Working draft — not yet in force. This document is under legal review and the highlighted items below are still being confirmed. It does not currently govern use of the Services.

Privacy Policy — Marketing Leaders Fellowship Program

Internal working draft — August 25, 2026. Yellow-highlighted [CONFIRM] items need final answers from legal, the client, or the developer before publishing. U.S. users only.

Effective date: CONFIRM: insert publish date

This Privacy Policy describes how the Marketing Leaders Fellowship Program ("MLFP," "we," "us," or "our") collects, uses, discloses, and protects personal information through https://themlfp.com, the MLFP application, the student portal, educational modules, assessments, live sessions, and related services (together, the "Services"). MLFP is operated by CONFIRM: legal operating entity and mailing address — the site footer currently names no legal entity. The Services are intended for users located in the United States.

1. Personal Information We Collect

What we collect depends on how you interact with the Services.

Contact and identification information.

Full name, email address, and telephone number if provided. CONFIRM: what the optional phone number is used for — if SMS will ever be sent, present separate SMS consent at the point of collection rather than relying on this Policy
Account or user identifiers for the student portal.
Parent or legal guardian contact information and consent records for participants under 18. CONFIRM: parental-consent workflow and whether guardian information will be stored — see Section 6

Application and educational information.

Education level, graduation year, school, activities and honors, portfolio and other links you choose to provide, and application essays and responses. Please avoid including highly sensitive information in essays or other free-text fields unless it is specifically requested.
The application supports save-and-return, so information you enter may be stored before you submit. Incomplete applications are retained for CONFIRM: retention period for abandoned applications and then deleted.

Account and authentication information.

Information used to authenticate and secure your account — which may include passwords stored in hashed form, login tokens, one-time codes, account status, and login history, depending on the authentication system used. CONFIRM with developer: authentication provider/method

Program participation information.

Module and video viewing progress; quiz, test, and assessment responses and scores; assignment completion; team assignments and collaboration activity; campaign concepts, written work, presentations, and other submissions; instructor and coordinator feedback; attendance and participation records; and completion status, certificates, awards, and recognition.

Communications.

Messages you send us, including to admin@themlfp.com, support requests, questions, and feedback. CONFIRM with developer: whether portal chat, Q&A, discussion boards, or team messaging exist and are stored

Live session information.

Live sessions and presentations are conducted over Zoom. Depending on configuration, Zoom or MLFP may process your display name, email address, attendance, chat messages, Q&A submissions, audio, and video. CONFIRM with client/developer: whether sessions are recorded and whether chat, Q&A, or transcripts are retained — if yes, recordings and transcripts must be expressly added here and noticed to participants

Device, usage, and technical information.

IP address, browser and device type, operating system, pages and modules accessed, dates and times of access, referring pages, interactions with the Services, approximate location derived from IP address, error, diagnostic, and security information, and cookie or consent preferences.

2. How We Use Personal Information

We use personal information to: receive, review, and administer applications; communicate with applicants and participants; create and manage student accounts; provide modules and program content; track completion; administer quizzes, tests, and assessments; organize teams; facilitate live sessions, mentorship, presentations, and judging; evaluate work and provide feedback; issue certificates, awards, and recognition; provide technical and participant support; authenticate users and protect accounts; detect, investigate, and prevent security incidents, fraud, misuse, or violations of program rules; maintain and improve the Services; analyze use of the Services where permitted by your cookie preferences; comply with legal, regulatory, and recordkeeping requirements; and establish, exercise, or defend legal rights.

We do not use participant information to train AI or machine-learning models. CONFIRM with client that no such use occurs — if it ever will, it must be separately disclosed

3. How We Disclose Personal Information

Service providers.

Vendors that perform services on our behalf: website and cloud hosting, database and file storage, account authentication and security, transactional email, video hosting or streaming, live conferencing (Zoom), analytics where enabled, cookie and consent management, and security, logging, and error monitoring. These providers may process personal information only as permitted by their agreements with us and applicable law. CONFIRM with developer: the actual production provider inventory before publication — see the companion open-items document for the current confirmed/unconfirmed list

Instructors, program administrators, and participating challenge clients.

Application materials and program work may be shared with MLFP personnel, instructors, coordinators, judges, and participating challenge clients where reasonably necessary to administer the program, evaluate submissions, provide feedback, or judge a challenge. CONFIRM with client/legal: precisely what applicant and student information the challenge client receives, and in what form

Legal, safety, and corporate.

We may disclose information to comply with law, regulation, subpoena, court order, or lawful governmental request; to investigate or prevent fraud, security threats, or misuse; to protect the rights, property, or safety of participants, MLFP, or others; to establish, exercise, or defend legal claims; or in connection with a merger, acquisition, financing, reorganization, or similar transaction.

4. No Sale, Sharing, or Targeted Advertising

MLFP does not sell personal information for monetary consideration, does not sell or share personal information for cross-context behavioral advertising, and does not use personal information for targeted advertising. If these practices ever change, we will update this Privacy Policy and provide any notices or opt-out mechanisms required by law. CONFIRM with developer/client once the production tag and pixel inventory is verified — this section must be re-checked if any advertising technology is present

5. Cookies and Similar Technologies

The Services use strictly necessary cookies and similar technologies for authentication, security, session management, remembering preferences (including cookie choices and saved application progress), and core functionality. These are active by default. With your permission, we may also use optional analytics technologies to understand how the Services are used and improve them. Optional cookies stay off unless you affirmatively enable them, and you can change your choices at any time through the Cookie Settings link on the Services. We honor supported browser privacy signals such as Global Privacy Control (GPC). CONFIRM with developer: implement a consent manager that blocks optional technologies before opt-in, and GPC handling, before any analytics or marketing scripts are enabled

6. Students Under 18

CONFIRM with legal: this entire section — including the minimum age — before publication MLFP is intended for high school and college participants. The Services are not intended for children under 13, and we do not knowingly collect personal information from children under 13; if we learn we have done so without appropriate authorization, we will take reasonable steps to delete it.

If you are under 18, a parent or legal guardian must review and agree to the applicable program terms on your behalf and provide consent where required. We may request additional information or consent from a parent or guardian when reasonably necessary to confirm eligibility or comply with law. Parents and guardians of participants under 18 may contact us at any time to review, correct, or request deletion of their student's personal information, or to withdraw consent to further collection or use. CONFIRM with legal/developer: the actual consent workflow in the application flow — this must be built, not just stated

7. Information Provided by Schools or Other Organizations

If a school, university, nonprofit, employer, or other organization refers or sponsors participants or provides information about them directly to MLFP, we may receive information from that organization, and any such arrangement may be governed by separate agreements or privacy requirements. CONFIRM with client: whether nominations or sponsorships occur — if so, legal should separately review education-record implications

8. Your Privacy Rights

Depending on your state of residence and applicable U.S. privacy laws, you may have the right to:

Request access to the personal information we maintain about you.
Obtain a copy of certain personal information in a portable and, where technically feasible, readily usable format.
Request correction of inaccurate personal information.
Request deletion of personal information, subject to legal exceptions.
Opt out of the sale or sharing of personal information, targeted advertising, or certain profiling, where applicable (as stated above, we do not engage in these practices).
Withdraw consent where processing is based on consent.
Appeal a decision on a privacy-rights request, where required by law.

We will not discriminate against you for exercising your privacy rights. We may take reasonable steps to verify your identity before fulfilling a request, and where permitted by law an authorized agent may submit a request on your behalf, subject to verification. To exercise any of these rights, contact us using the details in Section 13.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including administering applications and participation, maintaining appropriate business and security records, complying with legal obligations, and resolving disputes. When information is no longer reasonably necessary, we delete, de-identify, or otherwise dispose of it. CONFIRM with client/legal: whether to publish specific retention periods for rejected applications, program records and assessments, inactive accounts, security logs, and consent records — recommended

10. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. No internet service can be guaranteed completely secure. You are responsible for keeping your account credentials confidential and should contact us promptly if you believe your account has been compromised.

11. Third-Party Websites and Services

Portions of the Services depend on third-party platforms — for example, Zoom for live sessions — and the public website links to external websites and social platforms. When you interact with a third party, it processes information under its own privacy policy and terms, which we recommend reviewing.

12. United States Use

The Services are intended for individuals located in the United States. CONFIRM with developer/client: whether access will actually be geo-restricted or whether this remains an intended-use limitation only

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version with a revised effective date, and where changes materially affect how we collect, use, or disclose personal information, we will provide additional notice where appropriate or required by law.

14. Contact Us

Marketing Leaders Fellowship Program

8575 Higuera St, Culver City, CA 90232

Email: admin@themlfp.com CONFIRM: recommend standing up privacy@themlfp.com as a dedicated privacy contact

Website: https://themlfp.com

Questions about this document? Email admin@themlfp.com.