PRIVACY POLICY

Effective Date: February 26, 2026

Last Updated: February 26, 2026

1. INTRODUCTION

Welcome to ABC Sales Training LLC (doing business as "Closer Over College"). We operate the following websites and platforms:

abcsalestraining.com

closerovercollege.com

learn.closerovercollege.com

closedealsgetpaid.com

learn.closedealsgetpaid.com

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites, purchase our products, use our services, or interact with us through email, text messages, or phone calls.

By using our websites or services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our websites or use our services.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you of any changes by updating the "Last Updated" date at the top of this Privacy Policy. You are encouraged to review this Privacy Policy periodically to stay informed of updates.

2. CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

ABC Sales Training LLC

[YOUR BUSINESS ADDRESS]

[City, State ZIP]

Email: [email protected]

Phone: 501-690-5458

3. INFORMATION WE COLLECT

We collect information that you provide directly to us, as well as information that is automatically collected when you use our websites or services.

3.1 Personal Information You Provide

We may collect the following personal information when you:

Fill out forms on our websites (contact forms, opt-in forms, registration forms)

Purchase our products or services

Create an account or login to our course platform

Subscribe to our email list or SMS notifications

Communicate with us via email, phone, or chat

Participate in surveys, promotions, or contests

The personal information we collect may include:

First name and last name

Email address

Phone number

Billing address

Shipping address

Payment information (processed securely by our payment processors)

Account login credentials (username and password)

Any other information you choose to provide

3.2 Information Collected Automatically

When you visit our websites, certain information is automatically collected by our web servers, analytics tools, and third-party services. This may include:

Device Information: IP address, browser type, operating system, device type, and unique device identifiers

Usage Data: Pages visited, time spent on pages, links clicked, referring website, and other navigation data

Location Data: Approximate geographic location based on your IP address

Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to collect information about your browsing activity (see Section 5 for details)

3.3 Information from Third Parties

We may receive information about you from third-party sources, including:

Payment processors (Stripe, PayPal, Affirm, Klarna, Cash App, Venmo, Amazon Pay, Apple Pay, Google Pay, Zelle, and financial institutions for ACH and wire transfers)

Advertising platforms (Facebook/Meta, TikTok, Google)

Analytics providers (Google Analytics)

Marketing and CRM platforms (GoHighLevel)

Webinar platforms (Zoom)

4. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

4.1 To Provide and Improve Our Services

Process and fulfill your orders

Deliver digital products and course content

Provide customer support and respond to inquiries

Manage your account and login access

Send transactional emails and notifications (order confirmations, receipts, password resets, course updates)

Improve our websites, products, and services based on user feedback and behavior

4.2 For Marketing and Communication

Send you marketing emails about our products, services, promotions, and updates (you can opt out at any time)

Send you text messages (SMS) with appointment reminders, order notifications, marketing offers, and service updates (you can opt out at any time by replying STOP)

Contact you by phone for sales, support, or follow-up purposes

Personalize your experience and show you relevant content and offers

4.3 For Analytics and Advertising

Analyze website traffic and user behavior using Google Analytics and other analytics tools

Track the effectiveness of our marketing campaigns

Display targeted advertisements to you on third-party platforms (Facebook, TikTok, Google) based on your activity on our websites (remarketing/retargeting)

Create lookalike audiences and custom audiences for advertising purposes

Measure ad performance and optimize our advertising strategies

4.4 For Legal and Security Purposes

Comply with legal obligations and respond to legal requests

Protect our rights, privacy, safety, or property, and that of our users

Prevent fraud, abuse, or unauthorized access

Enforce our Terms of Service and other agreements

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to collect information about your browsing activity and improve your experience on our websites.

5.1 What Are Cookies?

Cookies are small text files that are stored on your device when you visit a website. They allow the website to recognize your device and remember information about your visit.

5.2 Types of Cookies We Use

We use the following types of cookies:

Strictly Necessary Cookies: These cookies are essential for the operation of our websites. They enable core functionality such as security, network management, and accessibility. You cannot opt out of these cookies.

Performance Cookies: These cookies collect information about how you use our websites, such as which pages you visit most often. This data helps us improve the performance and user experience of our websites. We use Google Analytics for this purpose.

Functional Cookies: These cookies allow our websites to remember choices you make (such as your login information or language preferences) and provide enhanced, more personalized features.

Advertising/Targeting Cookies: These cookies are used to deliver advertisements that are relevant to you and your interests. They also limit the number of times you see an ad and help measure the effectiveness of advertising campaigns. We use Facebook Pixel and TikTok Pixel for this purpose.

5.3 Third-Party Cookies

Some cookies are placed by third-party services that appear on our pages. We do not control these third-party cookies. Please review the privacy policies of these third parties for more information:

Google Analytics: https://policies.google.com/privacy

Facebook/Meta: https://www.facebook.com/privacy/explanation

TikTok: https://www.tiktok.com/legal/privacy-policy

5.4 How to Manage Cookies

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies. However, if you disable cookies, some features of our websites may not function properly.

To learn more about cookies and how to manage them, visit: www.allaboutcookies.org

For EU Visitors: We will ask for your consent before placing non-essential cookies on your device. You can manage your cookie preferences at any time through our cookie consent banner.

6. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. However, we may share your information with trusted third-party service providers and partners in the following circumstances:

6.1 Service Providers

We share information with third-party companies that help us operate our business and provide our services. These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

Our service providers include:

Payment Processors: Stripe, PayPal, Affirm, Klarna, Cash App, Venmo, Amazon Pay, Apple Pay, Google Pay, Zelle, and financial institutions that process ACH and wire transfers. These providers collect and process payment information securely. We do not store your full credit card or bank account information on our servers.

CRM and Email Marketing Platform: GoHighLevel. We use GoHighLevel to manage customer relationships, send marketing emails, deliver SMS messages, and automate communications.

Webinar Platform: Zoom. We use Zoom to host live webinars, training sessions, and group calls.

Analytics Providers: Google Analytics. We use Google Analytics to understand how visitors use our websites and to improve our services.

Advertising Platforms: Facebook/Meta, TikTok, and Google. We share limited information (such as email addresses, phone numbers, and website activity) with these platforms to deliver targeted advertisements, measure ad performance, and create custom and lookalike audiences.

Hosting and Infrastructure Providers: We use third-party hosting services to store data and deliver our websites and course content.

6.2 Marketing Partners

We may share customer data with marketing partners for the purpose of creating lookalike audiences, running joint promotions, or delivering targeted advertising. This may include sharing hashed email addresses or phone numbers with advertising platforms.

Important Note for SMS Opt-In Data: We do NOT share your mobile phone number or SMS opt-in consent with third parties for their marketing purposes. Your opt-in data for text messaging is used exclusively by us and our authorized SMS service provider (GoHighLevel). See Section 8 for full SMS privacy details.

6.3 Business Transfers

If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or use of your personal information.

6.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (such as a court order, subpoena, or government agency).

We may also disclose your information when we believe disclosure is necessary to:

Protect our rights, property, or safety, or that of our users or the public

Prevent fraud, abuse, or security threats

Enforce our Terms of Service or other agreements

7. EMAIL COMMUNICATIONS

7.1 Marketing Emails

We may send you marketing emails about our products, services, promotions, and updates. You can opt out of receiving marketing emails at any time by:

Clicking the "unsubscribe" link at the bottom of any marketing email

Contacting us at [email protected]

Updating your email preferences in your account settings (if applicable)

Please note: Even if you opt out of marketing emails, we may still send you transactional emails related to your account, purchases, or services (such as order confirmations, receipts, password resets, and important service updates).

7.2 Email Service Provider

We use GoHighLevel to send and manage email communications. GoHighLevel may collect information about email opens, clicks, and engagement to help us improve our communications.

8. TEXT MESSAGING / SMS POLICY

8.1 SMS Consent

We may send text messages (SMS) to the phone number you provide, but only if you have given explicit consentthrough our website forms, by texting a keyword to our number, or by opting in during the checkout process.

By providing your phone number and opting in, you consent to receive text messages from ABC Sales Training LLC / Closer Over College.

8.2 Types of Text Messages

Depending on the consent you provide, messages may include:

Appointment reminders

Order and shipping notifications

Marketing and promotional messages

Service notifications (course updates, community announcements, program information)

8.3 Message Frequency and Costs

Message frequency varies based on your activity and the programs you're enrolled in. For marketing messages, you can expect approximately 2-4 messages per month, though frequency may vary.

Message and data rates may apply. Standard text messaging rates from your mobile carrier will apply. Please contact your mobile carrier for details about your specific plan.

8.4 Opt-Out Instructions

You may opt out of receiving text messages at any time. To stop receiving text messages:

Reply STOP to any text message from us

Text STOP to 501-690-5458

Contact us at [email protected]

After you opt out, you will receive one final confirmation message, and then no further messages will be sent unless you opt in again.

To get help or more information, reply HELP to any text message or text HELP to 501-690-5458.

8.5 SMS Opt-In Data Privacy — Critical A2P Disclosure

We do NOT share your mobile phone number or SMS opt-in consent with third parties for marketing purposes.

Your opt-in data for text messaging is treated with the highest level of privacy protection:

No third-party sharing: Opt-in data and consent for text messaging will NOT be shared with any third parties.

No affiliate sharing: No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

Exclusive use: All categories of information sharing exclude text messaging originator opt-in data and consent. This information will NOT be shared with any third parties under any circumstances.

Our use only: Your phone number and SMS consent are used exclusively by ABC Sales Training LLC and our authorized SMS service provider (GoHighLevel) to deliver the messages you've consented to receive.

This policy applies specifically to SMS opt-in data and consent, which receives stricter privacy protections than other types of contact information.

8.6 Supported Carriers

Our SMS service is supported by most major US and Canadian mobile carriers. If you experience issues receiving messages, please contact your carrier or reach out to us at [email protected].

9. PHONE COMMUNICATIONS

We may contact you by phone for the following purposes:

Sales calls and follow-up conversations

Customer support and technical assistance

Appointment confirmations or reminders

Important account or service notifications

If you do not wish to receive phone calls from us, please notify us at [email protected], and we will add your number to our internal do-not-call list.

10. CHAT WIDGET

We use a chat widget on our websites to provide real-time customer support. When you use the chat widget:

Your messages and contact information (name, email) may be collected

Chat transcripts may be stored for quality assurance and training purposes

The chat service is provided by GoHighLevel

By using our chat widget, you consent to the collection and use of your chat data as described in this Privacy Policy.

11. DATA SECURITY

We take the security of your personal information seriously and use reasonable administrative, technical, and physical safeguards to protect it from unauthorized access, disclosure, alteration, or destruction.

Our security measures include:

Secure Socket Layer (SSL) encryption for data transmitted over the internet

Secure servers and databases with restricted access

Regular security audits and updates

Employee training on data protection and privacy practices

However, please understand that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

You are responsible for:

Maintaining the confidentiality of your account login credentials

Notifying us immediately if you suspect unauthorized access to your account

Using strong passwords and updating them regularly

If you have any questions about the security of your personal information, please contact us at [email protected].

12. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary depending on the type of information:

Account Information: Retained for as long as your account is active, plus a reasonable period afterward for legal and business purposes

Purchase and Payment Information: Retained for at least 7 years for tax, accounting, and legal compliance purposes

Marketing Information: Retained until you opt out or request deletion

Website Activity Data: Typically retained for 12-24 months for analytics purposes

When we no longer need your information, we will securely delete or anonymize it.

13. YOUR RIGHTS AND CHOICES

You have certain rights regarding your personal information. Depending on your location, these rights may include:

13.1 Access and Portability

You have the right to request access to the personal information we hold about you. You may also request a copy of your data in a portable format.

13.2 Correction

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

13.3 Deletion

You have the right to request that we delete your personal information, subject to certain legal exceptions (such as information we must retain for tax, legal, or business purposes).

13.4 Opt-Out of Marketing

You have the right to opt out of receiving marketing communications from us at any time:

Email: Click "unsubscribe" in any marketing email or contact [email protected]

SMS: Reply STOP to any text message or text STOP to 501-690-5458

Phone Calls: Request to be added to our do-not-call list by emailing [email protected]

13.5 Opt-Out of Targeted Advertising

You can opt out of targeted advertising by:

Facebook/Meta: Visit your Facebook Ad Preferences settings

TikTok: Visit your TikTok Privacy Settings

Google: Visit Google Ad Settings at adssettings.google.com

Browser Settings: Most browsers allow you to block third-party cookies

13.6 Do Not Track Signals

Some web browsers have a "Do Not Track" feature that signals to websites that you do not want your online activities tracked. Our websites do not currently respond to Do Not Track signals. However, you can manage cookies and tracking through your browser settings as described in Section 5.

13.7 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: [email protected]

Phone: 501-690-5458

Mail: ABC Sales Training LLC, [YOUR BUSINESS ADDRESS], [City, State ZIP]

We will respond to your request within 30 days. We may need to verify your identity before processing your request.

14. GDPR RIGHTS (FOR EUROPEAN UNION VISITORS)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR).

14.1 Legal Basis for Processing

We process your personal data based on the following legal grounds:

Consent: You have given explicit consent for specific processing activities (such as marketing emails or SMS messages)

Contract Performance: Processing is necessary to fulfill our contractual obligations to you (such as delivering products or services you purchased)

Legitimate Interests: Processing is necessary for our legitimate business interests (such as improving our services, preventing fraud, or direct marketing), provided these interests do not override your rights

Legal Obligation: Processing is required to comply with applicable laws

14.2 Your GDPR Rights

In addition to the rights listed in Section 13, you have the right to:

Withdraw Consent: You can withdraw your consent to data processing at any time (this does not affect the lawfulness of processing before withdrawal)

Object to Processing: You can object to processing based on legitimate interests or for direct marketing purposes

Restrict Processing: You can request that we limit how we use your data in certain circumstances

Data Portability: You can request your data in a structured, commonly used, machine-readable format

Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority if you believe we have violated your rights

14.3 International Data Transfers

We are based in the United States. If you are accessing our services from the EEA, please be aware that your information will be transferred to, stored, and processed in the United States, which may not have the same data protection laws as your country.

By using our services, you consent to the transfer of your information to the United States and other countries where we or our service providers operate.

We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

14.4 EU Representative

If required by GDPR, we will appoint an EU representative. Contact information will be provided here when applicable.

15. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA).

15.1 Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information:

Identifiers: Name, email address, phone number, postal address, IP address

Commercial Information: Purchase history, transaction records

Internet Activity: Browsing history, search history, interactions with our websites and advertisements

Geolocation Data: Approximate location based on IP address

Professional Information: Company name, job title (if provided)

15.2 Categories of Sources

We collect this information from:

Directly from you (forms, purchases, account creation)

Automatically through cookies and tracking technologies

Third-party services (payment processors, advertising platforms, analytics providers)

15.3 Business Purposes for Collection

We use this information for the purposes described in Section 4 of this Privacy Policy, including:

Providing and improving our services

Marketing and advertising

Analytics and research

Legal compliance and security

15.4 Categories of Third Parties We Share With

We share personal information with:

Service providers (payment processors, CRM platforms, hosting providers)

Advertising platforms (Facebook/Meta, TikTok, Google)

Analytics providers (Google Analytics)

Marketing partners (for lookalike audiences and targeted advertising)

15.5 Your CCPA Rights

California residents have the right to:

Know: Request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months

Delete: Request deletion of your personal information (subject to certain exceptions)

Opt-Out of Sale: Request that we do not "sell" your personal information (we do not sell personal information in the traditional sense, but sharing data with advertising platforms may be considered a "sale" under CCPA)

Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights

15.6 How to Exercise Your CCPA Rights

To exercise your rights under CCPA, contact us at:

Email: [email protected]

Phone: 501-690-5458

We will verify your identity and respond to your request within 45 days.

15.7 "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request certain information about our disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes without your consent.

16. CHILDREN'S PRIVACY

Our websites and services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13.

If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as soon as possible.

Note about users ages 13-17: While our primary audience is ages 17-28, we recognize that some visitors may be between 13-17 years old. If you are under 18, please obtain parental or guardian consent before providing any personal information or making a purchase.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at [email protected].

17. THIRD-PARTY WEBSITES

Our websites may contain links to third-party websites, products, or services that are not owned or controlled by us (such as social media platforms, payment processors, or partner websites).

We are not responsible for the privacy practices or content of third-party websites. When you leave our websites, we encourage you to read the privacy policies of every website you visit.

This Privacy Policy applies only to information collected by ABC Sales Training LLC through our websites and services.

18. GOOGLE ANALYTICS

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to collect and analyze information about how visitors use our websites.

Google Analytics uses cookies to track your interactions with our websites and generate reports on website activity and usage. The information collected by Google Analytics (including your IP address) is transmitted to and stored by Google on servers in the United States.

Google may use this information to:

Evaluate your use of our websites

Compile reports on website activity for us

Provide other services related to website activity and internet usage

To opt out of Google Analytics tracking:

Install the Google Analytics Opt-Out Browser Add-On: https://tools.google.com/dlpage/gaoptout

For more information on how Google uses data, visit: https://policies.google.com/privacy

19. FACEBOOK/META AND TIKTOK REMARKETING

We use the Facebook Pixel and TikTok Pixel to deliver targeted advertisements and measure ad performance.

These pixels collect information about your activity on our websites (such as pages visited, products viewed, and purchases made) and use this information to:

Show you relevant ads on Facebook, Instagram, and TikTok

Measure the effectiveness of our advertising campaigns

Build custom audiences and lookalike audiences for advertising purposes

To opt out of Facebook/Meta personalized advertising:

Visit your Facebook Ad Preferences: https://www.facebook.com/ads/preferences

To opt out of TikTok personalized advertising:

Visit TikTok Privacy Settings in your account

For more information:

Facebook Privacy Policy: https://www.facebook.com/privacy/explanation

TikTok Privacy Policy: https://www.tiktok.com/legal/privacy-policy

20. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or for other reasons.

When we make changes:

We will update the "Last Updated" date at the top of this Privacy Policy

If the changes are significant, we will provide additional notice (such as by email or a prominent notice on our website)

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

Your continued use of our websites or services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

21. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

ABC Sales Training LLC

[YOUR BUSINESS ADDRESS]

[City, State ZIP]

Email: [email protected]

Phone: 501-690-5458

We will respond to your inquiry as soon as possible, typically within 5-7 business days.

© 2026 ABC Sales Training LLC. All rights reserved.