Effective Date: 12/16/2015
NOTE: The CLS Safe Harbor assessment is underway, but not yet complete. CLS complies with the U.S.-EU Safe Harbor Framework and 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 European Union member countries and Switzerland. CLS 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 CLS’ certification, please visit http://www.export.gov/safeharbor/.
CLS is a member of the VeraSafe Website Privacy Seal Program, meaning that VeraSafe has assessed CLS’ data governance for compliance with the VeraSafe Website Privacy Program Criteria. The program criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to notice, choice, access, data integrity, security and third-party information sharing.
In the case that a privacy complaint or dispute cannot be resolved through CLS’ internal process, CLS has agreed to participate in the VeraSafe EU Safe Harbor Dispute Resolution Procedure for U.S.-EU and U.S.-Swiss Safe Harbor disputes. To file a complaint with the procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/dispute-submission.
Information We Collect
Information We Automatically Collect
When you access our Services, whether by computer, mobile phone or other device, we automatically collect certain information about your use of our Services (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; referral source; length of visit; page views; your mobile carrier; IP address or other unique identifier for your computer, mobile phone or other device) using technologies such as cookies from Google Analytics.
When you download and use iSitLead®, our mobile application, we may also collect additional information about your mobile device, including the hardware model, operating system and version, mobile network information, time zone and geographic location information.
This information is not linked to personally identifiable information (called “PII”).
Information You Provide to Us
In some situations, you may provide us with your PII. PII could include your name, street address, telephone number, email address, answer to security questions, information about your company or business, name and contact information of colleagues, credit card and/or other payment/ordering information, if necessary, and any other information we collect about you that by itself is not PII but if combined with PII could be used to personally identify you.
You may provide us with PII when you:
- Complete a survey
- Make a purchase
- Register for certain services, or register and/or set up an account/profile to access, visit and/or use certain portions of our Website
- Enter a new feedback provider in Situational Leadership Online and
- Make any other transaction with us on or in relation to our Services
Do Not Track
Our Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.
How We Use Your Information
CLS Will Use Information We Automatically Collect To:
Improve your experience on our Services and to count users who visit our Services or open our HTML-formatted email messages.
We may use IP addresses to help diagnose problems with our server, administer our Services, analyze trends, track users’ movement, gather broad demographic information for aggregate use in order for us to improve the Services and deliver customized content.
CLS Will Use PII To:
- Respond to your inquiries and/or other requests or questions
- Provide and enable your use of the Services
- Contact you regarding a purchase
- Collect payments from you
- Send you:
- Goods or services purchased through our Website
- Information and updates related to your purchase, such as invoices and email notifications, which you have specifically requested
- Email messages containing company news, product or service information
Sharing PII With Third Parties
We may use third parties to perform certain services on our behalf. We may share your PII with these third parties solely to enable them to perform the services for us.
Such third parties include those:
- Hosting our Website, Platform, ecommerce storefront and data
- Managing the functionality of our Website and Platform
- Providing hosted CRM software that we use in our business
- Providing hosted survey software that we use in our business
- Processing credit or other payment card payments
- Fulfilling and processing orders
- Delivering products you have ordered
- Assisting with promotions and
- Enabling us to send you email
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. Your information will not be sold to nor will it be exchanged, transferred or given to any other company for any reason whatsoever without first obtaining your consent other than for the express purpose of providing our product(s) and/or service(s).
Disclosure of Information/Sharing Your Information
We may disclose your PII (i) 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 or (ii) 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 or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes.
We reserve the right to use, transfer, sell and share aggregated, anonymous data, which does not include any PII, about our Website and Platform users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
CLS has implemented and follows 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 information you transmit to us or from our Website or Platform; therefore, you use our Services at your own risk.
All credit card information you submit via our Website is transmitted via TLS encryption.
CLS is not responsible for the treatment of your PII or any of your information by any third party.
Please note that if you opt out of promotional/marketing emails, you may continue to receive certain communications from us, such as administrative and service announcements and/or messages about your account/profile.
Changing or Updating Your Information
Notice to California Residents — Your California Privacy Rights
California’s “Shine the Light” law, Civil Code section 1798.83, permits residents of California to request information about how a business shares their information with third parties for direct marketing purposes. However, under that law, a business is not required to provide this information if it has a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt out of such information sharing. We have such a policy and we will not share your information with third parties for their direct marketing purposes without your consent. If you would like to opt-out of our sharing of your information with third parties for their direct marketing purposes or to find out more about your opt out rights, please contact our Privacy Officer by email or by mail as described in the Contact Us section.
Attn: Bobee Sithivorada
Customer Relations and Technology Manager
The Center for Leadership Studies
280 Towerview Ct
Cary, NC, 27513
If you have any questions or concerns about the General Data Protection Regulation 2016/679 and our treatment of European Union or European Economic Area personal information, please contact our Data Protection Officer at DataPrivacy@situational.com.
Data Protection Officer: James Porter
Address: 280 Towerview Ct. Cary, NC 27513
Phone Number: +1-919-335-8783
EU Representative: Matthew Joseph
Address: Zahradnickova 1220/20A Prague 15000 Czech Republic