Privacy Policy

Learn and Earn Club Publications · Last updated: July 16, 2026

1. Who We Are and What This Policy Covers

This Privacy Policy is published by Capital P Holdings, Inc. d/b/a Learn and Earn Club ("we," "us," "our," or "Learn and Earn Club"). We publish one or more email newsletters and related publications (each, a "Publication," and collectively, the "Publications"), including, for example, The Residuary. This Policy explains what personal information we collect about you, how we use it, who we share it with, and the choices and rights you have, and it applies to all of our Publications whether or not a Publication is specifically named here.

This Policy applies to information we collect when you:

• subscribe to or read any of our Publications;
• visit any website we operate, including our Publication pages (which are hosted for us on the Beehiiv platform) and our corporate and marketing website (which is served through our hosting and content-delivery provider, Cloudflare);
• interact with our emails (for example, by opening them or clicking links); or
• otherwise communicate with us.

We are the "controller" (or, under certain U.S. state laws, the "business") responsible for your personal information in connection with the Publications and our websites. We use Beehiiv as our newsletter and website platform, its payment processor, Stripe, to process payments, and Cloudflare to host, serve, and secure our corporate and marketing website. When these providers process your information to deliver a Publication, serve a web page, or process a payment, they act as our service providers/processors under our instructions and under data processing terms between us. Beehiiv's own privacy practices for its corporate website and account-holders are described separately at https://www.beehiiv.com/privacy and are not part of this Policy.

2. U.S.-Only Audience; Persons Outside the United States

The Publications are intended solely for residents of the United States. Our content, products, and any commercial offerings are directed at a U.S. audience.

By subscribing to or using any Publication, you represent and warrant that you are located in, and a resident of, the United States.

The Publications are not offered or directed to, and we do not knowingly provide them to, individuals located in the European Union, the European Economic Area, the United Kingdom, Switzerland, or any other jurisdiction outside the United States. We do not intend to subject ourselves to, and do not undertake to comply with, the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK GDPR, or other non-U.S. data protection laws.

If you are located outside the United States, please do not subscribe to or use the Publications. If you nonetheless provide us with personal information, you acknowledge and agree that:

• your information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from and may be less protective than those of your home jurisdiction;
• you are providing that information on your own initiative and at your own risk; and
• you are responsible for compliance with any local laws applicable to your use of the Publications.

If we become aware that a subscriber is located outside the United States, we reserve the right to unsubscribe and remove that subscriber, and we may delete the associated personal information.

3. Information We Collect

We collect the following categories of personal information:

a. Information you provide directly. When you subscribe, this typically includes your email address and, if you provide it, your name. If you purchase a paid subscription, you will provide payment information; that payment is processed by our payment processor, Stripe (via our platform provider, Beehiiv), and we do not receive or store your full payment card number. We do receive transaction and billing records, such as the plan you purchased, the amount, the date, and whether a payment succeeded, failed, or was refunded. You may also provide information when you reply to our emails, respond to a survey, submit feedback, or otherwise contact us; when you email or otherwise correspond with us, we receive and retain that correspondence and its contents, including any information you include in your message or email signature.

b. Information collected automatically. When you open our emails or visit our web pages, we and our platform and analytics providers may automatically collect:

• engagement data, such as whether you opened an email, which links you clicked, and the date and time of those interactions;
• device and connection data, such as IP address, general location inferred from IP address, browser type, operating system, and device identifiers; and
• web analytics data, such as referring and exit pages and pages viewed; and
• website interaction data, such as clicks or taps, scrolling, page navigation, session timing, and other interactions used to produce heatmaps and reconstructed session recordings.

This information is collected using cookies, web beacons/pixels, tracking links, session-replay and heat-mapping technologies, and similar technologies. See Section 8 (Cookies and Tracking Technologies).

c. Information from third parties. We may receive information about you from service providers, analytics providers, and, if you subscribe through a referral, recommendation, or co-registration arrangement, from the partner through whom you subscribed.

d. Polls and surveys. Our newsletters may include polls or surveys, typically presented as multiple-choice questions. When you respond, our newsletter platform records your response, and your response may be associated with you (for example, with your subscriber record or email address). We retain these responses and use them as described in Section 4, including to prepare and publish aggregated, non-identifying summaries of reader responses. Responding to a poll or survey is optional.

e. Information we derive, and organization-level information we obtain. We derive or infer information about you from the information you provide and from your use of the Publications. In particular, because subscribers commonly sign up using a business or work email address, we may infer your employer or organization from your email domain and infer your likely professional field or interests. We may also obtain organization-level information (for example, firm size, practice areas, locations, industry, and similar firmographic details) about the employer or organization we associate with you, including from third-party data providers, and combine that organization-level information with your subscriber record to build a fuller profile of you and your organization. When we obtain organization-level information in this way, we request information about the organization; we do not provide the data provider with your email address or other identifiers that identify you individually.

We may also obtain limited professional information about you from publicly available sources, including professional networking websites such as LinkedIn. Where we do so, we collect only your public professional profile link (for example, your LinkedIn URL) and your current job title; we do not collect or retain your photograph, employment history, contacts, or other profile content.

We do not intentionally collect Social Security numbers, financial account numbers, government identifiers, precise geolocation, or other sensitive categories of personal information, and we ask that you not send them to us.

4. How We Use Your Information

We use personal information to:

• deliver the Publications you subscribe to and any content or products you request;
• send you administrative and transactional messages about your subscription;
• measure, analyze, and improve our content, deliverability, and engagement;
• respond to your inquiries and provide support;
• send you marketing about our Publications and, where permitted, related offerings;
• operate, secure, and troubleshoot our Publications and web pages, and detect and prevent fraud, abuse, and unauthorized access;
• create aggregated or de-identified information that does not identify you;
• analyze our subscriber base and build profiles of subscribers and their organizations, including by inferring employer and appending organization-level information as described in Section 3(e), to understand our audience, to decide which organizations and prospects to market to, and to develop and grow our Publications and subscriptions;
• conduct polls and surveys, analyze the responses, and prepare and publish aggregated summaries of reader responses that do not identify any individual; and
• comply with law and enforce our terms and agreements.

If we run advertising (see Section 7), we also use certain information for the purposes described there.

5. How We Share Your Information

We share personal information as follows:

• Service providers / processors. We share information with vendors that perform services for us, who are permitted to use it only to provide those services to us. Our primary platform provider is Beehiiv. In addition to Beehiiv, the following providers process personal information on our behalf: Stripe (payment processing); Cloudflare (website hosting, content delivery, security, and web analytics, which may process technical data such as IP addresses, request logs, and page-view information to serve, protect, and measure our website); Microsoft (Microsoft Clarity behavioral analytics, which processes technical and website-interaction data to provide heatmaps, reconstructed session recordings, and related analytics); and Google (email and correspondence hosting through Gmail/Google Workspace, which processes the email address, name, and message content of correspondence between you and us).
• Advertising partners. If and when we run advertising, we may share certain information with advertising networks and partners as described in Section 7.
• Legal and protective disclosures. We may disclose information to comply with a subpoena, court order, or other legal process; to respond to lawful requests from public authorities; to enforce our Terms of Service; or to protect the rights, property, or safety of Learn and Earn Club, our subscribers, or others.
• Business transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, your information may be transferred as part of that transaction.

We do not sell your personal information for money. For how certain advertising-related sharing is characterized under U.S. state laws, see Sections 7 and 9.

6. Data Retention

We retain personal information for as long as your subscription is active and for a reasonable period afterward to operate our business, comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need personal information, we delete or de-identify it. We may retain de-identified or aggregated information indefinitely.

7. Advertising

We may display advertising in the Publications, and we may do so either directly or through a third-party advertising network, including the advertising network operated by Beehiiv.

When we run advertising, we or our advertising partners may use cookies, pixels, tracking links, and similar technologies to measure ad performance and, in some cases, to deliver advertising that is more relevant to you, including across other websites and services ("targeted" or "cross-context behavioral" advertising).

Depending on how this advertising is configured, our sharing of identifiers, internet/online activity information, and similar information with advertising partners for these purposes may be considered a "sale" or "sharing" of personal information, or "targeted advertising," under certain U.S. state privacy laws, even where no money is exchanged. You have the right to opt out of this activity. See Section 9 (Your U.S. State Privacy Rights) for how to opt out, and Section 8 for cookie controls.

We do not knowingly "sell" or "share" the personal information of individuals under 18 years of age. The Publications are not directed to anyone under 18.

8. Cookies and Tracking Technologies

We and our providers use cookies and similar technologies (web beacons, pixels, tracking links, local storage, session-replay technologies, and heat-mapping technologies) to operate our web pages, remember your preferences, measure email and page engagement, perform analytics, and, if we run advertising, support advertising.

Microsoft Clarity. We use Microsoft Clarity to understand how visitors interact with our corporate and marketing website through tools such as click maps, scroll maps, heatmaps, and reconstructed session recordings. Clarity may process technical and interaction information, including device and browser information, IP-derived general location, pages visited, clicks or taps, scrolling, navigation, and session timing. Session recordings are visual reconstructions created from webpage content and user actions; they are not video recordings of a visitor's physical screen. Depending on our configuration, applicable law, and consent status, Clarity may use cookies or operate without cookies. Microsoft processes this information as described in the Microsoft Privacy Statement.

You can control cookies through your browser settings, and you can typically disable images in your email client to limit open-tracking pixels. If you disable cookies, some features may not function properly.

9. Your U.S. State Privacy Rights

Depending on your state of residence and subject to applicable law and its exceptions, you may have some or all of the following rights regarding personal information we hold about you:

• to know/access the categories and specific pieces of personal information we have collected;
• to obtain a portable copy of certain personal information;
• to correct inaccurate personal information;
• to delete personal information;
• to opt out of the "sale" or "sharing" of personal information and of "targeted advertising";
• to opt out of certain profiling, where applicable law provides that right, in furtherance of decisions that produce legal or similarly significant effects; and
• to not be discriminated against for exercising these rights.

How to exercise your rights. Submit a request by emailing [email protected] with the subject line "Privacy Request." To opt out of any sale/sharing or targeted advertising, email the same address with the subject line "Opt-Out".

We will verify your request using information reasonably necessary to confirm your identity (for example, by confirming control of the subscribed email address) before acting on access, correction, or deletion requests. Authorized agents may submit requests where applicable law permits, subject to proof of authorization.

Appeals. If we deny your request and you reside in a state that provides an appeal right, you may appeal by emailing [email protected] with the subject line "Privacy Appeal," stating the decision you are appealing and your reasons.

California Notice

For California residents: in the preceding 12 months we have collected the categories of personal information described in Section 3 (identifiers; commercial information, including subscription and payment-transaction records; internet/electronic network activity; professional or employment-related information, including inferred employer, current job title, public professional profile links, and organization-level information; poll and survey responses; and inferences drawn to create a profile about you), from the sources described in Section 3 (including you, your use of the Publications, service and analytics providers, and publicly available sources such as professional networking websites), for the purposes described in Section 4, and have disclosed them to the categories of recipients described in Section 5 (including our platform, payment, hosting, and email providers, Beehiiv, Stripe, Cloudflare, Microsoft, and Google). We do not sell personal information for money. To the extent any advertising activity described in Section 7 constitutes a "sale" or "sharing" under the California Consumer Privacy Act, you may opt out as described above. We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit its use.

10. Children's Privacy

The Publications are intended for adults and are not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us personal information, contact us at [email protected] and we will take appropriate steps to delete it.

11. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping any account credentials confidential.

12. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the "Last updated" date above and, if the changes are material, provide additional notice (for example, by email or a notice in the newsletter). Your continued use of the Publications after an update takes effect means you accept the revised Policy.

13. Contact Us

If you have questions about this Policy or our handling of your personal information, contact us at:

Capital P Holdings, Inc. d/b/a Learn and Earn Club
[email protected]