Privacy Policy — Residency Compass

This Privacy Policy governs personal data processed in connection with Residency Compass (the "Tool"), a preference-analysis tool offered under the Residency Match brand. Residency Compass helps international medical graduates (IMGs) preparing to apply to residency evaluate and compare programs across a set of personal-fit conditions before deciding where to apply.

Two companies are involved, each responsible for a different part of the relationship:

• SpeakEasy Consulting LLC ("SpeakEasy"), a Puerto Rico limited liability company, creates and operates Residency Match and Residency Compass and delivers the Tool and its analysis. SpeakEasy is the data controller for the preferences you enter, the analysis generated, and related operational data. Address: Urb. Alturas del Mar, calle Coral 127, Cabo Rojo, PR 00623. Email: support@speakeasy-consulting.com.
• Closing Time Hub LLC ("Closing Time Hub"), a New Mexico limited liability company, is the merchant of record and sells paid access to Residency Compass. Closing Time Hub is the data controller for checkout, order, and billing data collected at the point of sale. Address: 4502 Hamptonshire Dr, Raleigh, NC 27613. Email: contact@closingtime-hub.com.

If you buy paid access, Closing Time Hub processes your order and payment and then transmits the information necessary to activate the Tool to SpeakEasy. Each company acts as an independent controller for the data it handles and shares data with the other only as needed to complete your purchase and give you access. "We," "us," and "our" refer to SpeakEasy and Closing Time Hub together where both are involved, and to the relevant company where only one is.

This Policy applies to individuals who use Residency Compass, visit its pages, or contact us about it. The Tool is offered to adults engaged in professional and educational development, primarily international medical graduates preparing to apply to residency.

Residency Compass is available in two tiers:

• a free tier, and
• a paid tier purchased through checkout, provided free to anyone who has purchased the Residency Match program.

Visitors located in the European Economic Area (EEA). The Tool is directed to individuals applying to residency programs in the United States. We do not target consumer sales to the EEA. Where we nonetheless process the personal data of individuals located in the EEA, we do so in accordance with the General Data Protection Regulation (GDPR), as described in Section 13, including the international-transfer safeguards in Section 10.

Depending on how you use Residency Compass, we may collect:

• Account and contact information: name; email address; and, for paid access, billing address and payment confirmation.
• Preference and analysis information (the core of the Tool): the ratings, weightings, and preferences you enter across the eleven fit conditions Residency Compass measures (for example, climate, proximity to family, and neighborhood safety, among others); the programs you are evaluating or considering; and the multivariable analysis and ranking the Tool generates for you.
• Technical information: IP address, browser and device type, and usage logs generated when you use the Tool.

We collect usage data about how you interact with the service, linked to a random browser identifier and, if you have an account, to your account. We use it to improve the service and to produce aggregated, non-identifying reports about residency program demand. We do not share information that identifies you individually.

The preferences you enter reflect personal priorities but do not require, and should not include, special-category data (such as health, religion, or similar). We do not sell or rent personal data, and we do not "share" personal data for cross-context behavioral advertising.

We process personal data for the purposes below. For individuals protected by the GDPR, the applicable legal basis is shown alongside each purpose.

We do not process personal data for purposes incompatible with those listed above. We do not use your preferences or results to profile you for advertising or to market residency programs to you.

Residency Compass is offered on a free tier and a paid tier. Individuals who have purchased the Residency Match program receive paid access at no additional charge.

Paid access is sold by Closing Time Hub as merchant of record through WooCommerce, using Stripe and PayPal as payment processors. We do not store full payment-card numbers. Card data is handled directly by Stripe and PayPal, which process it under the PCI-DSS standard. We retain order and billing records as required for tax and accounting purposes. The free tier does not require payment information.

Residency Compass collects the preferences you enter across eleven fit conditions and runs a multivariable analysis that scores and ranks the programs you are evaluating against those preferences. The output is a personalized comparison intended to help you understand your own position before you decide where to apply.

We use this data only to generate and return your analysis and to operate the Tool. We do not repurpose it for profiling, advertising, or program marketing. The Tool does not record audio or video. See Section 16 on the advisory nature of the analysis and Section 11 on how long we keep it.

We use cookies and similar technologies to operate the Tool and improve your experience:

• Essential cookies: required for security and to keep you logged in or to preserve your session. These cannot be disabled.
• Analytics cookies: measure traffic and usage (via Google Analytics).

Non-essential cookies, including analytics, are set only after you give affirmative, prior consent through our cookie banner. Until you consent, these tags do not run. You can accept, reject, or customize your preferences at any time, and rejecting is as easy as accepting. Disabling cookies may affect some features. Where required, we honor recognized browser-based opt-out signals, including the Global Privacy Control (GPC).

Any newsletter or promotional email (including "Prompting Humans") is sent only with your explicit prior consent, using a double opt-in process, and we store proof of consent. We do not use pre-checked boxes or implied consent. Using Residency Compass does not by itself subscribe you to anything.

When you subscribe, we may collect your email address, name (if provided), the date and time of subscription, technical metadata, and engagement data such as opens and clicks. Every message includes a clear unsubscribe link. You may withdraw consent at any time; after you unsubscribe, marketing emails stop, and we retain only the minimal information needed to honor your opt-out. Our email practices are designed to comply with the CAN-SPAM Act and, where applicable, the GDPR. We do not sell or share email addresses for third-party marketing.

We use trusted providers to operate Residency Compass. Each processes personal data only on our behalf, under confidentiality and data-protection terms, and only as needed to perform its function:

We may also disclose personal data when required by law or legal process, or in connection with a merger, acquisition, or business transfer.

Because Residency Compass is provided online, personal data may be processed in more than one country. The Tool and the data it collects are hosted and processed primarily in the United States:

• The application is hosted on Vercel (USA).
• The preferences and analysis data, moved by automated workflows, are stored in Google Workspace (USA).

For individuals in the EEA or UK whose data is transferred to the United States, those transfers rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and, where available, our providers' certifications under the EU–U.S. Data Privacy Framework. We apply access controls, encrypted communications, and contractual safeguards to protect data transferred between jurisdictions.

We keep personal data only as long as necessary for the purposes described, then delete or anonymize it:

• Preferences and generated analysis: for the duration of your access and up to [12 months] after your last use, or until you request deletion.
• Account and contact data: for the duration of your access, then up to [12 months], or until you request deletion.
• Billing and order records (paid tier): as required by tax and accounting law.
• Support communications: up to [2 years].
• Technical logs: up to [12 months].
• Newsletter data: until you unsubscribe.

We use appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration, including restricted access controls, secure hosting, encrypted storage, staff confidentiality obligations, and regular monitoring. Traffic between your browser and the Tool is protected with SSL/HTTPS encryption. No system can guarantee absolute security.

We honor privacy rights based on where you live. The core rights below are available to all users as a baseline; specific frameworks add to them.

Baseline rights (all users): access your data; correct inaccurate or incomplete data; request deletion (subject to legal retention); restrict or object to processing; request portability; withdraw consent; and unsubscribe from marketing.

Residency Compass is intended for adults and is not directed to anyone under 18. We do not knowingly collect personal data from minors, and we require users to confirm they are at least 18. Because the Tool is adults-only, it falls outside the scope of the U.S. Children's Online Privacy Protection Act (COPPA). If we learn that we have collected data from a person under 18, we will delete it.

If a security breach compromises personal data, we will investigate promptly. Where the GDPR or other applicable law requires it, we will notify the competent supervisory authority within 72 hours of becoming aware of the breach, and we will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights. Notifications will describe the nature of the breach, likely consequences, and recommended protective steps.

Residency Compass produces its ranking through automated calculation, but the result is advisory decision-support. It scores the programs you choose against the preferences you enter and returns a comparison for your own consideration. You decide where to apply. The Tool does not make any decision that produces legal or similarly significant effects about you, and it does not constitute automated decision-making of the kind restricted by Article 22 of the GDPR. If this changes, we will update this Policy and provide the disclosures required by applicable law.

The Tool may link to third-party sites we do not control. We are not responsible for their content or privacy practices. Review their policies before providing personal data.

We may update this Policy. Updates take effect when posted, with a revised "Last updated" date. Material changes will be communicated where required by law.

This Policy and any dispute relating to it are governed by the laws of the State of New Mexico, USA, without regard to its conflict-of-law principles, and the state and federal courts located in New Mexico will have jurisdiction. This choice of governing law does not deprive you of the protection of mandatory consumer-protection or data-protection rights available to you under the law of your country or state of residence.

Tool, preferences, or analysis matters — SpeakEasy Consulting LLC. Urb. Alturas del Mar, calle Coral 127, Cabo Rojo, PR 00623. Email: support@speakeasy-consulting.com.

Checkout, order, or billing matters — Closing Time Hub LLC. 4502 Hamptonshire Dr, Raleigh, NC 27613. Email: contact@closingtime-hub.com.