IronCircle

Privacy Policy

Last Updated: June 30, 2025

HackerUSA, Inc. dba IronCircle (“we,” “us,” “our” or “IronCircle”) works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) on which this Privacy Policy is linked (collectively, “Sites”), such as www.ironcircle.com, and any transactions, interactions, or other engagements you might have with us (collectively, “Services”).  

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Sites and/or Services. If you do not agree with our Terms of Use or this Privacy Policy, you must refrain from using our Sites/Services. By accessing or using our Sites or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing services on behalf of our educational institution partners and other clients (collectively, “Clients”). 

This Privacy Policy also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, employees, or their dependents and beneficiaries, or the collection, use, or disclosure of Personal Information by third parties. Please see our Employee and Prospective Employee Privacy Policy for information about our privacy practices related to job applicants, employees, and their dependents and beneficiaries residing in California. 

ABOUT THIS PRIVACY POLICY

Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make any material changes to this Privacy Policy, the revised policy  will be posted on the Sites with the date of revision. Changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services. We will also provide any other notices, and obtain any consents, required by law.

Conflict Between this Policy and Laws and Regulations

When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations. Please be aware that the Sites and Services are subject to the laws of the United States of America and that your Personal Information will be processed in the United States and other jurisdictions. The Sites and Services are intended for use by individuals in the United States.

INFORMATION WE COLLECT

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

  • Identifiers such as name, social media identifiers, mailing address, billing address, email address, phone number;
  • Commercial Information such as inquiries about or purchases of our products and services, use of our products and services (e.g., course completion status, program completion status), participation in promotional events, participation in surveys;
  • Internet and Other Electronic Network Information such as IP address, device ID, browsing/search history, browser type, device type and settings;
  • Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information such as images, call recordings, video or audio testimonials;
  • Education Information such as educational institutions attended, dates of attendance, degrees earned, grades, instructor reviews/feedback, transcripts;
  • Professional Information such as past and current employers, job title, salary earned, professional association membership, professional credentials and certifications;
  • Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models).

The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us. We also process Personal Information as defined in Cal. Civ. Code § 1798.80(e) to the extent it falls within another category identified above.  

Certain Personal Information we collect, specifically race and ethnicity, may be considered sensitive under your state’s privacy laws and subject to heightened protections.

Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we automatically collect the type of web browser you use, the type of device you use, the type of your operating system, the name of your Internet Service Provider, the pages you view on our Sites, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category Internet and Other Electronic Network Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.

De-Identified or Anonymized Information

We may de-identify or anonymize Personal Information so that it is no longer capable of being associated with you and therefore is no longer Personal Information, or collect information that is already de-identified or anonymized. We may use and disclose de-identified or anonymized information without restriction. We will not attempt to re-identify the consumer(s) associated with previously de-identified or anonymized information.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you explicitly consent to our recording and retention of communications.

HOW WE COLLECT INFORMATION

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), use the Sites or Services, enter into a relationship with us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services or we may not be able to fulfill your requested interaction.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as our university partners, data brokers, marketing/advertising agencies, identity verification services, financial institutions, and government agencies.

Social Media

If you engage with us via social media, use your social media credentials to access the Site or Services, or interact with social media buttons or widgets embedded in our Sites or Services, we may collect Personal Information available on your social media profile and Usage Data. For information about privacy controls available through your social media provider, please visit their website.

Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels and clear gifs (collectively referred to herein as “cookies”) to improve the experience of the Site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Site, and to facilitate analytics and advertising. Many web browsers are initially set up to accept cookies.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent.  However, certain features of the Site and Services may not work as intended if you delete or disable cookies.

We use the following types of cookies:

  • Functional Cookies: Functional cookies enable certain features or non-essential functionality for our Sites and Services. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to a Site in order to provide you with a more personalized experience.
  • Strictly Necessary Cookies: Strictly necessary cookies allow our Sites and Services to work as intended such as by allowing us to recognize and honor your login and take other actions for authentication and security. These cookies may not be disabled.
  • Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
  • Analytics Cookies: Analytics cookies help us understand how our Sites and Services work and who is visiting our Sites or using our Services. 

If you arrive at the Sites or Services by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching that led you to our Sites, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Sites or Services to determine what information was collected by that website and for what purposes you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Interest-Based Advertising

We work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you our ads or other of our content that we believe would be relevant to you. Advertisers may also show you third-party ads or content when you engage with our Sites. Advertisers may collect and use information about your use of the Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information, including across time, devices, and websites. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Sites, on third-party websites, or on social media properties. Using a tool created by the Network Advertising Initiated, you can opt out of several Advertisers’ activities. If you want to reduce advertising targeted to you online, please visit the YourAdChoices website for more information about tools provided by the Digital Advertising Alliance to opt out of targeted advertising from participating Advertisers. You may still receive other types of online advertising. Please also see the Additional State Consumer Rights section below regarding rights you may have under state laws to opt out of our sharing of Personal Information for targeted or cross-context behavioral advertising purposes.

Information from Advertisements

If you arrive at the Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date, and time).

Google Analytics

We use a web analytics tool from Google called “Google Analytics” that uses cookies to help us understand how you use the Sites and Services. To learn more about Google Analytics and your privacy, please review Google’s Safeguarding Your Data disclosure.

HOW WE USE AND DISCLOSE INFORMATION 

Generally

We use Personal Information for internal purposes, including:

Processing Purpose Personal Information Used
Provide you with the Site and Services, and service your account – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information
Market products and services to you and others – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information
Share with Third Parties for cross-context behavioral advertising or targeted advertising purposes – Identifiers
– Commercial information
– Internet or other electronic network information
Perform marketing and other types of analytics – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information
Enhance our products and services and develop new products and services – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information
Operate information security and anti-fraud programs – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information
Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, protecting or enforcing our rights or the rights of others, and facilitating business transactions – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information
Respond to governmental and other legal requests – Identifiers
– Commercial information
– Internet or other electronic network information
– Audio, electronic, visual, thermal, olfactory, or similar information
– Professional or employment-related information
– Education information
– Inferences drawn from other Personal Information

We use sensitive Personal Information for the following purposes:

Personal Information Type Processing Purpose
Race To better understand our consumers. This information is voluntary and you are not required to provide it in order to use our Sites or receive our Services.
Ethnicity To better understand our consumers. This information is voluntary and you are not required to provide it in order to use our Sites or receive our Services.

Profiling and Automated Decision-Making

We do not process Personal Information in connection with profiling or automated decision-making that results in legal or similarly significant impacts on consumers.

Testimonials 

If you provide a testimonial, we may post it publicly on the Sites or in other advertising material. By providing a testimonial, you give us permission to use it and your likeness in any manner and for any purpose, including in marketing and advertising communications, without any compensation or notice to you. 

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates (“Service Providers”), including for:

  • Provision of the Sites and Services;
  • Facilitating marketing, non-marketing, and internal communications;
  • Marketing design, development, and management;
  • Business analytics (both marketing and non-marketing related);
  • Project management and collaboration;
  • Learning management systems;
  • IT and network administration such as data storage and management, website hosting, data security, mobile application development; 
  • Sweepstakes, contest, and other promotional event design and administration;
  • Identity verification;
  • Location verification;
  • Financing products or services;
  • Payment processing;
  • Professional services such as legal and accounting; 
  • Obtaining legal records;
  • Collection of accounts; and
  • Day-to-day business operations such as courier services, facilities management, electronic signatures, and document destruction.

We only provide our Service Providers with the Personal Information reasonably necessary for them to perform these services on our behalf.  You may also be asked to provide Personal Information directly to a Service Provider. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified or permitted by us. 

In the past 12 months we have disclosed each category of Personal Information we collect (listed above) with one or more Service Providers. 

Third-Party Disclosures

We may disclose your Personal Information to companies, governmental entities, or persons that are not our Service Providers as explained more fully below. We refer to these types of data recipients in this Privacy Policy as “Third Parties” 

We do not sell your Personal Information to Third Parties for their direct marketing purposes or for any other purpose.

We may share your Personal Information to Third Parties consisting of advertising networks, ad technology providers, social media companies, and search engine providers to facilitate targeted advertising (including cross-context behavioral advertising). We may share, and have shared in the past 12 months, the following categories of Personal Information to Third Parties for targeted advertising purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity Information.  

OTHER PRIVACY AND SECURITY PROVISIONS

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use, both in transit and at rest. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Other Websites 

Please be aware that third-party websites accessible through the Sites or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties before providing information.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

Other Transfers

We may disclose Personal Information and Usage Data to businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. 

How Long We Retain Your Data

We retain your Personal Information in accordance with our record retention policies that are informed by our business needs as well as obligations to comply, and demonstrate compliance, with legal, regulatory, tax, and accounting requirements and standards. 

Children’s Privacy 

The Sites and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

ADDITIONAL STATE CONSUMER RIGHTS

If you are a resident of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia you have additional rights to access and control your Personal Information. Exemptions may apply. We are unable to act upon a request submitted to us relating to Personal Information we process on behalf of a Client unless directed to do so by the Client. If you submit a request related to Personal Information we process on behalf of a Client, we will inform you of the identity of the applicable Client so that you may submit your request directly to them.

Right to Know

You have the right to request twice per 12-month period that we provide you the categories or specific pieces of Personal Information we collected about you. You also are allowed to obtain certain information about our collection, use, and disclosure of your Personal Information over the past 12 months including: (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose(s) for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; (v) the categories of Third Parties to whom we sold your Personal Information; and (vi) our business or commercial purposes for selling/sharing Personal Information.  We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers. We will not provide specific pieces of Personal Information unless you expressly request them.

Residents of certain states, including Minnesota and Oregon, may have the right to receive the names of Third Parties (not our Service Providers) to whom we disclosed Personal Information, if any. We will provide such information in compliance with a Right to Know request as required by law.

Right to Delete

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, or comply with legal obligations.

Right to Correct

You have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will send you instructions for you to provide us with optional documentation to support your request and we will consider it. We may decline to correct your Personal Information if a legal exemption applies such as if we determine that your request is fraudulent or abusive or if we determine, based on the totality of the circumstances, that your correction is more likely inaccurate than accurate. We may decide to delete your allegedly inaccurate Personal Information instead of correcting it.

If you have an online account with us, you may also update your contact information various other information through your online account which will be faster than submitting a correction request.

Right to Opt Out of Sales and Sharing

You have the right to direct us not to sell or share (for cross-context behavioral advertising or targeted advertising purposes) your Personal Information to Third Parties. We will process such requests within 15 business days, subject to any applicable exceptions and extensions permitted by law.

Right to Limit Use of Sensitive Personal Information

If you are a California resident, you have the right to request that we limit the use of your sensitive Personal Information as defined under California law to only exempt purposes such as to provide the goods and services reasonably expected by the average consumer who requests such goods and services, to prevent fraud, and to verify or maintain the quality or safety of goods or services we provide.

If you are a resident of a state with privacy rights listed above except California, and you make a request to limit the user of your sensitive Personal Information as defined under your applicable state’s law, we will treat that request as a revocation of your consent for us to collect and process your sensitive Personal Information and will delete your sensitive Personal Information subject to any exemptions available under applicable law.

Appeals 

You have the right to appeal our decision to deny, in full or in part, your exercise of consumer rights by submitting a request to appeal. If we deny your appeal, we will provide you with a written explanation of the reasons for our decision.

Submitting a Privacy Request

You may submit your request(s) by using our Privacy Request Form, or emailing us at privacy@ironcircle.com. In your correspondence, please include at least your name, mailing address, email address, and a description of your request. 

After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process Right to Know,  Deletion, Correction, or certain Appeal requests without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.

We will process verified Right to Know, Deletion, and Correction requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. We will acknowledge receipt of your request within 10 business days. We will process verified Appeal requests within the time period allowed by applicable law, but typically within 45 days of receipt. If you have a password-protected online account with us, we may provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your Deletion request for 2 years as required by law. 

Authorized Agent

If you are an authorized agent submitting a request on behalf of a California resident, you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof of your identity. You may provide this documentation via email to privacy@ironcircle.com. after submitting the request. Depending on the request made, we may contact you and the consumer on whose behalf you claim to act to verify your identity, the consumer’s identity, and your authorization to act on the consumer’s behalf.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy. 

California “Do Not Track” Disclosure

“Do Not Track” is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “Do Not Track” signals.

CONTACT US

If you have any questions about our Sites, Services, or this Privacy Policy, please contact us using the information below. 

HackerUSA, Inc.

Attn: Privacy

10440 Little Patuxent Parkway 

Suite 1100 

Columbia, Maryland 21044 

Telephone: 786-628-3783

Email address: privacy@ironcircle.com

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