Tooling University, LLC (the "Company" or "Tooling University") is committed to protecting your online privacy while you use the services provided by the Company. Tooling University provides high-quality training on a wide variety of industrial manufacturing topics.

This policy describes the types of information we may collect from you or that you may provide by any of the following means (collectively, the "Tooling University Platforms"):

• When you visit the website https://www.toolingu.com and its subdomains (the "Tooling University Website").
• Through Company mobile and desktop applications you download from the Company or third-party app stores, which provide dedicated non-browser-based interaction between you and the Tooling University Platforms.
• In email, text, and other electronic messages between you and the Company.
  
  

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by the Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Tooling University Platforms.

We urge you to read this privacy statement in its entirety so that you will understand all of the practices and procedures that relate to your privacy. If you do not agree with our policies and practices, your choice is not to use the applicable Tooling University Platforms. By accessing or using the Tooling University Platforms, you agree to this privacy policy. This policy may change from time to time (see Modifications to our Privacy Policy). Your continued use of the Tooling University Platforms after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Tooling University Privacy Statement

Overview

This Privacy Statement addresses your privacy by:

• Informing you about:
  • The type of personal information the Company collects about you through the Tooling University Platforms;
  • How that information is collected;
  • The general purposes for which information is collected;
  • What disclosures of information will be made; and
  • How, and to what extent, you can limit those disclosures.
• Assuring you that:
  • Reasonable precautions are taken to protect your personal information from loss, misuse, unauthorized access, disclosures, alteration, or destruction;
  • Company employees who have access to your personal information are informed about our privacy procedures for protecting such information;
  • Reasonable policies and procedures are in place to ensure that the Company gathers only the information it needs in order to perform the tasks listed below and that your personal information is retained only as long as necessary for the purposes for which it was gathered;
  • Reasonable policies and procedures are in place to ensure that your personal information is retained only as long as necessary for the purposes for which it was gathered;
  • You have reasonable access to any personal information you provide; and
  • There is a procedure for correcting, modifying, or deleting your personal information, if appropriate.

Data Protection and Accountability

The Company is responsible for your personal Information under its control. The Company has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The Company has appointed an officer who is accountable for the Company's compliance with these privacy principles. The Company's privacy officer can be reached by telephone at (800) 733-4763, by e-mail at privacy@sme.org or by regular mail to SME, 1000 Town Center, Suite 1910, Southfield, Michigan 48075. Questions, requests for copies of policies or practices, comments or challenges concerning compliance should be directed to the privacy officer.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Tooling University Platforms, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, neither Tooling University's computer systems, data storage systems, nor data transmission over the Internet, can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of your personal information.

Children Under the Age of 16

The Tooling University Platforms are not intended for children under 16 years of age and we do not use the Tooling University Platforms to knowingly solicit data from or market to children under the age of 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact the Company's privacy officer, as provided above.

Collection of Personal Information

We collect several types of information from and about users of the Tooling University Platforms, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number or any other identifier by which you may be contacted online or offline ("Personal Information");
• that is about you, but individually does not identify you, such as your profession or the school you attend; and/or
• about your internet connection, the equipment you use to access the Tooling University Platforms and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Tooling University Platforms. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and/or
• from third parties, for example, companies or schools you are associated with.
  
  

Information You Provide to Us

There are times when you may fill out a form on the Tooling University Platforms or we may ask you for personal information including, but not limited to Personal Information. This information will be requested only when needed to complete a transaction for which such information is necessary. We will not collect sensitive information (e.g. political or religious beliefs, ethnic origin, sexual orientation, health, or medical condition).

Automatic Information Collection

Some information about your IP address, web browser, and computer system is automatically transmitted to our web servers as an integral part of the operation of the Internet, and we reserve the right to automatically collect and/or track such data as well as information on what pages of the Website visitors access and the date and time of a user's visit. In addition, information regarding what pages or functions of the Tooling University Platforms you access may be combined with data regarding your school or company and used and disclosed in a non-personally identifiable manner.

Information Collection Technologies

We reserve the right to use cookies and related technologies on our Website.

A "cookie" is a persistent, client-side, hypertext transfer protocol file. Cookies are pieces of information that a Website can transfer to a visitor's hard drive for record-keeping purposes. Cookies facilitate web surfing by saving visitor preferences and other information. The rise of cookies is a widespread industry standard and thus many major websites use cookies. Using a cookie allows record-keeping while you are visiting a Website and saves you the extra effort of entering certain information multiple times in one site.

Most browsers are initially configured to accept and process cookies. You can configure your browser to refuse cookies. Extensive information concerning cookies is available on the World Wide Web by searching for the word "cookies." If you have any questions concerning our use of cookies, please contact our privacy officer.

Use of Personal Information

Personal Information

Personal Information we collect will be used for:

• billing you appropriately for contracted transactions and services;
• performing the services you request and provide the goods you request;
• responding to your inquiries;
• providing general information that may be of interest to you;
• editorial and feedback purposes;
• monitoring and improving our internal operations;
• producing statistical and/or demographic data for use by advertisers, potential advertisers, and other business partners;
• customizing content and layout of our site;
• monitoring user participation and performance in training programs and identifying skill gaps;
• marketing and promotional purposes as permissible under applicable law; and
• for any other purpose with your consent.

We will protect Personal Information against unauthorized access in accordance with applicable law.

Aggregated, Non-Personally Identifiable Data

• monitoring and improving our internal operations;
• producing statistical and/or demographic data for use by advertisers, potential advertisers, and other business partners;
• customizing content and layout of our site; and
• marketing and promotional purposes as permissible under applicable law.

Disclosure of Personal Information to Third Parties

By using the Tooling University Platforms and providing the Company with data, you acknowledge and agree that the Company may use the data collected as set forth herein, and to provide the information to other selected third parties which may be outside your resident jurisdiction. In addition, such data may be stored on servers located in other jurisdictions and transferred between jurisdictions. By providing the Company with your data, you consent to the transfer of such data.

We will not disclose Personal Information if such disclosure is prohibited under applicable law, and we will comply with applicable law in connection with any disclosures that are permitted thereunder. Any third party we share, rent, sell or otherwise disclose data to will be prescreened by us as part of reasonable efforts to ascertain that they are reputable and that they will use the Personal Information only for the processing purposes we request or marketing purposes that we determine you might be interested in and in accordance with applicable law. In all events, we will comply with our privacy obligations, if any, under FERPA. We will use reasonable efforts to make sure that all such third parties are contractually prohibited from using or disclosing Personal Information for any purposes other than for that which they have been engaged and they are contractually required to maintain the security of the Personal Information provided by the Company, and to process such Personal Information only on our instructions, in compliance with this Privacy Statement, and in an appropriate confidential and secure manner.

In accordance with California law, California residents are entitled to request certain disclosures regarding certain Personal Information the Company may provide to third parties for direct marketing purposes. Such disclosures will be provided to you, if required by law, and upon written request directed to the Company at: privacy@sme.org or by regular mail to SME, 1000 Town Center, Suite 1910, Southfield, Michigan 48075.

Family Educational Rights and Privacy Act

We comply with the Family Educational Rights and Privacy Act ("FERPA"), which affords students over 18 years of age certain rights with respect to their education records, including the right to inspect and review the student's education records, the right to amend inaccurate records, and the right to consent to disclosure of personally identifiable records.

By using the Tooling University Platforms, You authorize us to release the information contained in the Tooling University system to the educational institution in which you are enrolled and to any authorized representatives of any clinical institutions/entities where you will participate in a clinical rotation (this information is only to be used for the purpose of documenting compliance with clinical site requirements for participating in such clinical rotations).

You understand that you are not required to give this consent, but such consent is a condition to receiving certain services provided through the Tooling University Platforms.

Consent and Opting Out

Our server does not automatically record Personal Information. Such information can become known to the Company only when you voluntarily submit it. By submitting your Personal Information, you are consenting to the collection, export, transfer, transport, transmission, use, or disclosure of your Personal Information.

You may opt out of having your Personal Information, Directory Information, or Education Records shared with third parties by contacting us by written request directed to the Company at: privacy@sme.org or by regular mail to SME, 1000 Town Center, Suite 1910, Southfield, Michigan 48075. Please note that in order to fulfill certain obligations, we may need to continue providing certain Personal Information or Education Records (as defined under FERPA) to your school or employer, or sending you notices or other important information concerning your account.

Access to and Ability to Correct or Delete Personal Data

You may request, via e-mail or regular mail, that we provide you with a summary of personal information we retain concerning you or that we modify or delete any personal information we retain concerning you. Students participating in training programs may request removal of certain personal information in accordance with this Privacy Policy. We reserve the right, for security reasons, to verify your identity before performing your requests.

Special Circumstances

Due to the existing legal, regulatory, and security environment, the Company may be required, under certain circumstances, to disclose records about usage of the Tooling University Platforms, including Personal Information and/or Educational Records. We will attempt to limit such disclosure to instances where we believe in good faith that we are required to do so in response to a subpoena or other legal process; where it is reasonably required to do so in order to maintain, update or otherwise implement our data security measures, equipment, technical operations and the like; or where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights.

Additionally, we may sell or otherwise transfer such information to a successor of the Company in connection with an asset sale, merger, consolidation, divestiture, stock sale, or other corporate transaction, or by way of assignment (whether by operation of law or otherwise) in connection with any such or similar transaction or in connection with a liquidation or the administration of a bankruptcy estate.

Modifications

This Privacy Statement, along with the additional Student Privacy Statement listed below, were issued on May 11, 2022 and are subject to future modification at the election of the Company. In the event of a material modification to the terms and conditions of these Privacy Statements, the Company will post a notice on this page advising you of any such changes.