Privacy Policy

Privacy Policy

Effective Date: June 11, 2025

1. Introduction Bratton & Co. dba Hyperdrive Agile Leadership (hereafter, “Hyperdrive,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains what information Bratton & Co., Inc. dba Hyperdrive Agile Leadership (hereafter “Hyperdrive”) and AgileCamp collects from or about users of the Hyperdrive website, including any content Bratton & Co. may provide through the websites (collectively, the “Hyperdrive website”) and Bratton services, including but not limited to other interactions (e.g., customer service inquiries, conferences, etc.), and states our practices regarding such information.

By accessing files, Browse, or otherwise using the Hyperdrive website or Service Offerings, you acknowledge that you have read and understood this Privacy Policy. If you are outside the European Economic Area (EEA), by accessing files, Browse, or otherwise using the Hyperdrive website, you have agreed to the use of your data as described in this Privacy Policy. If you are in the EEA, by accessing the Hyperdrive website, you have agreed to the use of my data as described in this Privacy Policy. If you do not agree with the terms, please do not access or use the Hyperdrive website, Service Offerings, or any other aspect of Bratton’s business.

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

Bratton & Co. dba Hyperdrive Agile Leadership 1547 Palos Verdes Mall #198 Walnut Creek, CA 94597 Email: info@hyperdriveagile.com

3. Scope of this Privacy Policy This Privacy Policy applies to personal information and other information Hyperdrive or its service providers collect from or about the users of the Hyperdrive website, Service Offerings, and other interactions (e.g., customer service inquiries, conferences, etc.). Unless otherwise specified below, this Privacy Policy does not apply to any other products or services or to information collected in any other way (whether online or offline) or for any other purpose.

4. Personal Information of Our Customers’ Clients and Employees (Our Role as a Data Processor) Hyperdrive collects information under the direction of our customers, and has no direct relationship with the individuals whose personal data it processes on behalf of such customers. When we provide services to our customers, in some instances we process personal information about their clients or employees (“Client Information”) on their behalf. In these situations, it is our customers rather than we who decide the reasons for which the Client Information will be processed.

If you are a client or employee of one of our customers and would no longer like to be contacted by one of our customers that use our service or for details of how the Client Information will be used and protected, and details of how to access or correct the information, please refer to the privacy statement of the Hyperdrive customer to which you submitted your personal information. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Hyperdrive acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete data should directly query Hyperdrive’s customer service. If requested to remove data, we will respond within the applicable legal timeframe. We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customers at their instruction. Hyperdrive may also retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

5. Personal Information We Collect For purposes of this Privacy Policy, “personal information” means information that can be used to personally identify you, such as your name, address, telephone number, e-mail address, online identifiers, device information, billing and transaction information, credit card or other financial information, contact preferences, and similar information. We do not collect or process any “sensitive personal information” as defined under applicable privacy laws (e.g., health data, racial or ethnic origin, religious beliefs, precise geolocation).

We or our service providers may collect, store, and process personal information and other information from or about you when you:

• Use Hyperdrive website or Service Offerings to order products or services;

• Register for our conferences;

• Register for our training;

• Request information;

• Subscribe to marketing or support materials;

• Enter a contest;

• Respond to promotional campaigns; and

• Register to a secure extranet site to obtain access to Service Offerings and any associated information, support, and training.

Specifically, this includes:

• Information You Provide Directly to Us:

  • Contact Information: Name, email address, phone numbers.

  • Professional Information: Company name, job role.

  • Location Data: Your general location, which you may provide directly (e.g., billing address).

  • Payment Information: Billing and transaction information, including credit card or other financial information, when you order products or services. This data is processed securely by our third-party payment processor, Stripe. We do not store full payment card details on our servers.

  • Communications & Inquiries: Information you provide when you request information, subscribe to materials, enter a contest, respond to promotional campaigns, or communicate with us for customer service inquiries, feedback, or surveys.

• Information Collected Automatically (Through Cookies and Other Technologies):

  • Usage Data: Your Internet Protocol (IP) address, Internet domain name, the web browser and operating system used to access Hyperdrive website, Service Offerings, our mobile applications or other interactions (e.g., customer service inquiries, conferences, etc.), the files visited, the time spent in each file, and the time and date of each visit or clickstream data.

  • Device Information: Information about the device you use to access our services (e.g., device type, unique device identifiers).

  • Analytics Data: We use tools like PostHog to collect and analyze information about your interaction with our services to understand user behavior, improve our offerings, and personalize your experience. This may include user ID (if assigned by PostHog), session duration, and feature usage.

  • Inferred Information: We may generate inferences about your preferences and characteristics based on the information collected.

6. How We Use Your Information (Purposes and Legal Bases for Processing) Hyperdrive or our service providers may use the personal information and other information we collect from you in various ways, based on the following legal grounds:

• Performance of a Contract with You:

  • To provide service and support to you, including fulfilling your requests and purchases (e.g., processing payments via Stripe).

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Hyperdrive.

  • To send you service-related communications (e.g., order confirmations, security alerts, updates, certification-related communications for Scrum Alliance, ICAgile, and Scaled Agile programs).

  • For billing you for Service Offerings.

• Our Legitimate Interests:

  • To verify your identity.

  • To communicate information about the Hyperdrive website, Service Offerings and other interactions (e.g., customer service inquiries, conferences, etc.).

  • To contact you to complete surveys that we use for marketing or quality assurance purposes.

  • For analytics: To understand how users interact with our services and identify trends (using tools like PostHog) to improve and optimize our website, products, and services, and to develop new features and functionalities.

  • For security and fraud prevention: To detect, prevent, and respond to security incidents, fraud, and other malicious or illegal activities.

  • To protect the rights, interests, safety, or property of its business, employees, suppliers, customers, or others.

  • To combine information we or our service providers have collected from or about you through the Hyperdrive website, Hyperdrive Service Offerings and other interactions (e.g., customer service inquiries, conferences, etc.), including about your use thereof, may be combined with or enhanced by other information from or about you that we have obtained from other online or offline sources, including from our service providers or business partners.

• Your Consent:

  • To send you promotional information, newsletters, and special offers via email or push notifications, where required by law. If you no longer wish to receive these types of communications, you may turn them off at the device level by opting out or unsubscribing by following the specific instructions in the email or other communication you receive. It may take a reasonable period of time to process your request, but no longer than 10 business days for email promotions. In countries where Hyperdrive is required to do so by law, Hyperdrive will offer you the opportunity to provide opt-in consent before promotional materials are sent, or promotional calls are made, to you.

  • For certain uses of cookies and tracking technologies beyond what is strictly necessary (as detailed in Section 7).

  • For any other purpose with your consent.

  • For the specific transfer of your name, address, and email to Scrum Alliance, Inc. in the United States for certification and attendance monitoring purposes, as acknowledged during course registration. You understand that Scrum Alliance, Inc. is based in the United States and the European Commission has not determined that the United States ensures an adequate level of protection for personal data. You understand that your consent for this specific transfer can be withdrawn at any time, but realize that Scrum Alliance, Inc. must have this personal data to maintain certification.

• Compliance with a Legal Obligation:

  • To comply with applicable laws, regulations, legal processes, governmental requests, or court orders (e.g., tax, audit, subpoenas).

  • To produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings.

  • To combat fraud, crime and as otherwise required or permitted by law.

7. Cookies and Tracking Technologies Hyperdrive and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Hyperdrive may collect and/or log your Internet Protocol address, Internet domain name, the web browser and operating system used to access Hyperdrive website, Service Offerings, our mobile applications or other interactions (e.g., customer service inquiries, conferences, etc.), the files visited, the time spent in each file, and the time and date of each visit or clickstream data. Hyperdrive may collect this information automatically as you browse via the use of log files and web beacons to analyze trends in the aggregate and administer the Hyperdrive website and Service Offerings.

• What are Cookies? Cookies are small data files placed on your device or computer.

• How We Use Them: We use cookies for:

  • Strictly Necessary Cookies: Necessary cookies are essential for the website to function and cannot be disabled. These are used for website preferences, logging in, or making purchases.

  • Analytics/Performance Cookies: Analytics cookies help us understand how visitors engage with our website.

  • Advertising Cookies: Advertising cookies are used to track visitors across websites to allow publishers to display relevant and engaging advertisements.

Your Choices Regarding Cookies and Consent: We use a cookie consent banner to manage your preferences. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. Our cookie banner provides you with options to accept or decline certain cookie categories (excluding strictly necessary cookies). You can adjust your cookie preferences at any time by accessing our cookie banner by clicking “Manage Cookie Settings” under the “Resources” menu. If you wish to opt out of interest-based advertising, please contact us at info@hyperdriveagile.com or follow the opt-out instructions in the email.

8. How We Share and Disclose Your Information Hyperdrive may share non-personal information (e.g., anonymous, aggregated data) without restriction. Hyperdrive may share your personal information as described in this Privacy Policy and with its service providers and suppliers to the extent necessary to deliver the Hyperdrive website or Service Offerings you requested, respond to your requests for information on Service Offerings, or otherwise support your business needs. If you opt out of sharing your information with these third-party service providers for these purposes, we may be unable to provide the Hyperdrive website, Service Offerings, mobile applications, information or support you requested. Third-party service providers and suppliers receiving personal information are authorized to use your personal information only for the purpose it was originally intended or as required or permitted by law. However, unless otherwise dictated by law or agreement, Hyperdrive is not responsible for any improper use by such parties.

We may also disclose your personal information and other information, including across country borders:

• Service Providers and Suppliers: We engage third-party service providers to perform functions on our behalf. These include payment processors (like Stripe), analytics providers (like PostHog), hosting providers, email service providers, and customer support platforms.

• Certifying Bodies: For students seeking certifications, we must share basic information like student name, email, and sometimes company name with certifying bodies for certification purposes. This includes:

  • Scrum Alliance, Inc.

  • ICAgile

  • Scaled Agile

• Our Subsidiaries, Affiliates, and Worldwide Offices.

• Business Transfers: In connection with any proposed or actual sale or other transfer of some or all assets of Hyperdrive, and/or any proposed or actual sale or merger of Hyperdrive or any division of Bratton & Co.

• Legal Obligations and Protection: To comply with the law or in response to a subpoena, court order, law enforcement or government request, or other legal process ; to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings ; if Hyperdrive determines in its good faith judgment that such disclosure is necessary to provide its services or to protect the rights, interests, safety, or property of its business, employees, suppliers, customers, or others.

• For Fraud or Other Criminal Activity: To combat fraud or other criminal activity.

• With Your Consent : For any other purpose disclosed by us when you provide the information.

We do not engage in the “selling” or “sharing” of your personal information as defined by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). This means we do not disclose your personal information for monetary or other valuable consideration to third parties, nor do we disclose it for cross-context behavioral advertising. Unless permitted by relevant laws, Hyperdrive and its parent company will not share, sell, trade, or lease your personal information to or with others except as provided for in this Privacy Policy.

9. International Data Transfers As an online business with a global customer base, your personal information may be transferred to, and processed in, countries other than the country in which you reside. Our primary servers are located in the United States.

For transfers of personal data from the European Economic Area (EEA), the UK, Switzerland, or other jurisdictions with data transfer restrictions to the United States and other non-adequate countries, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs): In certain cases Hyperdrive offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the European Union, and other international transfers of customer data. We incorporate the European Commission’s Standard Contractual Clauses into our data processing agreements with relevant service providers and partners where required.

• Consent: In specific circumstances, where appropriate and legally permitted, we may rely on your explicit consent for international data transfers (e.g., for the transfer of specific data to Scrum Alliance, Inc. as detailed in Section 6).

By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

10. Data Retention We will retain your personal information for as long as your account is active or as needed to provide you Hyperdrive Websites, Service Offerings and mobile applications. If you wish to cancel your account, or request that we no longer use your personal information to provide you Services, contact us via the applicable methods provided below. Unless you request removal, we will generally retain your data indefinitely, subject to legal, regulatory, ethical, or document retention obligations.

Even after we cancel your account or cease using your personal information to provide you Services, we may still retain, use, and disclose your information as necessary to comply with our legal, regulatory, ethical, or document retention obligations, and any request to delete your personal information is subject to these obligations and restrictions.

11. Your Data Protection Rights It also describes the choices regarding use, access and collection of personal information as well as your rights to your personal data that we process. Depending on your location and applicable data protection laws, you may have the following rights regarding your personal information:

• Right to Know/Access: Hyperdrive strives to keep your personal information accurate. We have implemented management processes and policies designed to maintain data integrity. We will provide you with reasonable access to your personal information in accordance with relevant laws, including by making reasonable efforts to provide you with online access and the opportunity to update your information. Upon request, Hyperdrive will provide you with information about whether we hold any of your personal information.

• Right to Rectification/Correction: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

• Right to Deletion/Erasure (“Right to be Forgotten”): You have the right to request the deletion of your personal information, subject to certain exceptions (e.g., where we need to retain it for legal obligations).

• Right to Object to Processing: You have the right to object to the processing of your personal information in certain circumstances, particularly for direct marketing purposes or when processing is based on legitimate interests.

• Right to Restrict Processing: You have the right to request that we limit the way we use your personal data in certain circumstances.

• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.

• Right to Withdraw Consent: Your decision to provide the personal information that we may request from time to time is voluntary. If we are relying on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not apply to service communications that are considered part of certain Service Offerings, which you may receive periodically unless you cancel the applicable Service Offerings. This will not affect the lawfulness of processing based on consent before its withdrawal.

• Right to Non-Discrimination (California residents): You have the right not to receive discriminatory treatment for exercising any of your privacy rights.

How to Exercise Your Rights: To request access, correction, or deletion or transfer of your personal information, follow the applicable instructions below. To protect your privacy and security, we will take steps to verify your identity before granting access or making changes to your personal information. While we will make reasonable efforts to accommodate your request, we also reserve the right to reject such requests or to impose certain restrictions and requirements on such requests, if required or permitted by applicable law. We will respond to your request within a reasonable time frame.

Please email us at info@hyperdriveagile.com to request access, correction, deletion or transfer of your personal information or withdrawal of consent to the processing described in this Privacy Policy.

Right to Lodge a Complaint: If you are a resident of the EEA and have an unresolved privacy or personal information collection, use, or disclosure concern that we have not addressed satisfactorily, please contact the EU Data Protection Authorities. For more information on how to contact the EU Data Protection Authorities, click here. If you are a resident of Switzerland and have this concern, please contact the Swiss Federal Data Protection and Information Commissioner. For more information on how to contact the Swiss Federal Data Protection and Information Commissioner, click here.

12. Children’s Privacy Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verifiable parental consent, we will take steps to delete that information. If you believe we may have collected personal information from a child under 18, please contact us immediately.

13. Security of Your Personal Information Hyperdrive has implemented administrative, technical, and physical measures designed to protect your personal information from accidental loss and from unauthorized access, disclosure, use, alteration, or destruction. These measures include computer safeguards and secured files and buildings, Internet firewalls, anti-virus protection, and, where appropriate and required by applicable law, Transport Layer Security (“TLS”) or similarly encrypted browsers.

However, no electronic data transmission or storage of information can be guaranteed to be 100% private and secure, and you understand that Hyperdrive does not ensure or warrant the privacy or security of any information we collect from or about you, and that you use the Hyperdrive website and provide us with information at your own risk. If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. Please also be careful to avoid “phishing” scams, where someone may send you an email that looks like it is from Hyperdrive asking for your personal information. Hyperdrive will never request your personal information through email. If you have any questions about the security of your personal information, you can contact us at set forth below.

14. Changes to This Privacy Policy Hyperdrive may update this Privacy Policy periodically, and will note the date of its most recent revision above. If we make material changes to this Privacy Policy, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how Hyperdrive and its parent company is collecting, using, retaining, protecting, disclosing, and transferring your information.