Privacy Statement

Information pursuant to Articles 13, 14, and 21 of the General Data Protection Regulation (GDPR)

1. What we do at Partners In Leadership

Partners in Leadership (“Partners”, “we”, “us”, “our”, or “our Company”) provides Accountability Training and Culture Change consulting services to corporate customers.

Our services include assessing our customers’ Workplace Accountability Index™ (individually, the “WAI”), Culture Advantage Index™ (individually, the “CAI”), and various 360 Assessments – all of which are based on employee assessments (collectively together, the “Assessment” or “Assessments”) that measure the level of accountability within an organization and how this impacts organizational agility. For creating the WAI or the CAI, employee responses are evaluated and compared with statistics from a previously administered WAI or CAI.

2. What this statement covers

Your privacy and trust are important to us. In this Privacy Statement (“Statement”), we explain how we collect, store, and otherwise process your personal data for improving our statistics on WAI or CAI responses (“Benchmarking”). Such Benchmarking enables us to relate employee responses to previously administered WAI or CAI and serves to generally improve the conclusiveness of the WAI or CAI that we measure. Benchmarking is not conducted for any of our 360 Assessments.

This Statement does not cover our processing of your personal data for determining the specific Assessment, WAI, or CAI of the organization you work for (“Your Organization”). For more information on this processing, please refer to Your Organization.

3. Controller of the data and whom to contact

We are data controllers with regards to the processing of your personal data for Benchmarking purposes (only). This means that we determine what data to process and how to process it.

Our contact details are:

27555 Ynez Rd # 300, Temecula, California 92591

info@partnersinleadership.com ;

assessments@partnersinleadership.com ;

https://www.partnersinleadership.com/about-us/contact-us/

Toll free number: (+1) 833-246-5323

4. Categories of personal data we process and sources we use

We process the following personal data about you in a depersonalized form:

– Some of the data you provide to us as part of your participation in the Assessment; this includes your Assessment responses with regards to Your Organization and might include demographic information about yourself.

– Some of the data Your Organization provides to us; this might include your gender, age, job level, department, location, and/or tenure.

We do not store your name or e-mail address for Benchmarking purposes. These details are deleted beforehand to ensure you are not directly identifiable through the WAI or CAI data.

5. Purpose and legal basis of processing your personal data

We process your personal data for the following purposes and based on the following legal provisions:

– Your consent, Article 6(1)(a) GDPR

Generally, the processing of your personal data by us is based on your consent. Your consent is expressly obtained before you take the WAI survey.

You may withdraw your consent at any time with effect for the future. If you want to withdraw your consent please click the opt-out link in the invitation e-mail or contact us at assessments@partnersinleadership.com.

– For compliance with a legal obligation, Article 6(1)(c) GDPR

In exceptional circumstances, we might process your personal data to fulfill a legal obligation, such as when this is necessary to comply with a court order.

6. Recipients of your personal data

As allowed by applicable law, we may share your personal data for the abovementioned purposes with the following third parties:

– Processors used by us (Article 28 GDPR) particularly in the field of IT services;

– Courts, arbitration tribunals, authorities or legal advisers if required to comply with applicable law or for the establishment, exercise or defense of legal claims;

– In case of a reorganization or sale of our Company or assets, to the respective acquirer, subject to the acquirer accepting the commitments made in this Statement.

7. For how long your personal data will be retained

We will store your personal data no longer than requested to fulfil the purpose for which it has been collected or as permitted or required by applicable law. This means that we will generally retain your personal data for as long as needed to continuously improve our Benchmark measurements and services.

8. Data transfer to third countries or an international organization

We are a US based company. Your personal data will be stored on servers in the US and/or Canada, provided that you have given us your explicit and informed consent to this.

The EU Commission has decided that for transfers of personal data to Canada, such as done by Partners, there is an adequate level of data protection. No decision by the EU Commission exists according to which the US generally offers an adequate level of data protection. In the US, data subject rights and data security requirements are not equivalent to the ones in the EU. Also, for our transfer of your personal data, there are no safeguards in place within the meaning of Article 46 of the General Data Protection Regulation, such as binding corporate rules approved by a supervisory authority. Independently from that, we are dedicated to providing a high level of data protection at all locations.

9. Your data protection rights

You have different rights related to our processing of your personal data:

– You may at any time request confirmation if and how we process your personal data (Article 15 GDPR).

– With reference to the personal data provided by you, you may have the right to receive a copy of this data in a structured, commonly used and machine-readable format so that you can further use or forward it to other organizations (Article 20 GDPR).

– If you are of the opinion that your personal data stored by us is incorrect or incomplete, you may request us to rectify or complete such data (Article 16 GDPR).

– Under certain circumstances, you also have the right to object to the processing of your data (Article 21 GDPR) and you may request us to restrict our processing of your data (Article 18 GDPR) and erase your data (Article 17 GDPR).

– You have the right to withdraw your consent to the processing of your personal data by us at any time (Article 7(3) GDPR).

However, there are some exceptions to these rights. For example, it is not possible for us to erase your data if we have a legal obligation to retain it or if we are unable to identify your personal data. Furthermore, information on and access to your data may be refused if the provision of the data would result in the disclosure of personal data concerning any other person or we are prevented from disclosing such data for legal reasons.

If you have any questions regarding our processing of your personal data or would like to express any concerns in this respect, please do not hesitate to contact us in writing using the contact information provided in section 3.

We take your rights and needs very seriously and always endeavor to fulfil them. If you are nevertheless of the opinion that the processing of your personal data constitutes a breach of the GDPR or any other applicable data protection law, you have the right to lodge a complaint with a data protection authority at your place of residence, place of work or the place where the breach is presumed to have occurred.

Your data subject rights vis-à-vis Your Organization remain unaffected by your rights and legal relationship with us.

10. Security

We take precautions—including administrative, technical, and physical measures—to safeguard your personal data against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.

The effective date of this Privacy Statement is February 5, 2020.

To view the Partners In Leadership general privacy policy, click here.