Privacy Policy

"The Company" refers to Gimbel Technologies, LLC, and all its affiliated products and websites, including,,, TraderChallenge, SpaceWalk, Learned Happiness, and Citizen Experiments.

The Company (“we”, “our”, or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive via our Service, as defined in the Terms of Service available at:

This Privacy Policy may be updated from time to time. Your use of the Service following any such update will signify and constitute your assent to and acceptance of such revised Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used herein have the same meanings as in our Terms of Service. 

This Privacy Policy does not apply to the products or services of any third parties, even if their products or services are linked to, or embedded within, our Service. For example, we may provide social media features as part of our Service that enable you to share information with your social networks. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We recommend that you review the privacy statements of the other parties with whom you interact before submitting any information to them. 

1.  Information Collection and Use

For the purposes of this Privacy Policy, “Personal Information” means information that can be used to uniquely identify you, such as your name and e-mail address.

Personal Information We Collect

When you interact with us, we may ask you to supply us with Personal Information.  For example, when you create an account with us, participate in a program, or otherwise use our Service, we may ask you to provide information such as your name, address, personal thoughts on a topic, and/or e-mail address.

If you connect with the Service via a social network platform (“SNP”) such as, without limitation, Facebook, the SNP will provide us with information, including Personal Information, about you, and we will treat that information in accordance with this Privacy Policy. The information we receive from an SNP may depend on the privacy settings you have with the SNP, so please check the SNP’s privacy and data practices before causing your SNP to connect with our Service.   

Our Use of Your Personal Information

We mainly use your Personal Information, either alone or in combination with other information, so that we can provide, enhance, improve and personalize our Service and related content, products, services, and marketing efforts.   

The following are examples of a variety of ways that we may use your Personal Information.  We may use your Personal Information:


*           to provide you with the best user experience possible;

*           to respond to your questions, and carry out the transactions you have requested;

*           to communicate with you regarding Service updates, offers, alerts, promotions, and events and/or about your Content and/or payments;

*           to help us develop, customize, deliver, support and improve our Service, products, content, and advertising;

*           to help authenticate any account you create with us;

*           to administer promotions and contests;

*           to protect the rights or property of The Company or our users, and prevent fraud and other prohibited or illegal activities;

*           to protect the security of our products, services, and business;

*           for research purposes

*           for our internal purposes (such as auditing, data analysis, and research to improve our products, services, and communications); and

*           otherwise, as disclosed to you at the point of collection.

If you decide at any time that you no longer wish to receive communications from us, please follow any unsubscribe instructions that may be provided in our communications to you, or send an e-mail request to us at the following e-mail address:  Please note that we may use your Personal Information to contact you with important notifications, such as notices with respect to safety, payments, or changes to our terms, conditions, and policies; you may not opt out of these notifications.

Public Forums & Content-Sharing Features

We may offer video features, message boards, commenting features, or similar public forums where you and other users of our Service can publicly post Content or otherwise communicate.  For example, the Service may include features and functionalities that allow users to post, embed or otherwise share user generated programs. The protections described in this Privacy Policy do not apply when you provide information (including personally identifiable information about any person) in connection with your use of the public forums and information-sharing features we make available. Any information you share in a public forum, including without limitation all information in programs you provide for display on the Service, is public information and may be seen or collected by other persons, including third parties that do not adhere to the standards set forth in this Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Service. 

Collection and Use of Non-Identifying Information

We may collect, use, transfer, and disclose information in a form that does not personally identify you (“Non-Identifying Information”) for any purpose.  Non-Identifying Information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We and/or our third party service providers obtain Non-Identifying Information about you from information that you provide us, either separately or together with your Personal Information, and from your clicking and other behaviors when using the Service. We and/or our third party service providers also automatically collect certain Non-Identifying Information from you when you access our Service or, in some cases, when you link your account on the Service with an SNP.

Certain Non-Identifying Information about you would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified. However, the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying information. We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users or sources to attempt to provide you with a better experience, to improve the quality and value of our products and services, to analyze and understand how our products and services are used, and for research purposes. We may also use the combined information without aggregating it to serve you specifically.  

Non-Identifying Information We Automatically Collect 

When you access our Service, we and our third-party service providers may use a variety of technologies and methods, now and hereafter devised, that automatically record certain usage information. This information may include your Internet Protocol address (and other unique identifiers for the particular device you use to access the Internet), browser type, your web or application request, your interaction with our Service, the webpage or other feature you were using before you came to our Service, pages of our Websites that you visit, information you search for via our Service, access times and dates, and other similar information. We use this information for a variety of purposes, including analyzing and enhancing our products and services, and to help personalize our Service for you. We do not treat this information as Personal Information (except to the extent required by local law), although if we combine it with the Personal Information you provide, we will treat the combined information as Personal Information.  We and our third-party service providers may automatically collect Non-Identifying Information using various methods, including, without limitation, cookies.    

A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service, to better understand how you interact with our Service and to monitor aggregate usage by visitors and online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. If you do not accept cookies, however, you may not be able to use all portions of our online services or all functionality of our online services. 

2.  Information Sharing and Disclosure

Except as described in this Privacy Policy, we will not share your Personal Information with other companies or individuals outside of The Company unless we have received your consent. Non-Identifying Information may be provided to third parties for marketing, advertising, research or other uses.

Our Service Providers and Other Third Parties

We may engage third party companies and individuals to perform services on our behalf (e.g., without limitation, payment processing, software maintenance services, e-mail notifications, database management, web analytics and other services). These third parties may have access to your Personal Information.  If they do, this access is provided so that they may perform these tasks on our behalf and they are not authorized by us to otherwise use or disclose your Personal Information, except to the extent required by law. If you have taken one of our Decision Academy courses through or on, your data, including Personal Information and Non-Identifying Information, may be shared with The BigThink Inc., in which case, their own privacy policy and terms of use will determine their usage of the data collected.


Compliance with Laws, Legal Process and Authorities

If you run or use a GuidedTrack program, the creator of that program, and any person the creator of that program adds as a collaborator or editor for that program, will have access to all of the data generated during your use of that program, including Personal Information and Non-Identifying Information.

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

Data Transfer

Your Personal Information may be transferred to, and used by, entities located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Such export is a requirement of providing your information to The Company, and you hereby authorize and consent to such export.   

Business Transfers

Circumstances may arise where, whether for strategic or other business reasons, we may sell, transfer or otherwise disclose some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

3.  General.

Changing or Deleting Your Information

The Company may make available the means to correct or modify certain Personal Information via our websites, but you may not have the means to modify some Personal Information after it is entered or submitted. Please note we may retain server/backup copies of all such data, and that we may decline to process change or deletion requests that we deem to be unreasonable, or require disproportionate technical effort, or jeopardize the privacy of others.    


We employ security measures to protect your Personal Information from unauthorized access, alteration, disclosure, or destruction.  These security measures include administrative and technical precautions to safeguard your Personal Information against loss, theft, and misuse.  Please be advised, however, that while we strive to protect your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your personally identifiable information.

Our Policy Toward Children

We do not knowingly collect personally identifiable information from children under 13 via our Service, and do not target our Service to children under 13. We encourage parents and guardians to take an active role in their children’s online activities and interests.


Our Privacy Policy applies to all of the services offered by The Company and its affiliates, including services offered on other sites (such as our ClearerThinking services, and ThoughtSaver services), but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including sites that may include The Company services (like, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies and other technologies to serve and offer relevant ads.

Contacting Us

If you have any questions about this Privacy Policy, please feel free to contact us via e-mail to


Privacy Policy Effective Date:   August 19, 2013