A Note to Users Outside of the United States re Data Transfers. Your data, including Personal Information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations and laws may not offer the same level of protection as in other parts of the world. We will take all steps reasonably necessary to ensure that your data, including Personal Information, is treated securely and in accordance with this policy.
Types of Data We Collect. We collect information about you in a range of forms, including Personal Information. “Personal Information”(or “Personal Data” as defined in the EU General Data Protection Regulation “GDPR”) is data that allows someone to identify or contact you, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that does not relate to an identified or identifiable natural person or to Personal Information rendered anonymous in such a manner that the data subject is not or is no longer identifiable. Anonymous Data does not, by itself, permit the identification of individuals. We collect Personal Information and Anonymous Data, as described below.
Why do we need your Personal Information? We will only process your Personal Information in accordance with applicable data protection and privacy laws. We need certain Personal Information in order to provide you with access to the Site and Services. If you created a profile/registered with us, you will have been asked to indicate your agreement to provide this data in order to access our Services, purchase our products, or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your Personal Information in line with this policy, please do not use our Site or Services.
(a) Information You Provide Us.
We or our affiliates collect your first and last name, e-mail address, and password when you create an account to log in to our network (“Account”). You are also required to tell us where you are based. You may also supply additional contact information, such as your mailing address, your job title and your organization name.
We collect information, including Personal Information, from any behavioural assessments and Services we provide.
If you use our Services on your mobile device, including through our Applications, we may collect your phone number and the unique device id number.
Our mobile homepage lets you store preferences like your location, safe search settings, and favourite widgets. We may associate these choices with your ID or the mobile device, and you can edit these preferences at any time on our mobile homepage.
When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
When you order Products or Services on our online store, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.
We retain information on your behalf, such as files and messages that you store using your Account.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. This information may be shared with third parties who help process and fulfil your purchases. When you submit credit card numbers, we encrypt that information using industry-standard technology.
When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Site, the information contained in your posting will be stored on our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page (“Profile”). The information that you provide in your Profile will be visible to others, including anonymous visitors to the Site.
When you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
When you participate in one of our surveys, we may collect additional profile information.
We also collect other types of Personal Information that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
If you participate in a sweepstake, contest or giveaway on our Site, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes physical addresses to verify your identity. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstake and contest that you enter.
8. Information Collected via Technology Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Pixel Tag In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track the online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format that users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Information.
Do Not Track. We do not currently respond to “do not track” signals from web browsers.
Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our Applications. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Applications, and information about the type of device you use. In addition, in the event our Applications crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Applications. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. Our Site and Services may use any or all of the following types of cookies for the purposes set out below:
Type of cookies Purpose
Essential Cookies These cookies are essential to provide you with services available through our Site and Services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow our Site and Services to remember choices you make when you use our Site or Services, such as remembering your login details and remembering the changes you make to other parts of our Site and Services. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site or use our Services.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Site and Service and how users use our Site and Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site or used our Services, and whether they have visited our Site or used our Services before, and other similar information. We use this information to help operate our Site and Services more efficiently, to gather broad demographic information and monitor the level of activity on our Site.
We use Google Analytics and other third-party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site and Services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Site and Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices,http://www.aboutads.info/choices or http://www.networkadvertising.org. If you choose to remove targeted or advertising cookies, you will still see advertisements but they may not be relevant to you. Even if you do choose to remove cookies from the companies listed at the above link, not all companies that serve online behavioural cookies are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Social Media Cookies These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
(d) Information Collected from Third Party Companies. We may receive Personal Information and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or affiliate website that offer their products and/or services on our Site. These third-party companies may supply us with Personal Information. For example, we use Eventbrite for our events. Eventbrite shares the Personal Information they collect with us and we add that Personal Information to our database.
9. Use of Your Personal Information
In general, the Personal Information you submit to us is used either to respond to requests that you make or to aid us in serving you better. We also use your Personal Information to:
facilitate the creation of and secure your Account on our network;
identify you as a user in our system;
provide improved administration of our Site and Services;
provide the Services you request;
improve the quality of experience when you interact with our Site and Services;
send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
send you administrative e-mail notifications, such as security or support and maintenance advisories;
respond to your inquiries related to employment opportunities or other requests; and
send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Organizational Soul Ltd.
(a) User Testimonials and Feedback. We receive, and occasionally publish, testimonials and comments from users who have had positive experiences with our Services. When we publish this content, we may identify our users by first and last name, job title, company, country, or other information provided for the testimonial. We obtain user consent prior to posting his or her name along with the testimonial. We may post user feedback on our Sites from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting your name with your feedback. If you make any comments on a blog or forum associated with our Sites, you should be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to submit to these blogs and forums.
(b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Information by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to gain better insight into how our Services are working and to conduct research about global trends to advance the understanding of emotions, emotional intelligence, and positive change. We also use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties at our sole discretion.
We will share your Personal Information with other Users solely for the purpose of providing the Services. For instance, licensees must have certain information, such as name, email address, and assessment information, to provide the Services to you.
Third-Party Service Providers. We may share your Personal Information with third-party service providers to provide you with the Services that we offer you through our Site; for example, third-party assessment tools; conducting quality assurance testing; facilitating the creation of accounts; providing technical support; and/or to provide other services to the Company. These third-party service providers are required not to use your Personal Information other than to provide the services requested by Company.
Disclosure to Third Party Companies. We may enter into agreements with companies that provide our Services by way of affiliates, co-branded or private-labelled websites or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Information that we collect from its customers. As a result, we may disclose your Personal Information to a Third Party Company; however, we will not disclose your Personal Information to any Third Party Company for the Third Party Company’s own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive e-mail communications from a Third Party Company and later wish to discontinue receipt of these e-mails, please contact the Third Party Company directly to update your preferences. The privacy policies of these Third Party Companies may apply to the use and disclosure of your Personal Information that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of Third Party Companies, you should read and understand their privacy policies.
11. Your Rights and Choices. You have several choices regarding the use of information on our Service:
Opt-out. You may contact us anytime to opt out of: direct marketing communications, including newsletters and emails; or the transfer of your Personal Information outside your country. Please note that your use of some of the Sites or Services may be ineffective upon opt-out.
Your data is portable – i.e. you have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example, when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
Applications; De-Linking SNS. You can stop all collection of information by the Applications by uninstalling them, either through the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You may also de-link the SNS account in the “preferences” section in your account settings if you wish to de-link your Account from the SNS account. You may also manage the sharing of certain Personal Information with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.
If you wish to exercise any of these rights, please contact us using the contact information above. In your request, please make clear: (i) what Personal Information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you used to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
12. Online Security
For online payments, you may elect to use the following payment services on our sites; for more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to the links for each payment processor:
Organizational Soul Limited is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Organizational Soul Limited uses reasonable efforts to protect your Personal Information, Organizational Soul Limited cannot guarantee its absolute security.
13. Retention. We will only retain your Personal Information as long reasonably required for you to use the Site/Application(s) and/or to provide you with the Services and/or until you close your account/cancel your subscription unless a longer retention period is required or permitted by law (for example for regulatory purposes).