Privacy Policy

1. Definitions

1.1In this Policy, unless the context otherwise requires:

1.1.1“Applicable Privacy Laws” means all privacy and data protection laws applicable to our processing of Personal Information, including the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Personal Information Protection Act (British Columbia) (“BC PIPA”), Canada’s Anti-Spam Legislation (“CASL”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”) and comparable United States state privacy statutes, the Telephone Consumer Protection Act (“TCPA”), and the CAN-SPAM Act.

1.1.2“Client” means an individual who purchases, enrolls in, or participates in a Program.

1.1.3“Client Materials” means draft chapters, dissertations, research data, datasets, supervisor or committee feedback, and other academic work or materials submitted to us by a Client.

1.1.4“Personal Information” means information about an identifiable individual, and includes “personal information” as defined in PIPEDA, BC PIPA, and the CCPA/CPRA.

1.1.5“Program” means any coaching, mentorship, or academic-development program offered by GradCollective, including the program currently offered under the name The Strong Finish – Dissertation Coaching Program.

1.1.6“Sensitive Personal Information” means the categories of information designated as sensitive or requiring heightened protection under Applicable Privacy Laws, including “sensitive personal information” as defined in the CCPA/CPRA.

1.1.7“Services” means the Programs, the Website, our application and inquiry process, and all related communications and support.

1.1.8“Website” means gradcollective.com, apply.gradcollective.com, and any successor or related domain, including all pages, subdomains, funnels, landing pages, and forms operated by us.

1.1.9“you” or “your” means any individual whose Personal Information we process, including Website visitors, inquirers, applicants, Clients, and prospective Clients.

1.2In this Policy, “including” means “including without limitation”; the singular includes the plural and vice versa; a reference to a statute includes its regulations, amendments, and successor legislation; and headings are for convenience only and do not affect interpretation.

2. Who We Are and Our Role

2.1GradCollective is a trading name only. The contracting and responsible entity is 1543120 B.C. LTD., a company incorporated under the Business Corporations Act (British Columbia), Incorporation Number BC1543120, incorporated on 6 June 2025, with its registered and records office at Unit 318 - 10168 149 Street, Surrey, British Columbia V3R 0E9, Canada.

2.2We provide dissertation completion coaching, mentorship, structured feedback, accountability, and related academic-development services exclusively to PhD and doctoral candidates. We do not provide ghostwriting, contract cheating, or any service intended to facilitate academic misconduct.

2.3For the purposes of PIPEDA and BC PIPA, we are the organization responsible for the Personal Information under our control. For the purposes of the CCPA/CPRA, we act as a business. Where we engage third parties to process Personal Information on our behalf, those parties act as service providers or contractors, as those terms are defined in the CCPA/CPRA.

2.4Our Privacy Officer may be contacted at [email protected]. Contact details are set out in full at Clause 19.

3. Scope of This Policy

3.1This Policy applies to Personal Information collected through the Website, through our inquiry and application forms, through consultation calls, during delivery of a Program, and through our email, SMS, and messaging communications.

3.2Our Programs are offered to clients located in the United States and Canada. We do not target or market our Programs to individuals located in the European Economic Area or the United Kingdom. If you are located outside the United States or Canada, please do not submit an inquiry or application.

3.3This Policy does not apply to third-party websites, platforms, or services that we do not control, even where accessible through a link on the Website. Clause 17 sets out our position on third-party services.

3.4Where you engage with us through a third-party marketplace, including Fiverr or Upwork, that platform operates its own privacy policy in respect of information you provide to it. This Policy applies to Personal Information we receive from that platform and to Personal Information you subsequently provide to us directly.

4. Personal Information We Collect

4.1Information you provide directly. We collect the following categories of Personal Information when you submit an inquiry, complete an application, book a consultation, purchase a Program, or communicate with us:

4.1.1identifiers, including your full name, email address, telephone number, and country or region of residence;

4.1.2academic and professional information, including your institution, degree program, discipline, stage of candidature, supervisor or committee arrangements, submission timeline, prior progress, and the obstacles you describe to us;

4.1.3Client Materials, including draft chapters, dissertations, research data, datasets, literature reviews, methodology sections, and supervisor or committee feedback that you submit for review;

4.1.4commercial information, including the Program purchased, the fee agreed, the installment schedule, and your payment and transaction history;

4.1.5billing information, which is collected and processed by Digistore24 at its own checkout. We do not receive, store, or have access to your payment card details. We receive only limited transaction data confirming your purchase and payment status;

4.1.6the contents of your communications with us, including emails, form submissions, SMS and WhatsApp messages, Slack messages, and notes of consultation and coaching calls; and

4.1.7any other information you choose to provide to us.

4.2Information collected automatically. When you access the Website, we and our analytics and advertising partners may collect:

4.2.1your IP address, approximate geographic location derived from it, device type, operating system, browser type and version, and screen or device characteristics;

4.2.2pages and landing pages visited, referring URL, links clicked, form interactions, video engagement, session duration, and date and time stamps;

4.2.3email engagement data, including whether an email was delivered, opened, or clicked; and

4.2.4information collected by cookies, pixels, tags, local storage, and similar technologies, as further described at Clause 9.

4.3Session recordings and transcripts. Coaching sessions are recorded, and transcripts and automated meeting notes may be generated. This is dealt with separately at Clause 7.

4.4Information from third parties. We may receive Personal Information about you from Digistore24 as seller of record, from marketplace platforms through which you engage us, from persons who refer you to us, and from our analytics, advertising, and technology providers.

4.5Sensitive Personal Information. We do not seek Sensitive Personal Information and we ask that you do not provide it unless it is necessary. We recognize that, in the course of describing academic circumstances, a Client may voluntarily disclose information concerning health, disability, accommodation arrangements, or personal circumstances. Where that occurs, we process that information only to the extent necessary to deliver the Program, we do not use it for marketing or profiling, and we do not disclose it other than as set out in this Policy.

4.6Children. We do not knowingly collect Personal Information from anyone under the age of 18. See Clause 16.

5. How We Use Personal Information

5.1We use Personal Information for the following purposes:

5.1.1Assessment and enrollment - to review inquiries and applications, to assess whether a Program is suitable for you, to conduct consultation calls, to prepare proposals, and to enter into and administer an agreement with you;

5.1.2Program delivery - to schedule and conduct coaching sessions, to review Client Materials and provide structured written and verbal feedback, to prepare diagnostic reports, to provide templates, frameworks, and worksheets, to track progress, and to provide asynchronous support between sessions;

5.1.3Payments - to invoice you, to collect the fee and any installments, to take payment from a card on file, to manage failed or missed payments, and to recover overdue amounts;

5.1.4Communications - to respond to your inquiries, to send transactional and service messages relating to scheduling, delivery, payment, and account matters, and to provide support;

5.1.5Marketing - to send promotional emails, SMS messages, and WhatsApp messages where you have provided the consent required by Applicable Privacy Laws, and to conduct advertising and retargeting as described at Clauses 6 and 9;

5.1.6Improvement and analytics - to understand how the Website and our funnels perform, to measure the effectiveness of our advertising, and to improve the Services;

5.1.7Quality assurance - to review recordings and Client Materials internally for the purpose of maintaining coaching quality and consistency;

5.1.8Security and fraud prevention - to protect the Website and our systems, to detect and prevent unauthorized access, fraud, chargeback abuse, and misuse of our materials, and to maintain records of consent and acceptance;

5.1.9Legal and regulatory - to comply with our legal, tax, accounting, and recordkeeping obligations, to establish, exercise, or defend legal claims, and to respond to lawful requests from authorities.

5.2We do not use Client Materials to train artificial intelligence or machine learning models, and we do not permit our service providers to do so on our instructions.

5.3We do not make decisions producing legal or similarly significant effects concerning you based solely on automated processing.

6. How We Disclose Personal Information

6.1Service providers. We disclose Personal Information to third parties that perform functions on our behalf. The categories of recipient, and the providers currently engaged, are:

6.1.1customer relationship management, funnel hosting, forms, email and SMS delivery - GoHighLevel;

6.1.2payment processing for direct invoices issued outside the Digistore24 checkout, where used - Stripe. Program purchases made through the Digistore24 checkout are handled by Digistore24 Inc. as described at Clause 6.2;

6.1.3email, document storage, file sharing, and video conferencing - Google Workspace, including Gmail, Google Drive, Google Docs, and Google Meet;

6.1.4video conferencing for coaching sessions - Zoom;

6.1.5meeting notes and transcription - Fathom;

6.1.6scheduling - Calendly;

6.1.7delivery and project management - ClickUp;

6.1.8internal operations and knowledge management - Notion;

6.1.9internal and Client communications - Slack and WhatsApp;

6.1.10design and preparation of Client-facing materials - Canva;

6.1.11coaching delivery - independent contractor coaches engaged by us to deliver Programs, who receive Client information and Client Materials only for the purpose of coaching the Client to whom they are assigned, and who are bound by written confidentiality and data protection obligations to us;

6.1.12professional advisers, including our accountants and legal advisers, where necessary.

6.2Digistore24 as seller. Our Programs are sold through Digistore24 Inc., 360 Central Avenue, Suite 800, St. Petersburg, FL 33701, USA, which acts as the reseller and seller of record. When you purchase a Program you are directed to a checkout page hosted by Digistore24, and the personal information you enter there is collected by Digistore24 under its own privacy policy, not by us. Digistore24 is an independent controller of that information and is not our service provider. We receive from Digistore24 the information necessary to identify you as a purchaser and to deliver the Program, including your name, contact details, the Program purchased, and the status of your payment. We do not receive or store your payment card details.

6.3These providers act as service providers or contractors. They are permitted to process Personal Information only for the limited purpose of performing services for us, only in accordance with our written instructions, and are prohibited from retaining, using, or disclosing it for any other purpose, including their own commercial purposes. Disclosure to a service provider on this basis is not a sale or sharing of Personal Information. This list may change from time to time, and we will update this Policy accordingly.

6.4Advertising and analytics partners. We use Google Analytics 4, the Google Ads conversion tag, the Meta pixel, Microsoft Clarity and Vidalytics on the Website. Google Analytics 4 and the Google Ads conversion tag collect information about your interaction with the Website and transmit it to Google. The Meta pixel transmits that information to Meta. Google and Meta may combine it with information they hold and use it to deliver and measure advertising, including advertising directed to you on other websites and platforms. Microsoft Clarity records how visitors interact with the Website, including mouse movement, clicks, scrolling and the content of pages viewed, and transmits that record to Microsoft. Vidalytics provides us with analytics about how videos on the Website are used.

6.5Position on sale and sharing. We do not disclose Personal Information to third parties in exchange for money, and we do not disclose Personal Information to any third party for that third party’s own independent commercial purposes, other than as described in this Clause. However, our use of the advertising technologies described at Clause 6.4 constitutes “sharing” of Personal Information for cross-context behavioral advertising under the CCPA/CPRA, and may constitute a “sale” under certain United States state privacy statutes, which define those terms broadly and by reference to the exchange of value rather than money alone. We state this expressly rather than assert that no sale or sharing occurs. Your right to opt out is set out at Clause 12.

6.6Legal requirements and protection of rights. We may disclose Personal Information where we reasonably consider it necessary to comply with a legal obligation, subpoena, court order, or lawful request from a government or regulatory authority; to enforce our terms and agreements; to investigate suspected fraud, chargeback abuse, academic misconduct requests, or misuse of our materials; or to protect the rights, property, or safety of GradCollective, our Clients, our personnel, or the public.

6.7Business transfers. If we are involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, Personal Information may be transferred as part of that transaction, subject to Applicable Privacy Laws and to the recipient being bound by terms substantially consistent with this Policy.

6.8Aggregated and de-identified information. We may create and use aggregated or de-identified information that cannot reasonably be used to identify you. We will maintain and use such information in de-identified form and will not attempt to re-identify it, except as permitted by Applicable Privacy Laws.

7. Recording of Coaching Sessions

7.1Coaching sessions are recorded, and automated transcripts and meeting notes may be generated using Fathom.

7.2We recognize that a number of United States jurisdictions require the consent of all parties to the recording of a communication. Accordingly, we present a separate recording consent to each Client before the first session is recorded, and no session is recorded until that consent has been given. Consent may be withdrawn at any time, in which case subsequent sessions will not be recorded.

7.3Recordings and transcripts are stored in Google Drive within our Google Workspace environment. Access is restricted to the Client, the Client’s assigned coach (who may be an independent contractor engaged by us), and GradCollective’s quality reviewer.

7.4Recordings and transcripts are retained for twelve (12) months following the close of the engagement, after which they are deleted, unless a longer period is required to comply with a legal obligation or to establish, exercise, or defend a legal claim.

7.5Recordings are made available to the Client under a personal, non-exclusive, non-transferable license for the Client’s own study and reference. They may not be republished, shared, distributed, or resold.

8. Storage and Cross-border Processing

8.1We are established in Canada. Most of our service providers are established in, or store data in, the United States. Personal Information is therefore stored and processed both in Canada and in the United States, and may be transferred between them.

8.2Personal Information processed outside the country in which you are located is subject to the laws of the destination jurisdiction, and may be accessible to courts, law enforcement, regulatory authorities, and national security authorities of that jurisdiction under the laws of that jurisdiction. We use contractual and organizational measures to require comparable protection from our service providers, but we cannot exclude the operation of foreign law.

8.3If you would like further information about where your Personal Information is stored, or about the safeguards applied to a particular transfer, please contact [email protected].

9. Cookies and Tracking Technologies

9.1The Website uses cookies, pixels, tags, local storage, and similar technologies. The categories used are:

9.1.1strictly necessary - required for the Website and funnel to function, including session management, form submission, and security;

9.1.2analytics and performance - used to understand how visitors interact with the Website, including Google Analytics 4, Microsoft Clarity and Vidalytics;

9.1.3advertising and targeting - used to deliver and measure advertising and to retarget visitors, including the Meta pixel and the Google Ads conversion tag.

9.2We do not operate a cookie consent banner, on the basis that our Programs are offered to clients in the United States and Canada and that Applicable Privacy Laws in those jurisdictions do not require prior consent for the placement of these technologies. Instead, we provide the notice set out in this Clause, and the opt-out mechanisms described at Clauses 9.4 and 12.6.

9.3You may also control cookies through your browser settings. Disabling strictly necessary cookies may prevent parts of the Website from functioning.

9.4We recognize and honor the Global Privacy Control signal, and other opt-out preference signals that we are required to honor, as a valid request to opt out of the sharing of Personal Information for cross-context behavioral advertising for the browser or device from which the signal is received.

10. Marketing Communications

10.1Email. Because we are a Canadian sender, CASL applies to our commercial electronic messages in addition to the CAN-SPAM Act. We send commercial email only where we have express or implied consent as permitted by CASL. Every commercial email identifies GradCollective as the sender, provides current contact information, and includes a functioning unsubscribe mechanism. Unsubscribe requests are actioned promptly and in any event within ten (10) business days.

10.2SMS and WhatsApp. We send marketing SMS and WhatsApp messages only where you have given prior express written consent through a separate, unticked consent box that is not bundled with acceptance of any other terms. Consent to receive marketing messages is not a condition of purchasing any Program. Message and data rates may apply. You may opt out at any time by replying STOP, and may obtain assistance by replying HELP.

10.3Transactional messages. Messages relating to scheduling, session reminders, delivery, payment, and account administration are sent in connection with the Services you have purchased and are not marketing communications. You may continue to receive these messages after opting out of marketing.

10.4Consent records. We record and retain evidence of marketing consent, including the wording presented, the date and time of consent, and the source, for the period required by Applicable Privacy Laws and for so long as necessary to demonstrate compliance.

10.5Withdrawing consent to marketing does not affect the lawfulness of communications sent before withdrawal, and does not affect our ability to contact you in relation to a Program you have purchased.

11. Your Privacy Rights - Canada

11.1If you are located in Canada, or where PIPEDA or BC PIPA otherwise applies, you have the right to:

11.1.1request access to the Personal Information we hold about you, and information about how it has been used and to whom it has been disclosed;

11.1.2request correction of Personal Information that is inaccurate or incomplete;

11.1.3withdraw your consent to the collection, use, or disclosure of your Personal Information, subject to legal and contractual restrictions and on reasonable notice, recognizing that withdrawal may prevent us from continuing to provide a Program; and

11.1.4make a complaint about our handling of your Personal Information.

11.2Requests should be made to [email protected]. We will respond within thirty (30) days, or notify you within that period of any extension permitted by law.

11.3If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada, or to the Office of the Information and Privacy Commissioner for British Columbia. Contact details are set out at Clause 19.

12. Your Privacy Rights - United States

12.1This Clause applies if you are a resident of California or of another United States state that has enacted a comprehensive consumer privacy statute.

12.2Categories of Personal Information. In the preceding twelve months we have collected the following categories of Personal Information as those categories are defined by the CCPA/CPRA: identifiers; personal information categories listed in the California Customer Records statute; commercial information; internet or other electronic network activity information; geolocation data in approximate form; audio and visual information, being session recordings; professional or education-related information; and inferences drawn from the foregoing. The sources, purposes, and recipients are described at Clauses 4, 5, and 6.

12.3Disclosure and sharing. We have disclosed identifiers, commercial information, internet activity information, education-related information, and audio and visual information to the categories of service provider listed at Clause 6.1 for business purposes. We have shared identifiers and internet activity information with advertising partners for cross-context behavioral advertising, as described at Clauses 6.4 and 6.5. We have not disclosed Personal Information in exchange for money.

12.4Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes other than those permitted without the right to limit under the CCPA/CPRA.

12.5Your rights. Subject to verification and to the limits of applicable law, you have the right to:

12.5.1know the categories and specific pieces of Personal Information we have collected, the sources, the purposes, and the categories of recipient;

12.5.2request deletion of Personal Information we have collected from you;

12.5.3request correction of inaccurate Personal Information;

12.5.4opt out of the sale or sharing of your Personal Information for cross-context behavioral advertising;

12.5.5limit the use and disclosure of Sensitive Personal Information, where applicable; and

12.5.6not be subject to discriminatory treatment for exercising any of these rights. We will not deny you a Program, charge you a different price, or provide a different level of service because you have exercised a privacy right.

12.6How to exercise your rights. You may submit a request by emailing [email protected], or by using the “Do Not Sell or Share My Personal Information” link available in the footer of the Website. You may also opt out by transmitting a Global Privacy Control signal, as described at Clause 9.4.

12.7Authorized agents. You may use an authorized agent to submit a request on your behalf. We may require written authorization from you and may require you to verify your identity directly with us.

12.8Verification and timing. We will take reasonable steps to verify your identity before responding to a request to know, delete, or correct. We will acknowledge a request within ten (10) business days and respond within forty-five (45) days, which may be extended by a further forty-five (45) days where reasonably necessary, in which case we will notify you.

12.9Other states. Residents of other United States states with comprehensive privacy statutes may have equivalent rights, including rights of access, correction, deletion, portability, and opt-out of targeted advertising, together with a right to appeal a refusal of a request. We will honor those rights as required by the applicable statute. To appeal a decision, reply to our response or contact [email protected] with the word “Appeal” in the subject line

13. Data Retention

13.1We retain Personal Information only for as long as is reasonably necessary for the purposes described in this Policy, and thereafter as required to comply with legal, tax, accounting, and recordkeeping obligations, to resolve disputes, and to establish, exercise, or defend legal claims.

13.2Our ordinary retention periods are:

13.2.1inquiry and application information where no Program is purchased - twenty-four (24) months from last contact;

13.2.2Client account, correspondence, and Program delivery records - seven (7) years from the close of the engagement;

13.2.3Client Materials - twelve (12) months from the close of the engagement, unless the Client requests earlier deletion;

13.2.4session recordings and transcripts - twelve (12) months from the close of the engagement;

13.2.5payment and transaction records - as required by applicable tax and corporate law;

13.2.6marketing consent and opt-out records - for so long as necessary to demonstrate compliance and to give effect to an opt-out.

13.3Where Personal Information is no longer required, we securely delete it or de-identify it. Information held in backups is deleted in accordance with our backup cycle.

14. Data Security

14.1We maintain administrative, technical, and organizational measures designed to protect Personal Information against unauthorized access, loss, misuse, alteration, and disclosure. These include encryption in transit, access controls based on role and operational need, multi-factor authentication on business-critical systems, restricted sharing permissions on Client files, and selection of service providers with regard to their security posture.

14.2We do not receive or store full payment card numbers. Card data is handled by our payment processor within its own environment.

14.3No system, transmission, or storage method is completely secure. While we take reasonable steps to protect Personal Information, we cannot guarantee its absolute security. You should avoid transmitting highly sensitive information through unsecured channels, and should not send passwords, government-issued identification numbers, or payment card details through website forms or messaging channels.

15. Data Breach Notification

15.1If a breach of security safeguards occurs that creates a real risk of significant harm to an individual, we will report the breach to the Office of the Privacy Commissioner of Canada and notify the affected individuals as soon as feasible, as required by PIPEDA, and will maintain records of the breach as required.

15.2Where a United States state breach notification statute applies, we will provide notice to affected residents and to any regulator, within the time and in the manner that statute requires.

16. Children’s Privacy

16.1The Services are directed to adults. Our Programs are offered exclusively to PhD and doctoral candidates, and we require every Client to be at least eighteen (18) years of age.

16.2We do not knowingly collect Personal Information from any person under the age of eighteen (18), and we do not knowingly collect Personal Information from children under the age of thirteen (13) within the meaning of the Children’s Online Privacy Protection Act.

16.3If you believe that a person under the age of eighteen has provided Personal Information to us, please contact [email protected]. We will investigate and delete the information where appropriate.

17. Third-party Links and Services

17.1The Website may contain links to third-party websites, booking pages, payment pages, social media platforms, video content, and other external resources. We do not control those third parties and are not responsible for their content, security, or privacy practices.

17.2Before providing Personal Information to any third-party service, you should review that provider’s own privacy policy and terms.

18. Changes to This Policy

18.1We may update this Policy from time to time to reflect changes to the Services, our technology stack, our business practices, or Applicable Privacy Laws.

18.2When we make changes, we will revise the “Last Updated” date at the top of this Policy and publish the revised version on the Website. Where a change is material, we will take additional steps to notify you, which may include email notice or a prominent notice on the Website.

18.3Your continued use of the Website or the Services after a revised Policy takes effect will be subject to the revised Policy, to the extent permitted by Applicable Privacy Laws. Where a change requires your consent, we will obtain that consent separately.

Contact Information and Complaints

If you have questions about this Policy, wish to exercise a privacy right, or wish to make a complaint about our handling of Personal Information, please contact:

GradCollective - Privacy Officer

1543120 B.C. LTD., carrying on business as GradCollective

Unit 318 - 10168 149 Street, Surrey, British Columbia V3R 0E9, Canada

Privacy requests: [email protected]

Legal notices: [email protected]

We will acknowledge your complaint and investigate it. If you are not satisfied with our response, you may contact the following authorities:

Office of the Privacy Commissioner of Canada

Website: www.priv.gc.ca - Toll-free: 1-800-282-1376

Office of the Information and Privacy Commissioner for British Columbia

Website: www.oipc.bc.ca

By using the Website or the Services, you acknowledge that you have read and understood this Privacy Policy.