New England Training

This Privacy Policy ("Policy") is issued by Adam D. Smith, LLC ("Company") and governs data collection and usage on every website and brand the Company operates, including New England Training at newenglandtraining.com, Ummah English at www.ummahenglish.com and the company site at www.adamdsmithllc.com. For the purposes of this Policy, unless otherwise noted, all references to the Company include those websites and brands. The Company provides English language training through these websites. By using the Company website, you consent to the data practices described in this statement.

I. Collection of Your Personal Information

In order to better provide you with products and services offered, the Company may collect personally identifiable information, such as your:

• First and last name

• Mailing address

• Email address

• Phone number

• Employer

• Job title

• National ID, IP Address, Middle Names, Full Name in Native Language, Browser Information, Location Information, Device Information

If you purchase the Company's products and services, your card payment is processed by Stripe, which collects your card details directly under its own privacy policy. The Company receives your name, billing address and a record of the transaction, not your full card number.

The Company may also collect anonymous demographic information, which is not unique to you, such as your:

• Age

• Gender

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services. These may include: (a) registering for an account; (b) sending us an email message; (c) submitting your payment information when purchasing products and services. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We may also gather additional personal or non-personal information in the future.

II. Use of your Personal Information

The Company collects and uses your personal information in the following ways:

• to operate and deliver the services you have requested.

• to provide you with information, products, or services that you request from us.

• to provide you with notices about your account.

• to carry out the Company's obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• to notify you about changes to our websites or any products or services we offer or provide through them.

• to maintain the security of the Company's services and prevent fraud or misuse.

• to comply with applicable laws, regulations, legal processes, or governmental requests.

• to maintain the Company's internal records and administrative functions, to deliver services, and to maintain integrity of products and services.

• in any other way we may describe when you provide the information.

• for any other purpose with your consent.

The Company may also use your personally identifiable information to inform you of other products or services available from the Company and its affiliates.

III. Voice Recordings and Written Work

When you sit a Speaking paper, the site records your spoken answers through your browser. The recording is stored on the site with your attempt so that an examiner can listen to it, mark it and return feedback, and so that you can review your own work. We do not create voiceprints, facial recognition data, fingerprints or any other biometric identifier from these recordings, and we do not use them to identify you. Your written answers and recordings can be seen by you, by the examiner or teacher who marks them, and by the site administrator when support or maintenance requires it. Under the Terms and Conditions, work you submit becomes the property of the Company. Recordings are kept for as long as your account and course records are kept, or until you ask us to delete them, subject to the exceptions in Section XI.

IV. Sharing Information with Third Parties

The Company does not sell, rent, or lease its customer lists to third parties.

The Company does not sell, share or license your voice recordings, your written answers or any other personal data to third parties.

V. Disclosure of Non-public Personal Financial Information of Former Customers

The Company shall, in its Policy and in accordance with applicable law, describe the categories of non-public personal financial information of former users that it discloses, as well as the categories of third parties to whom such information is disclosed, excluding disclosures permitted by law or authorized under applicable regulatory exceptions.

Information Shared with Third Parties About Former Users:

In limited circumstances, such as registering students for placement exams such as the IELTS, we may provide necessary information such as Name, ID number, contact information, and payment status in order to complete registration.

Categories of Affiliates and Non-affiliated Third Parties Receiving Non-public Personal Financial Information:

• Service providers (our payment processor, hosting, backup, email and network security providers), who may use your information only to provide their service to the Company.

You have the right to opt out of the disclosure of your non-public personal information to non-affiliated third parties, subject to certain legal exceptions.

To exercise your opt-out right, you may contact us here:

• Website: www.newenglandtraining.com
• Email: adam@adamdsmithllc.com
• Phone Number: 508-510-1754

Your opt-out choice will apply to both current and former customers. Your opt-out direction may be submitted at any time and will remain effective until you revoke it in writing or electronically.

The Company may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to the Company, and they are required to maintain the confidentiality of your information.

The Company may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Company or the site; (b) protect and defend the rights or property of the Company; and/or (c) act under exigent circumstances to protect the personal safety of users of the Company, or the public.

VI. Opt-Out of Sale or Disclosure of Personal Information to Third Parties

The Company does not sell your personal information and does not share it for cross-context behavioral advertising. Under the California Consumer Privacy Act of 2018 (CCPA) and other privacy and data protection laws, as applicable, you have the right to know what personal information we collect, use and disclose, to request its deletion, and to opt out of any sale or sharing of your personal information. Because we do not sell or share personal information, no opt-out is required. To ask a question or make a request, email adam@adamdsmithllc.com or call 508-510-1754.

VII. Tracking User Behavior

The Company may keep track of the websites and pages our users visit within the Company, in order to determine which of the Company's services are the most popular. This data is used to improve the site and its courses. The Company does not serve advertising on its websites.

We use the learning platform's activity logs and xAPI statements to record and measure your actions and engagement with the site and courses, including course progress, test attempts and grades.

VIII. Automatically Collected Information

The Company may automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, access times, and referring website addresses. This information is used for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding the use of the Company website.

IX. Use of Cookies

The Site sets only the cookies it needs to work: a session cookie that keeps you logged in and a preference cookie that can remember your username. We set no advertising or analytics cookies. Our network security provider may also set a cookie to distinguish real visitors from automated traffic. If you block cookies, you cannot log in. Our Cookie Policy, published on this site, gives the details.

X. Security of Your Personal Information

The Company secures your personal information from unauthorized access, use, or disclosure. The Company uses the following methods for this purpose:

• SSL Protocol

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100 percent secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet that are beyond our control; and (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed.

XI. Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and

• Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, and provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise, use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.

Unless you ask us to delete it, and subject to the exceptions above, we keep your account, attempts, recordings, marks and feedback indefinitely, so that your record remains available to you and to us.

XII. Data Security and Breach Notification

The Company maintains reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, acquisition, disclosure, or use. In the event of a security incident involving personal information, the Company will promptly investigate the incident and provide notice to affected individuals and, where required, to applicable regulatory authorities in accordance with applicable law.

The Company will provide any required notice in the manner and within the timeframes prescribed by applicable law.

XIII. Age Requirements

You must be 18 years or older to use this platform. The Company does not knowingly collect personally identifiable information from anyone under the age of 18. If you believe a person under 18 has provided us with personal information, contact us at adam@adamdsmithllc.com and we will delete it.

XIV. Job Applications

If you apply for an opening through the careers page of a Company website, the Company collects what you enter on the application form: your name, your email address, the country and time zone you give, your account of your experience, your reasons for applying, and any link you choose to supply. The Company also records the time the form was sent and the IP address it was sent from. The address is used only to limit abuse of a form that anyone can reach, and it is cleared within a day.

This information is used to assess your application and to reply to you. It is stored on the website and is also sent by email to the address the Company uses for applications. Company staff who hold the site's manager role can read it. It is not sold, and it is not shared outside the Company except with the email provider that carries the message.

You do not need an account to apply, and applying does not create one. The Company keeps an application until you ask for it to be deleted. Section XI, Right to Deletion, applies to an application as it does to any other personal information, and a request goes to adam@adamdsmithllc.com.

XV. External Data Storage Sites

We may store your data on servers provided by third-party hosting vendors with whom we have contracted.

XVI. Changes to This Statement

The Company reserves the right to change this Policy from time to time. For example, when there are changes in our services, changes in our data protection practices, or changes in the law. When changes to this Policy are significant, we will inform you. You may receive a notice by sending an email to the primary email address specified in your account, by placing a prominent notice on our website, and/or by updating any privacy information. Your continued use of the website and/or services available after such modifications will constitute your: (a) acknowledgment of the modification of this Policy; and (b) agreement to abide and be bound by this modified Policy.

XVII. Contact Information

The Company welcomes your questions or comments regarding this Statement of Privacy. If you believe that the Company has not adhered to this Statement, please contact the Company at:

Adam D. Smith, LLC
41 W Hwy 14 #600
Spearfish, South Dakota 57783

Email Address:
adam@adamdsmithllc.com

Phone number:
508-510-1754

Effective as of September 11, 2026