The Leadership Circle Web Applications Privacy Notice

Effective: December 20, 2016

We at The Leadership Circle, LLC (“The Leadership Circle,” “we,” “us,” and “our”) know that your privacy is important. This privacy notice is designed to assist you in understanding how we will process the personal data you provide when you use the following web application (the “web app”):

  • project-center.theleadershipcircle.com

Please read this privacy notice to learn more about the ways in which we collect and use your personal data. If we make any material changes to this privacy notice, we will notify you in accordance with the process described in the Changes section of this notice. By using our web app, you consent to our processing of your personal data as described in this notice, including the transfer of your data to the United States and the Philippines.

VeraSafe

This The Leadership Circle, LLC privacy policy complys with the VeraSafe Website Privacy Program Certification Criteria.

EU-U.S. Privacy Shield

With respect to personal data processed in the scope of this privacy notice, The Leadership Circle, LLC complies with the EU-U.S. Privacy Shield Framework (the “Privacy Shield”) as adopted and set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use, retention, and transfer of personal data from European Union member countries, as well as from Iceland, Liechtenstein and Norway. The Leadership Circle, LLC commits to adhere to and has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability, as well as the Supplemental Privacy Shield Principles, in each case with respect to all PII (as such term is defined in the section titled “Data We Process”) that The Leadership Circle, LLC receives in reliance on the EU-U.S. Privacy Shield.


To learn more about the Privacy Shield, and to view The Leadership Circle, LLC’s certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively.

U.S.-Swiss Safe Harbor

With respect to personal data processed in the scope of this privacy notice, The Leadership Circle, LLC complies with the U.S. - Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. The Leadership Circle, LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view The Leadership Circle, LLC’s certification, please visit http://www.export.gov/safeharbor/.

VeraSafe Privacy Program

The Leadership Circle is a member of the VeraSafe Privacy Program, meaning that with respect to personal data processed in the scope of this privacy notice, VeraSafe has assessed The Leadership Circle’s data governance and data security for compliance with the VeraSafe Privacy Program Certification Criteria. The certification criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to notice, onward transfer, choice, access, data security, data quality, recourse and enforcement.

Data Controllership

We are the data controller for the data processed in our web app.

Data We Process

When you access our web app, whether by computer, mobile phone, or other device, we automatically collect certain information about your use of our web app. This information may include, without limitation, geographical location and IDs of your computer, mobile or other device, bandwidth used, system and connection performance, browser type and version, operating system, length of visit, page views, referral source, unique identifier for your computer, mobile phone or other device, and your mobile carrier. To collect this information we may use technologies such as cookies and web beacons.


This information is not linked to personal data (“PII”).


Data You Provide To Us

In some situations you may provide us with your PII, which could include your:

  • name;
  • email address;
  • mailing address;
  • profession;
  • job title/position;
  • race;
  • gender;
  • information that describes an individual's leadership style;
  • IP address; and
  • any other data you provide that by itself is not PII but if combined with PII could be used to personally identify you.

You may provide us with PII in our web app when you:

  • setup a goal in the web application;
  • invite an evaluator via our web application; and
  • complete a survey.

Lawful Basis of Processing

We process PII on the basis of your consent, or on the basis of legitimate interests pursued by our customer(s), such as the desire to track leadership qualities over time. You may withdraw your consent by requesting that we delete your PII, as described in the section titled “Access, Review & Opting Out.” 


Purposes of Use

We may process your PII for the purposes of:

  • enabling your use of the web app;
  • retaining your data, indefinitely, for your future use, although we will always respect your request(s) that we delete your data (subject to the limitations described in this privacy notice); and
  • sending you email notifications which you have specifically requested.

Confidentiality

Except as provided in this privacy notice, we will maintain the confidentiality of PII we process.

Data Integrity and Security

We have implemented and follow commercially reasonable measures to protect against unauthorized access to and unlawful interception or processing of PII. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any data you transmit to us or from our web app, therefore you use our web app at your own risk.


If you use our web app, you are responsible for protecting the security of your user name and password. You are responsible for any transaction made using your user name and password.

Access, Review & Opting Out

You can access, change, delete or update PII you have provided and your subscriptions or preferences regarding information you receive from us by logging into our web app and making changes in the My Account section, where applicable. Alternatively, you may email us at the email address found in the Contact Us section of this notice. We will implement your requested changes as soon as we reasonably can.


When you edit your PII or change your preferences, data that you remove may remain in our databases or backup media because it is not always possible to completely remove or delete information from those locations.


Please note that if you opt out of promotional or marketing emails, you may continue to receive certain communications from us, such as administrative and services announcements and messages about your account or profile.

Disclosure of PII

We may disclose your PII:

  • to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
  • if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change;
  • to our subsidiaries or affiliates only if necessary for business and operational purposes; and
  • to our vendors if necessary in order to provide you with service as further described below.

We may use third party vendors to perform certain services on our behalf, such as:

  • web hosting and managing service providers;
  • maintenance and development service providers;
  • tracking analytics service providers;
  • email service providers; and
  • administrative services providers.

We may share your PII with these third party vendors solely to enable them to perform the services for us. In providing such information, we require that those third party vendors maintain at least the same level of confidentiality that we maintain for such information. We do not provide your PII to parties unconnected with the services we provide.


We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our web app users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.


Liability for Onward Transfer

When we transfer your PII to our third party vendors for processing on our behalf, we are liable for such processing, including processing that is inconsistent with this privacy notice (unless we are not responsible for the event giving rise to such noncompliant processing).

Data Retention

PII that we process in the web app is retained indefinitely, or until the data subject instructs us to delete such data. Please note that requests to erase PII are subject to the limitations described in the section titled “Access, Review & Opting Out.”

Privacy of Children

Our web app is not directed at, or intended for use by, children under the age of 13. We do not knowingly allow anyone under 18 to provide any PII on our web app. Children should always get permission from a parent or guardian before sending personal information over the Internet. If you believe your child may have provided us with PII, you can contact our Privacy Officer using the information in the Contact Us section of this privacy notice and we will delete the data.

Changes to This Privacy Notice

We may update this privacy notice from time to time by posting a new version on this web page. You should visit this page occasionally to ensure you agree with any changes.


By continuing to use our web app after we post any such changes, you agree that you accept the privacy notice as modified.

Questions or Concerns, Contact Us

If you have a complaint, dispute, or questions regarding this privacy notice or our treatment of your PII, please write to our privacy officer by email at privacy@fcg-global.com


or by postal mail at:
Attn: Privacy Officer, The Leadership Circle, LLC
Nathan Delahunty
5671 S Redwood Road, Suite 20
Salt Lake City, UT 84123
USA


We will respond to your inquiries within four weeks.

Dispute Resolution

If a privacy complaint or dispute cannot be resolved through The Leadership Circles’ internal process, The Leadership Circle has agreed to participate in the VeraSafe Dispute Resolution Procedure. Subject to the terms of the VeraSafe Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/dispute-submission

Binding Arbitration

If your dispute or compliant can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

Regulatory Oversight

The Leadership Circle, LLC is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.


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