Privacy

Privacy Policy

CCPA/CPRA + state privacy lawsprivacy framework
8 July 2026last reviewed

This Privacy Policy explains how Walsh Advisors, Inc. doing business as GenuineShift (trading as GenuineShift) collects, uses, discloses, and protects personal information when you visit our website, access our courses or programmes, purchase services, communicate with us, or otherwise use GenuineShift services. It also explains the privacy rights available to you under applicable United States privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act and other applicable state privacy laws.

1. Introduction

We are responsible for decisions about how personal information is processed when we operate our website, programmes, communications, and customer support. For those activities, we act as the business or controller under applicable United States privacy law. Where we process information on behalf of an organisational customer under a written agreement, that customer may determine the purposes of processing and we process the information according to that agreement.

We collect only information that is reasonably necessary for the purposes described in this policy. We do not intentionally collect sensitive personal information unless you choose to provide it to us or it is needed to provide a service you requested.

2. Information we collect

We may collect contact details, account and login information, programme enrolment and progress information, purchase and transaction details, communications, support requests, usage data, device information, and cookie or similar technology data.

3. How we use information

We use personal information to provide and improve our programmes and services, manage accounts, process purchases, respond to enquiries, maintain security, personalise learning or communications, comply with legal obligations, and measure website and service performance.

4. Cookies and analytics

We use cookies and similar technologies for essential site operation, preferences, analytics, and marketing where permitted. Details live in our Cookie Policy, and you can manage choices using the cookie consent control.

5. Sharing personal information

We share personal information with service providers and sub-processors that help us operate the website, deliver programmes, process payments, host content, analyse usage, protect against fraud or abuse, and communicate with users. We may also disclose information where required by law, to protect rights and safety, or in connection with a business transaction.

6. Your privacy rights

Depending on where you live, you may have the right to access, correct, delete, or obtain a copy of personal information; to opt out of certain sharing or targeted advertising; to limit use of sensitive personal information where applicable; and to appeal certain decisions. You can exercise these rights through our privacy request form.

7. Retention

We keep personal information only for as long as necessary for the purposes described in this policy, including to provide services, maintain records, comply with legal obligations, resolve disputes, and enforce agreements.

8. International transfers

We are based in the United States and use service providers that may process information in the United States and other countries. Where personal information is transferred internationally, we use contractual, organisational, and technical safeguards designed to protect that information in line with applicable United States privacy and data protection requirements.

9. Contact and requests

Questions, privacy requests, and accessibility or policy enquiries should be submitted through our contact us route so they can be logged and handled consistently.