Privacy Policy

(for Natulo — a brand of Consulting on Demand LLC)

Last Updated: July 2026

1. Who We Are

This Privacy Policy explains how Consulting on Demand LLC, a California limited liability company ("we," "our," "us"), collects, uses, discloses, retains, and protects personal information.

"Natulo" is a course brand and trademark of Consulting on Demand LLC. It is not a separate company. Consulting on Demand LLC is the data controller and the entity responsible for the practices described in this policy.

This policy applies to our website, our online courses, our live sessions, and all related services (the "Services").

Privacy contact: privacy@consulting-ondemand.com Mailing address: [FULL MAILING ADDRESS]

2. Age Requirements — Please Read First

Our Services are for students aged 13 and older. We do not knowingly collect personal information from anyone under the age of 13.

At enrollment, we ask for the student's date of birth in order to confirm eligibility. We use date of birth solely to determine age eligibility. If we learn that we have collected personal information from a child under 13, we will delete it and cancel the enrollment with a refund of unused fees. If you believe a child under 13 has provided us information, contact us at privacy@consulting-ondemand.com.

3. Information We Collect

From the Enrolling Adult: name, email, billing information (processed by our payment processor; we do not store full card numbers), and mailing address where provided.

About the student: first name, age/date of birth (for eligibility), grade level, and coursework, progress, and submissions created during the course.

Session recordings: audio and video of live sessions in which the student participates. Under the amended COPPA Rule, this includes audio recordings and any biometric identifiers such as voiceprints or face templates.

Automatically: limited technical and usage data (e.g., device/browser type, pages viewed) collected through our website and analytics tools.

4. How We Use Information

We use information to: provide and deliver the courses; communicate about enrollment, scheduling, and support; process payments; maintain security; comply with law; and — only with the Enrolling Adult — send administrative and, where consented, marketing communications.

We do not market to students, build advertising profiles from student data, or use student information for targeted advertising. Any marketing consent is collected separately from the Enrolling Adult and applies only to the adult.

5. How We Share Information

We share information with: service providers who help us operate (payment processor, hosting, the learning platforms named in our Terms, such as Salesforce Trailhead and Slicer Cloud, and communication tools), each under contract; and authorities where required by law or to protect rights and safety. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

6. Do Not Track and Third-Party Tracking

Some browsers offer a "Do Not Track" signal. Because there is no common standard, we do not currently respond to Do Not Track signals. We do not permit third parties to collect personally identifiable information about our users across different websites over time through our Services, other than the analytics and service providers described here. Where we use analytics on a site available to minors, we disable advertising features and signals.

7. Security

We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including access controls and, for accounts, two-factor authentication. No system is perfectly secure; we cannot guarantee absolute security.

8. Data Retention Schedule

We keep personal information only as long as needed for the purposes described in this policy, then delete or de-identify it on the following schedule:

• Session recordings: deleted at the end of the cohort plus 30 days.

• Student coursework and progress data: retained for the duration of enrollment and for [X] thereafter, then deleted.

• Enrollment and billing records: retained as required for tax, accounting, and legal purposes (generally [X] years), then deleted.

• Marketing contact data (Enrolling Adult): retained until consent is withdrawn.

We collect children's information described above in order to deliver and support the courses, verify eligibility, and communicate with the Enrolling Adult, and we delete it on the timeframes stated here.

9. Recordings and Media Consent

California is an all-party consent state. Enrollment includes consent to record the student during live sessions for instructional use only. If a parent or other person is present and audible during a session, their consent is included. Posting a session recording that shows other students requires the consent of those families. We do not use recordings for marketing unless you sign a separate media release granting that permission.

10. Your Privacy Rights

Depending on your residency, you may have rights to access, correct, delete, or obtain a copy of personal information, and to withdraw marketing consent. California residents may exercise rights under the CCPA/CPRA. To make a request, contact privacy@consulting-ondemand.com. We will not discriminate against you for exercising these rights.

Additional California disclosures:

• We do not sell or share personal information for cross-context behavioral advertising, and have not done so in the preceding 12 months.

• We do not use or disclose sensitive personal information beyond the purposes permitted for providing the Services.

• We have not knowingly sold or shared the personal information of any consumer under 16 years of age.

11. Data Breach

If a breach affecting personal information occurs, we will notify affected individuals and any authorities as required by California Civil Code § 1798.82 and other applicable law, without unreasonable delay.

12. Students Outside California and the U.S.

The Services are intended for users in the United States, and information is processed in the United States. 

13. Third-Party Platforms

Our courses require student accounts on third-party learning platforms, which may include Salesforce Trailhead and Slicer Cloud. Those platforms collect information directly from the student under their own privacy policies, which we do not control. Review them before enrolling. The Enrolling Adult is responsible for creating and supervising those accounts and for providing any parental consent those platforms require.

14. Changes to This Policy

We may update this policy. If we make a material change to how we handle information already collected, we will notify Enrolling Adults by email at least 15 days in advance and post the updated policy with a new "Last Updated" date. We will not use previously collected personal information in a materially different way without notice and, where required, consent.

15. Contact Us

Consulting on Demand LLC 40381 Trenton Ct., Temecula, CA 92591 Privacy inquiries: privacy@consulting-ondemand.com Phone: 714-263-5976