MAKING THE MIDDLE™ PRIVACY POLICY 

Effective Date: January 2026 

Last Updated: January 2026 

Making the Middle™ (“MTM,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy  explains how we collect, use, disclose, and safeguard personal information when you interact with  our website, programs, content, or communities (collectively, the “Program”). 

1. Information We Collect 

Information You Provide 

Through your use of our website or interaction with the Program, we may collect your personal  information, including your: 

• Name 
• Email address 
• Billing address 
• Purchase history 
• Account login information (via Kajabi) 
• Communications you send to us 

Scholarship Applications (If Applicable) 

If you apply for a scholarship, we may collect additional personal information you voluntarily  provide as part of the application process. Any of this information collected through our  website is subject to this Privacy Policy. All information collected for scholarship applications is  used solely to review scholarship eligibility and is not sold or used for unrelated marketing  purposes. 

Automatically Collected Data 

 

Using automatic data collection technologies we may collect the below information, which may  include personal information: 

• IP address 
• Device and browser information 
• Approximate location 
• Pages viewed, timestamps, and usage data 

The technologies we use for this automatic data collection may include: 

• Cookies. A cookie is a small file placed on your device when you interact with the Program  website. You may refuse to accept or disable cookies by activating the appropriate setting  on your browser or device. However, if you select this setting, you may be unable to  access certain features of the Program. 
• Web Beacons. Some parts of the Program and our emails may contain small electronic  files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)  that permit MTM, for example, to count users who have visited those parts or opened an  email and for other related statistics (for example, recording the popularity of certain  content and verifying system and server integrity). 

We may use these automatic collection technologies to collect information about your online  activities over time and across third-party sites or other online services (behavioral tracking).  Using automatic collection technologies helps us to improve our Program and to deliver a better  and more personalized experience. 

To the extent any of these automated technologies are considered a personal data sale, targeted  advertising, or profiling, under applicable laws, depending on where you live, you may opt out  from use of these automated technologies for such uses by sending an e-mail to  hello@makingthemiddle.com. Please note that some Program features may be unavailable as a  result. 

Third Party Data Collection 

When you interact with the Program or our website, there are third parties that may use  automatic collection technologies to collect information about your or your device. These third  parties may include: 

• Advertisers, ad networks, and ad servers. 
• Third party providers for payment processing. 
• Analytics companies. 
• Your device manufacturer. 
• Your internet or mobile service provider.

 

These third parties may use tracking technologies to collect information about you when you use  the Program or our website. The information they collect may be associated with your personal  information or they may collect information, including personal information, about your online  activities over time and across different websites, apps, platforms, and other online services. They  may use this information to provide you with interest-based (behavioral) advertising or other  targeted content. 

We do not control these third parties' tracking technologies or how they may be used. If you have  any questions about an advertisement or other targeted content, you should contact the  responsible provider directly. 

Community & Social Media Data 

Your participation in any MTM Facebook groups or social media platforms is  completely voluntary and any information you provide on such platforms is subject to those  platforms’ privacy policies. MTM is not affiliated and has no connection with Facebook or any  other social media platforms whose links may be posted on our website.  

2. How We Use Information 

We use personal information to: 

• Deliver and manage Program access 
• Process payments and refunds (if applicable) 
• Review scholarship applications 
• Communicate with you about purchases and updates 
• Send marketing communications (where permitted) 
• Improve services and user experience 
• Secure systems and prevent fraud 
• Comply with legal obligations 
• Enforce our Terms & Conditions 

We do not sell personal information. 

3. Legal Bases for Processing (GDPR) 

Where applicable, processing of your information is based on: 

• Contractual necessity 
• Legitimate business interests
• Consent (marketing, cookies) 
• Legal obligations 

4. Choices About How We Use and Disclose Your Information 

We strive to  provide you with choices regarding the personal information you provide to us.This section describes mechanisms we provide  for you to control certain uses and disclosures of over your information.  

• Cookies and other Tracking Technologies. You can set your browser to refuse all or  some browser cookies, or to alert you when cookies are being sent. If you disable or refuse  cookies or block the use of other tracking technologies, some parts of the Program may  then be inaccessible or not function properly. Some browsers include a "Do Not Track"  (DNT) setting that can send a signal to the online services you visit indicating you do not  wish to be tracked. Because there is not a common understanding of how to interpret the  DNT signal, our Program may not respond to all browser DNT signals. Instead, you can  use the range of other tools to control data collection and use, including the cookie controls  and advertising controls described in this policy. 
• Promotion by MTM. If you do not want us to use your email address to promote our  products to you, you can opt-out by sending an email to hello@makingthemiddle.com with  the subject title “MARKETING OPT OUT.” 

5. Sharing of Information 

We may share your information that we collect or you provide: 

• To our subsidiaries and  affiliates. 
• To contractors, service providers, and other third parties we use to  support our business and who are bound by contractual obligations to keep personal  information confidential and use it only for the purposes for which we disclose it to them. 
• Legal authorities when required 
• Business partners in the event of restructuring or sale 
• To fulfill the purpose for which you provide it. For example, if you give us an email address  to subscribe to Program emails, we will transmit the contents of our Program emails to the  email address provided.  
• To enforce our rights arising from any contracts entered into between you and us, including  our Terms & Conditions, and for billing and collection. 
• For any other purpose disclosed by us when you provide the information. 
• With your consent.

6. Data Retention 

We retain personal information only as long as reasonably necessary for service delivery, legal  compliance, dispute resolution, fraud prevention and enforcement of agreements. This means  that we consider our legal and business obligations, potential risks of harm, and nature of the  information when deciding how long to retain information. At the end of the retention period,  personal information will be deleted, destroyed, or deidentified. 

If you are a California or EU resident, see your specific rights below for more information about  the retention periods that apply to the information we collect. 

7. Data Security 

 

We use commercially reasonable administrative, physical, and technical measures designed to  protect your information from accidental loss or destruction and from unauthorized  access, use, alteration, and disclosure. However, no website, mobile application, system,  electronic storage, or online service is completely secure, and we cannot guarantee the security  of your information transmitted to, through, using, or in connection with the Program. In particular,  email, texts, and chats sent to or from the Program may not be secure, and you should carefully  decide what information you send to us via such communications channels. Any transmission of  personal information is at your own risk. 

The safety and security of your information also depends on you. You are responsible for taking  steps to protect your personal information against unauthorized use, disclosure, and access. 

8. Your Privacy Rights 

EU/UK (GDPR) 

In regards to your personal information, you may request access, correction, deletion,  the right to be forgotten, restrict processing, portability, object to processing., and  the right to obtain human intervention. Send an email to hello@makingthemiddle.com with the  subject line: GDPR RIGHTS for any questions or requests related to this section.  

 

Your State Privacy Rights 

State consumer privacy laws may provide their residents with additional rights regarding our use  of their personal information. 

Many states, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa,  Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state  residents with rights to: 

• Confirm whether we process their personal information. 
• Access and delete certain personal information. 
• Correct inaccuracies in their personal information, taking into account the information's  nature processing purpose (excluding Iowa and Utah). 
• Data portability. 
• Opt-out of personal information processing for: 
• targeted advertising (excluding Iowa); 
• sales; or 
• profiling in furtherance of decisions that produce legal or similarly significant effects  (excluding Iowa and Utah). 
• Either limit (opt-out of) or require consent to process sensitive personal information or  process personal information of minors under 18, 17, or 16 years old. 

The exact scope of these rights may vary by state. To exercise any of these rights, please write us at: hello@makingthemiddle.com with subject line: Privacy Request. To appeal a decision  regarding a consumer rights request please write us at: hello@makingthemiddle.com with subject  line: Privacy Request.  

You may request to know, access, delete, or correct personal information. We do not discriminate  against users who exercise privacy rights. 

Nevada provides its residents with a limited right to opt-out of certain personal information sales.  Residents who wish to exercise this sale opt-out rights may submit a request to this designated  address: hello@makingthemiddle.com with subject line: Privacy Request. However, please know  we do not currently sell data triggering that statute's opt-out requirements. 

Privacy Notice To California Residents 

This notice to California Residents pursuant to the California Consumer Privacy Act and the  California Privacy Rights Act supplements the information contained in our Privacy Policy and  applies solely to employees, visitors, and other individuals who reside in the State of California  (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act  (“CCPA”), the California Privacy Rights Act (“CPRA”) and other California privacy laws. Any terms  defined in the CCPA and CPRA have the same meaning when used in this notice. 

Information We Collect 

We collect information that identifies, relates to, describes, references, is capable of being  associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or  device (“personal information”). In particular, we have collected the following categories of  personal information on consumers as defined under the CCPA and CPRA within the last twelve  (12) months:

Category	Examples	Collected
A. Identifiers	A real name, IP address, email address, or other similar  identifiers.	YES
B. Personal Information  Categories listed in the  California Customer    Records Statute (Cal. Civ.  Code §1798.80(e))	A name, signature, Social Security Number, address,  telephone number, passport number, driver’s license  number, insurance policy number, education,  employment history, bank account number, credit card  number, financial information, medical information, or  health insurance information.	YES
C. Protected classification  characteristics under    California or Federal law.	Age, race, ancestry, national origin, citizenship, religion,  marital status, medical condition, physical or mental  disability, sex (including gender, gender identity,  pregnancy, childbirth and related medical conditions),  sexual orientation, veteran or military status, genetic  information.	NO
D. Commercial information	Records of personal property, products or services  purchased, obtained, or considered, or other purchasing  or consuming histories or tendencies.	YES
E. Biometric Information	Genetic, physiological, behavioral, and biological  characteristics, or activity patterns used to extract a  template or other identifier or identifying information, such  as fingerprints, faceprints, and voiceprints, iris or retina  scans, keystroke, gait, or other physical patterns, and  sleep, health, or exercise data.	NO
F. Internet or similar    network activity	Browsing history, search history, information on  interaction with a website, application, or advertisement.	YES
G. Geolocation Data	Physical location or movements.	YES
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar  information.	NO

 

Category	Examples	Collected
I. Professional or    employment-related   information.	Current or past job history or performance evaluations.	NO
J. Non-public education  information (per the Family  Educational Rights and  Privacy Act (20 U.S.C.  Section 1232g; 34 CFR  Part 99).	Education records directly related to a student  maintained by an educational intuition or party acting on  its behalf, such as grades, transcripts, class lists, student  schedules, student identification codes, student financial  information, or student disciplinary records.	NO

 

Personal information does not include: 

• Publicly available information that is lawfully made available from government records,  that a consumer has otherwise made available to the public. 
• De-identified or aggregated consumer information. 
• Information excluded from the CCPA’s or CPRA’s scope, like: 

o Health or medical information covered by the Health Insurance Portability and  Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical  Information Act (CMIA) or clinical trial data; 

o Personal information covered by certain sector-specific privacy laws, including the  Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or  California Financial Information Privacy Act (FIPA) and the Driver’s Privacy  Protection Act of 1994. 

We obtain the categories of personal information listed above from the following categories of  sources: 

• Directly from you. For example, from forms you complete on our website or through the  Program. 
• Indirectly from you. For example, from observing your actions on our website or through  the Program. 
• We retain your data pursuant to our records retention policy. 
• Information collected through cookies includes Internet addresses, types of operating  systems, IP addresses, and browser software and pages accessed by users.  

Use Of Personal Information

We may use or disclose the personal information we collect for one or more of the following  business purposes: 

• To fulfill or meet the reason you provided the information. For example, if you share your  name, contact information, and applicable Program video information due to a Program  video malfunction, we will use that information to evaluate the cause of the malfunction. 
• To provide you with support and respond to your inquiries, including to investigate your  concerns and monitor and improve our responses. 
• To respond to law enforcement requests and as required by applicable law, court order,  or government regulations. 
• As described to you when collecting your personal information or as otherwise set forth in  the CCPA and CPRA. 
• To confirm your identity for lawful purposes connected with your employment including  access to secure systems. 
• We will not collect additional categories of personal information or use the personal  information we collected for materially different, unrelated, or incompatible purposes  without providing you notice. 

Disclosing Personal Information 

We may disclose your personal information to a contractor or service provider for a business  purpose. When we disclose personal information for a business purpose, we enter a contract that  describes the purpose and requires the recipient to both keep that personal information  confidential and not use it for any purpose except performing the contract. 

In the preceding twelve (12) months, we have disclosed the following categories (corresponding  with the table above) of personal information for a business purpose: Category A, Category B,  Category D, Category F, Category G. 

We disclose your personal information with the following categories of third parties: our service  providers and third parties to whom you authorize us to disclose your personal information in  connection with services we provide to you. 

In the preceding twelve (12) months, we have not sold or shared any personal information. Your Rights And Choices 

The CCPA and CPRA provide California residents with specific rights regarding their personal  information. This section describes your CCPA and CRPA rights and explains how to exercise  those rights. 

Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and  use of your personal and sensitive information unless responding to the request is impossible or 

involves disproportionate effort. Once we receive and confirm your verifiable request, we will  disclose to you: 

• The categories of personal information and sensitive information we collected about you. 
• The categories of sources for the personal and sensitive information we collected about  you. 
• Our business or commercial purpose for collecting, using and/or disclosing that  information. 
• The categories of third parties, contractors and service providers with whom we share,  sell or disclose that personal information. 
• The specific pieces of personal information we collected about you (also called a data  portability request). 
• If we disclosed your personal information for a business purpose, a list of those  disclosures, identifying the personal information categories that each category of recipient  obtained. 
• Whether your information is sold or shared. 
• The retention period or criteria used for retention. 

Deletion and Correction Request Rights 

You have the right to request that we correct or delete any of your personal information that we  collected from you and retained, subject to certain exceptions. Once we receive and confirm your  verifiable request, we will correct and/or delete (and direct our service providers to correct and/or  delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service  provider(s) to: 

• Complete the transaction for which we collected the personal information, provide a good  or service that you requested, take actions reasonably anticipated within the context of  our ongoing business relationship with you, or otherwise perform our contract with you. 
• Help to ensure security and integrity to the extent the use of the consumer’s personal  information is reasonably necessary and proportionate for those purposes. 
• Debug products to identify and repair errors that impair existing intended functionality. 
• Exercise free speech, ensure the right of another consumer to exercise their free speech  rights, or exercise another right provided for by law. 
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §  1546 et. seq.). 
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public  interest that adheres to all other applicable ethics and privacy laws, when the information’s 

deletion may likely render impossible or seriously impair the research’s achievement, if  you previously provided informed consent. 

• Enable solely internal uses that are reasonably aligned with consumer expectations based  on your relationship with us. 
• Comply with a legal obligation. 

Exercising Access, Data Portability, Correction and Deletion Rights 

To exercise the right to know, data portability, delete, or correct described above, please submit  a verifiable request to us by either: 

 

• Emailing us at hello@makingthemiddle.com.  
• By regular mail at: 7750 Clayton Rd. Suite 108. St. Louis, MO 63117.

Only you, or a person registered with the California Secretary of State that you authorize to act  on your behalf, may make a verifiable request related to your personal information. You may also  make a verifiable request on behalf of your minor child. 

You may only make a verifiable request for access or data portability twice within a 12-month  period. The verifiable request must: 

• Provide enough information that allows us to reasonably verify you are the person about  whom we collected personal information or an authorized representative. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate,  and respond to it. 

We cannot respond to your request or provide you with personal information if we cannot verify  your identity or authority to make the request and confirm the personal information relates to you.  We will only use personal information provided in a verifiable request to confirm the requestor’s  identity or authority to make the request. 

Response Timing and Format 

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we  require more time, we will inform you of the reason and extension period in writing. We will deliver  our written response by mail or electronically, at your option. Any disclosures we provide will only  cover the 12-month period preceding the verifiable request’s receipt. The response we provide  will also explain the reasons we cannot comply with a request, if applicable. For data portability  requests, we will select a format to provide your personal information that is readily useable and  should allow you to transmit the information from one entity to another entity without hindrance,  specifically by electronic mail communication. 

We do not charge a fee to process or respond to your verifiable request uwnless it is excessive,  repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell 

you why we made that decision and provide you with a cost estimate before completing your  request. 

Personal Information Sales Opt-Out and Opt-In Rights 

MTM does not sell your personal information. 

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless  permitted by the CCPA or CPRA, we will not: 

• Deny you services. 
• Provide you a different level of service. 
• Discriminate in making employment decisions. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits employees that are  California residents to request certain information regarding our disclosure of personal information  to third parties for their direct marketing purposes. To make such a request, please send us an  electronic message via hello@makingthemiddle.com. 

Changes To Notice 

MTM may make changes to this Notice. Notification of changes will be posted on this page. You  should review this Notice periodically to keep up to date on our most current policies and  practices. 

Date Of Last Update: January 2026 

Questions And Contact Information 

If you have questions regarding this Notice, please contact MTM  

at hello@makingthemiddle.com. 

Requests: 

Email hello@makingthemiddle.com with subject line: Privacy Request 

9. Children’s Privacy 

The Program is not intended for children under 18 years of age. No one  under age 18 may provide any personal information about themselves or anyone else under 18.  We do not knowingly collect personal information from children under 18. If you are under 18,  do not use or provide any information on this website or to the Program or create an account with  MTM, or provide any information about yourself to us, including your name, address, telephone  number, email address, or any screen name or user name you may use. If we learn we have  collected or received personal information from a child under 18 without verification of parental 

consent, we will delete that information. If you believe we might have any information from or  about a child under 18, please contact us at hello@makingthemiddle.com. 

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding  the collection and sale of their personal information. Please see Your State Privacy Rights for  more information. 

10. International Transfers 

Data may be processed anywhere in the United States. By using our services, you consent to our transfer of your data for processing where permitted by law. 

11. Updates 

We may update this policy from time to time, and we will provide  notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at  the top of the page. We will notify you of changes to this policy by updating the "last updated"  date and posting the updated policy online. We may email or otherwise communicate reminders  about this policy, but you should check www.makingthemiddle.com periodically  to see the current policy and any changes we have made to it. Your continued use of the Program  after we make changes as described here is deemed to be acceptance of those changes, so  please check the policy periodically for updates. 

12. Contact 

Email: hello@makingthemiddle.com 

Business: Making the Middle™