCCs and the UK Addendum to transfer data to countries outside the EU and UK.

For a copy of the SCCs or the UK Addendum, please contact us using the contact information provided at the end of this Privacy Policy or [ click here / which may be found at at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj] for the SCCs, or [click here / which may be found at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/] for the UK Addendum.

 

DATA SECURITY; NO LIABILITY

We strive to protect your Personal Information and we have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, we urge you to take every precaution to protect your Personal Information when you are on the internet.

We will maintain reasonable technical, administrative and organizational measures in order to protect and safeguard your information. Unfortunately, information transferred over the internet is not completely secure. Accordingly, we do not guarantee that your information will not be misused or disclosed to third parties. You acknowledge and agree that any transmission of information to our Website is made at your own risk. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We will have no liability to you for any misuse or disclosure of your information.

If you share information with third parties via our Website, you do so at your own risk. Any such information you share with the third party will not be governed by this Privacy Policy and we have no liability to you with respect to such information.

You understand that electronic communications may be accessed by unauthorized parties when communicated across the internet, network communications facilities, or other electronic means. You understand and agree that we are not responsible for any electronic communication or any of your information which may be lost, altered, intercepted, or stored without authorization during the transmission of any data whatsoever across networks not owned or operated by us.

 

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy, at any time, without notice to you; provided, however, that any changes will only apply to information collected after such changes go into effect.

This Privacy Policy was last updated on September 11, 2025 .

If you continue to use the Website or provide Personal Information to us after we change this Privacy Policy, that signifies your consent to such changes and your use of the Website will be subject to the terms set forth in the most recent version of the Privacy Policy.

 

OUR TERMS OF USE

Your access to and use of this Platform is subject to our Terms of Use

 

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy or if you need assistance regarding your information, including assistance accessing your information or correcting your information, please contact:

PO Box 278
West Stockbridge MA 01266
support@somiainternational.com

Doc #4878319.1