PRIVACY POLICY
The Wolverine Group, Inc.
Effective Date: July 18, 2026
Last Updated: July 18, 2026
1. Introduction
The Wolverine Group, Inc. (“TWG,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you access our website, purchase or enroll in our online courses (including “Commercial GenAI for Public Sector Procurement” and related offerings), subscribe to our communications, or otherwise interact with us.
This Policy applies to individuals who purchase courses as consumers and to government employees who purchase courses using a government purchase card (“P-card”), purchase order, or other government payment method.
By using our services, you acknowledge the practices described in this Policy. If you do not agree, please do not use our services.
2. Who We Are and How to Contact Us
Entity: The Wolverine Group, Inc.
Email for privacy requests: support@thewolverinegroup.com
General contact: info@wolverine-group.com
3. Information We Collect
We collect the following categories of personal information:
3.1 Information You Provide Directly
• Account and enrollment information: name, email address, employer or agency name, job title, professional role, and account credentials.
• Payment information: billing name, billing address, government purchase card (P-card) last four digits, purchase order number if applicable, and transaction identifiers. Full payment card numbers are processed by our payment processor and are not stored by TWG.
• Communications: messages you send through our contact forms, support requests, email replies, and any content you submit in course discussion areas.
• Marketing preferences: your opt-in to our newsletter or other communications, and your preferences regarding the frequency and type of communications.
• Course content you submit: responses to exercises, assessments, capstone project materials, and other content you submit for review or grading.
3.2 Information Collected Automatically
• Usage data: pages visited, lessons accessed, video completion, quiz results, time spent, and interaction patterns within the course platform.
• Device and technical data: IP address, browser type, operating system, device identifiers, referring URL, and approximate location derived from IP address.
• Cookies and similar technologies: see Section 8 below.
3.3 Information from Third Parties
• Our learning management system provider (Teachable) provides us with enrollment, progress, and transaction data.
• Payment processors provide us with transaction confirmations and limited card metadata.
• If you access our services through a single sign-on provider or social login, we receive the profile information that the service shares with us.
3.4 Information We Do Not Intentionally Collect
We do not seek to collect sensitive personal information (such as government-issued identification numbers, health information, or biometric data) and ask that you do not submit such information through our services. We do not knowingly collect information from individuals under 18 years of age; our services are intended for procurement professionals.
4. How We Use Your Information
We use personal information for the following purposes:
• Provide the courses, process your enrollment, grant access to course materials, and issue certificates of completion.
• Process payments, including government P-card transactions and purchase orders, and issue receipts and invoices.
• Communicate with you about your account, course updates, customer support requests, and material changes to our services or legal terms.
• Send marketing communications (including our newsletter) where you have opted in, and allow you to opt out at any time.
• Operate, secure, and improve our website and course platform, including diagnosing technical problems and preventing fraud.
• Comply with legal obligations, including tax, accounting, and records retention requirements, and respond to lawful requests from government authorities.
• Defend against claims, enforce our Terms of Service, and protect the rights, property, and safety of TWG, our users, and others.
5. How We Share Your Information
We share personal information only as described below. We do not sell or share personal information for cross-context behavioral advertising.
5.1 Service Providers
We share information with vendors that perform services on our behalf under contracts that restrict their use of the information. Current categories include:
• Learning management system: Teachable (course hosting, enrollment, progress tracking).
• Payment processing: Stripe (payment card processing and transaction records).
• Email communications: Mailchimp (newsletter delivery, transactional email).
• Website hosting and analytics: HostGator
5.2 Government Purchase Card Transactions
When you purchase a course using a government P-card or purchase order, your transaction information is processed by our payment processor and may appear on government financial records. Your individual name, email, and agency affiliation may be reflected in receipts, invoices, and course completion records. Government agencies may be required to disclose such records under applicable public records laws.
5.3 Legal and Safety Disclosures
• To comply with applicable law, regulation, legal process, or enforceable government request.
• To enforce our Terms of Service or investigate potential violations.
• To protect the rights, property, or safety of TWG, our users, or others.
• In connection with a merger, acquisition, sale of assets, reorganization, or other business transaction, where personal information may be among the assets transferred. The successor entity will be bound by the terms of this Policy with respect to previously collected information, unless you are notified of changes and given an opportunity to opt out as required by applicable law.
5.4 With Your Consent
We may share personal information for purposes not listed above with your consent.
6. Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy, including to provide the courses, comply with legal and tax obligations, resolve disputes, and enforce our agreements. General retention periods:
• Account and course records: duration of the student relationship plus seven years after the last course activity, to support certificate verification and address future student inquiries.
• Payment and transaction records: seven years, to meet tax and accounting requirements.
• Marketing communications: until you unsubscribe, and a suppression record is retained thereafter to honor your opt-out.
• Website analytics: generally up to 26 months, or as configured with our analytics provider.
When personal information is no longer needed, we delete, anonymize, or securely archive it.
7. How We Protect Information
We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit, and vendor due diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We are not liable for unauthorized access that occurs despite our implementation of commercially reasonable security measures. You are responsible for protecting your account credentials and for notifying us of any suspected unauthorized access.
8. Cookies and Tracking Technologies
Our website and course platform may use cookies and similar technologies. Categories include:
Strictly necessary cookies. Required for the website and course platform to function, including login, cart, and security.
Functional cookies. Remember your preferences, such as language and display settings.
Analytics cookies. Help us understand how visitors use our site so we can improve it. These do not identify individual users beyond the device level.
You can control cookies through your browser settings. Blocking strictly necessary cookies may prevent parts of the website or course platform from working correctly.
Note: If you add Google Ads, Meta Pixel, LinkedIn Insight Tag, or similar advertising pixels in the future, this section must be updated and a cookie consent banner added. You indicated those are not in use today.
9. Your Privacy Rights
9.1 Rights Available to All Users
• Access: request a copy of the personal information we hold about you.
• Correction: request that we correct inaccurate information.
• Deletion: request that we delete your personal information, subject to legal retention requirements.
• Opt out of marketing: unsubscribe at any time using the link in any marketing email or by contacting us.
9.2 Additional Rights for California Residents (CCPA / CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
• Right to know the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties with whom it is shared.
• Right to delete personal information, subject to exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of personal information. TWG does not sell or share personal information for cross-context behavioral advertising.
• Right to limit the use and disclosure of sensitive personal information. We do not use sensitive personal information for purposes beyond those permitted without the right to limit.
• Right to non-discrimination for exercising your privacy rights.
To exercise these rights, email us at support@wolverine-group.com. We will verify your request by asking you to confirm information we already hold about you, such as your enrollment email and a recent transaction. You may designate an authorized agent to submit a request on your behalf by providing written authorization. We will respond within 45 days, with a possible extension as permitted by law.
9.3 Notice of Financial Incentive
We do not offer financial incentives in exchange for personal information.
10. Children's Privacy
Our services are directed to procurement professionals and are not intended for individuals under 18. We do not knowingly collect personal information from individuals under 18. If you believe a minor has provided personal information to us, please contact us and we will delete the information.
11. Do Not Track
Some browsers transmit a “Do Not Track” signal. There is no industry consensus on how to respond to these signals, and we currently do not respond to Do Not Track signals. We will update this Policy if that changes.
12. Third-Party Websites and Services
Our website and course materials may link to third-party websites, including government websites (such as acquisition.gov), third-party tool providers (such as ChatGPT, Claude, Gemini, and Copilot), and other resources. We are not responsible for the privacy practices of those third parties. Review their privacy policies before providing personal information.
13. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will post the updated Policy with a new “Last Updated” date and, where appropriate, notify you by email or through the course platform. Continued use of our services after an update constitutes acknowledgment of the updated Policy.
14. How to Contact Us
Questions, requests, or complaints regarding this Policy or our data practices can be directed to:
Email: support@wolverine-group.com
If you are not satisfied with our response, you may also contact your state attorney general or data protection authority.