Privacy Policy

HCA WEBSITE PRIVACY POLICY

Effective Date: July 10, 2026

Heavy Construction Academy (“HCA,” “we,” “us” or “our”) recognizes the importance of protecting the privacy of our online visitors. The following privacy policy (“Privacy Policy”) is the way we handle information learned about you from your visits to our website available at https://www.operator-academy.com/ (the “Site”).

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you access or use the Site or submit information to or through the Site, you accept the terms of this Privacy Policy and our Terms of Use, confirm that you are not located outside the United States, and consent to our collection, use, disclosure, retention and other processing of your information as described in this Privacy Policy. We currently only accept business and Site visitors within the United States.

Personal Information
HCA collects personally identifiable information from you, which may include:
• First and last name
• Address
• Email address
• Phone number
• Age
• Date of birth
• Income (e.g., salary, support/assistance, disability/retirement, or other sources of income)
• Government-issued identification number, such as Social Security number
• Racial or ethnic origin
• Military status
• Disabilities
• Gender
• Household size
• Marital status
• Number of dependents
• Any additional information you may provide to us when you contact us, including via the Site’s “Contact Us” page or chat functionality.
• If you interact with us on our social media pages, such as by commenting on our posts, we will collect the content of that message. Please note that if you choose to post a

comment on any of our social media pages, any information you post will be visible to any other visitors to that social media page. We are not responsible for any personal information you include in such posts or for any use of such information by any other visitor to the social media page.

This information is collected and stored electronically when you contact us. We may also collect this information from publicly available information sources, our service providers, and our business partners.

Where permitted by applicable law, we may combine your personal information with other non-personally identifiable information we have collected from you. We may also combine your personal information with information we receive about you from other sources, such as publicly available information sources, our service providers, and our business partners.

Information Collected Automatically
In addition, information about your computer hardware and software is automatically collected by HCA when you use the Site. This information may include:
• IP address
• Browser type
• Type of operating system
• Access times and dates
• Device type
• Approximate geographic location
• Information about how you interact with the Site and advertisements, including the actions you take on the Site and the pages viewed.
• Other technical information such as protocol status and substatus, bytes sent and received.
This information is used by us for our business purposes, including for the operation and improvement of the Site, for technical troubleshooting, to maintain quality of the Site, to provide general statistics regarding use of the Site and to determine the effectiveness of our promotional campaigns.

We may also receive similar data from our business partners, including website analytics and digital advertising vendors, online advertising networks, and from social media platforms, subject to your registration and privacy settings with such third-party social media platforms. We may share your information with these third parties as well.

Cookies and Other Information Collection Tools Cookies
What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences, and other information.

Duration of Cookies. We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erases them. Persistent cookies have varying durations that are dependent on their expiration date.

Why do we use them? Cookies help us improve the Site by providing us with information about which parts of the Site are most popular, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. We may also use third-party cookies and other data collection tools (such as pixels/web beacons) to help improve your experience with the Site. For example, we use Google Analytics to help analyze how users use the Site. You can visit https://www.google.com/settings/ads to learn more about Google’s use of cookies. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics opt-out browser add-on designed for this purpose.

How do I control cookies? Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet, or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site.

Pixels / Web Beacons
A pixel or web beacons is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email.

We may utilize pixels/web beacons both on certain aspects of the Site and in HTML-formatted email messages to you. Pixels/web beacons may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and tracking the activities of users of the Site and email recipients. For instance, we may use pixels/web beacons from Google and Meta to collect or receive information from our HTML-formatted email messages to you, Site and elsewhere on the Internet to enable us to create targeted advertisements and measure the effectiveness of our ads. Please note that information collected via pixels/web beacons may be shared with our website analytics and digital advertising vendors.

Interest Based Advertising
We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies and pixels/web beacons that we may utilize on the Site and in our HTML-formatted email messages to you. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. You may also opt-out of interest-based advertising by managing your preferences by reviewing cookies located in the website footer. Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.

How Information is Used
We may use the information we collect for any of the following purposes:
• to provide the Site to you and to improve the Site.
• if you sign up for our email list, to send you our newsletters.
• to personalize our advertising and marketing communications and provide you with information about products and services that we and other businesses may provide that we think may be of interest to you.
• for quality assurance purposes, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site.
• for research and analysis purposes.
• to fulfil your requests.
• to respond to your inquiries and communicate with you.

• For our other business purposes, such as data analytics, audits, developing new services, improving our services, identifying Site usage trends, determining the effectiveness of our promotional campaigns, and determining the effectiveness of our promotional campaigns.
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities;
(iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations;
(vi) to protect our rights, privacy, safety or property, and/or that of you or others; and
(vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Sharing of Information
• With Our Affiliates. We may share your personal information with our corporate affiliates (e.g., subsidiaries or companies under common control) for our internal business purposes.
• With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site (e.g., the chat functionality), provide data analytics and research on the Site and send out emails about the Site and our services.
• With Our Business Partners. We share your information with other businesses with whom we have a relationship in connection with our financial counseling services, including those entities that referred you to us. We may share information with the entities that referred you to us to provide feedback regarding the status of your counseling. We may also share information so that our business partners can provide you with information about products and services that may be of interest to you.
• For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property, or protect the rights, property, or safety of others, or as needed to support external auditing, compliance, and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
• Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Links to External Websites and Online Services
Our Site may contain links to third-party websites and online services. Any access to and use of such third-party websites and online services is not governed by this Privacy Policy but is instead governed by the privacy policies of those third-party websites and online services, and we are not responsible for the information practices of such third-party websites and online services.

Social Media

Some aspects of the Site may allow you to interface with social media, such as Facebook, Instagram, X, LinkedIn, and YouTube. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Site through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

Security Used & Retention of Personal Information
HCA uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition, or misuse of personal information. We encrypt the personal information transmitted via our Site with Secure Sockets Layer (“SSL”) technology. SSL establishes a secure connection between the server and an SSL-capable browser, then encrypts and decrypts information as it is sent and received. By encrypting messages, SSL is intended to ensure that transactions are private and that information has not been altered during transmission. SSL can also authenticate the server to the browser by providing the server’s certificate to the browser. The browser must be capable of using the SSL protocol, including verifying certificates and encrypting and decrypting messages.

However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information, and you should avoid transmitting sensitive information when using public or unsecured Wi-Fi and be cautious when sharing personal information on social media.

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations.
Do Not Track
Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

Children
We do not knowingly collect or maintain personal information from any person under the age of 13. No parts of our Site are directed to or designed to attract anyone under the age of 13.

Your Rights and Choices
You may opt out of receiving promotional e-mails from us by following the unsubscribe instructions provided in any such messages. Please note that if you opt out of receiving

promotional messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails and SMS messages relating to follow up requests or changes to this Privacy Policy).

Nevada Residents
Under Nevada law, HCA does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us at [email protected].

California “Shine the Light” Law
Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about the personal information we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. To request a copy, please contact us at [email protected]. Please be aware that not all information sharing is covered by the “Shine the Light” law requirements and only information on covered sharing will be included in our response.

California: In accordance with California law, we will not share information we collect about you with companies outside of HCA, unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide products and services you request. We will limit sharing among our companies to the extent required by California law.

Vermont: In accordance with Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, except as permitted by law, such as with your consent, to service your accounts or to other financial institutions with which we have joint marketing agreements. We may share information about our transactions or experiences with you within our corporate family without your consent. Additional information concerning our privacy policies can be found at www.operator-academy.com/privacy or call 888-772-9002.

*Please keep in mind that, as permitted by applicable law, if you enroll in a co-branded service with us and one of our joint financial service providers, we share information about you with that company in connection with maintaining and servicing your account, including for that company to market to you. As permitted by applicable law, our products and services are subject to terms and conditions, which may include authorizations and consents to share information about you with your creditors. Federal law does not give you the right to limit this sharing

Your Right to Opt Out

You have the right to opt out of certain uses of your personal information, including:
• Marketing Communications: You may opt out of receiving promotional emails, texts, or other marketing communications from us at any time by clicking the “unsubscribe” link included in our emails, replying “STOP” to text messages, or contacting us directly at [insert contact email/phone].
• Sale or Sharing of Personal Information: If applicable, you may opt out of the sale or sharing of your personal information for targeted advertising purposes by [insert method, e.g., clicking “Do Not Sell or Share My Personal Information” link on our website, or contacting us at [insert contact]].
• Cookies and Tracking Technologies: You may adjust your browser settings to refuse cookies or alert you when cookies are being used. Additionally, you may manage your cookie preferences through our [Cookie Preference Center / Consent Banner], if available.
• Data Processing (where applicable by law): Depending on your jurisdiction, you may have the right to object to certain processing of your personal data, request restriction of processing, or withdraw previously given consent at any time.

To exercise any of these opt-out rights, please contact us at:
Heavy Construction Academy
[email protected]
5 Industrial Drive Brentwood NH 03833
888-772-9002

Please note that opting out of certain communications or data uses may affect your ability to use some features of our services. It may take up to 10 business days to process your opt-out request.

Dispute Resolution and Arbitration
Any dispute, claim, or controversy arising out of or relating to this Privacy Policy, including any alleged violation of applicable privacy laws or any belief that a violation may have occurred, shall be resolved exclusively through binding arbitration rather than in court, except where prohibited by law. Such arbitration shall be conducted in the State of New Hampshire, in accordance with the rules of the American Arbitration Association (AAA) then in effect. The arbitration shall be conducted by a single arbitrator, and judgment on the award rendered may be entered in any court having jurisdiction thereof. By using our services, you agree that any such dispute will be resolved on an individual basis and not as part of a class, consolidated, or representative action, to the fullest extent permitted by law. This arbitration provision shall be governed by the Federal Arbitration Act and, to the extent not preempted, by the laws of the State of New Hampshire, without regard to its conflict of law principles.