The Academy of Brain-based Leadership LLC (ABL), 50 Via De La Mesa, Rancho Santa Margarita, CA 92688 USA, is committed to protecting and respecting your privacy.
This Policy (and any other documents referred to in it, and any other contractual terms that may be in place between us and you) sets out the basis on which any Personal Data that we collect from you or process for you through our Services, will be used by us.
For the purposes of the EU General Data Protection Regulation (“GDPR”), in the cases where we gather data through our websites and marketing campaigns, we are the “data controller”. For more details on how The Academy of Brain-based is GDPR compliant please visit this page.
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Information we may collect from you
Through our websites, registration systems or learning platforms
You may give us information about you by filling in forms on our websites or by corresponding with us by email, phone or otherwise. This includes information you provide when you register and subscribe to use our services, contact forms you may submit on any of our websites, and communications with our team.
The information you give us may include your name, email address, physical address, work role, gender, address, phone number, institution name, bank account/credit card information in order to pay for products and/or services within the service.
When purchasing products and services via these websites you will asked for your credit card/payment details by a third-party provider (Paypal or Stripe) in order to pay for the service within the service. Please refer to Paypal’s and Stripe’s privacy policies for information on the protection of this data.
When you pay for a product and/or a service via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity. Such information may include, without limitation: Date of birth, Passport or National ID card, Bank card statement, Other information linking you to an address
Through our S.A.F.E.T.Y.TMAssessment (ablsafety.com)
When completing the S.A.F.E.T.Y.TM Assessment you are requested to give us the following information: your first name, last name, email address, gender, work role, ethnicity, birth year, education, country as well as your responses to 50 questions.
Through our marketing campaigns
You may give us information about you when filling in forms in our content marketing campaigns (for example in the case where we offer a brochure or white paper in the exchange of your data), registrations to webinars and other events, subscribing to our blogs, or participating in marketing activities at trade-shows and conferences.
The information you give us may include your name, email address, country, state, city, phone number, institution type, institution name, institution website, and institution size.
Tracking technologies and cookies
We do not collect any personal information from you when you visit our site unless you expressly and voluntarily participate in an activity that asks for it and you voluntarily provide it. We use voluntarily provided personal information to communicate directly with you by email. We do not sell or rent your personal information to third-party data vendors or marketing companies.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.
We use both session cookies and persistent cookies on our websites.
Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies. The cookies used on the website include those which are strictly necessary cookies for access and navigation, cookies that track usage (performance cookies), remember your choices (functionality cookies), and cookies that provide you with targeted content or advertising
We may use the information we obtain from your use of our cookies for the following purposes:
- to recognise your computer when you visit the website
- to track you as you navigate the website, and to enable the use of any e-commerce facilities
- to improve the website’s usability
- to analyse the use of the website
- in the administration of the website
- to personalise the website for you, including targeting advertisements which may be of particular interest to you.
When you use the website, you may also be sent third party cookies.
Our advertisers and service providers may send you cookies. They may use the information they obtain from your use of their cookies:
- to track your browser across multiple websites
- to build a profile of your web surfing
- to target advertisements which may be of particular interest to you.
Most browsers allow you to refuse to accept cookies. For example:
- in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;
- in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.
- in Google Chrome you can adjust your cookie permissions by clicking “Options”, “Under the hood”, Content Settings in the “Privacy” section. Click on the Cookies tab in the Content Settings.
- in Safari you can block cookies by clicking “Preferences”, selecting the “Privacy” tab and “Block cookies”.
Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use certain features on the website (log on, access content, use search functions).
You can also delete cookies already stored on your computer:
- in Internet Explorer, you must manually delete cookie files;
- in Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools”, “Options” and “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu.
- in Google Chrome you can adjust your cookie permissions by clicking “Options”, “Under the hood”, Content Settings in the “Privacy” section. Click on the Cookies tab in the Content Settings.
- in Safari you can delete cookies by clicking “Preferences”, selecting the “Privacy” tab and “Remove All Website Data”.
Obviously, doing this may have a negative impact on the usability of many websites.
“Do Not Track”
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Statement.
How do we use your data?
Data collected through our websites or use of our services
The data provided by users when using/subscribing to our products and services is used in the following ways:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account:to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract:the development, compliance and undertaking of the contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You:To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide Youwith informative emails, periodic newsletters, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests:To attend and manage Your requests to Us.
Data collected through the S.A.F.E.T.Y.TM Assessment (ablsafety.com)
The data and answers provided by users when completing the SAFETY assessment is lawfully processed under ‘user consent’ and may be used in the following ways:
- To generate your SAFETY scores and profile. The answers you provide to the 50 questions in the SAFETY assessment are used to calculate your ‘scores’ for each of the first 5 domains of SAFETY (Security, Autonomy, Fairness, Esteem, Trust). This calculation is made using an algorithm based on normalized data of all users. These scores are used to generate your profile report that contains your SAFETY scores and provides insights into what your scores in each domain might indicate about your needs and behaviors as well as the possible impact your profile may have on yourself and on others.
- PDF Profile Report is securely emailed to the email address you provide to us when completing the assessment and is encrypted in transit. This Report is generated in runtime and is not stored on any system. Your report will remain your property and you will maintain complete control of who, how and when it is shared. We will not share, store or provide details of your profile to any third party.
- If completed as part of a workshop/training/coach initiative managed by a 3rd party:
If you complete the assessment as part of a workshop, coaching session or other initiative instigated and managed by a third party (eg your employer, coach, training provider) you may be requested to share your report with the organizer for printing and/or collation of your anonymous results into a team report for use in that engagement. The decision to share the report is left to your discretion and as soon as your data is passed onto someone else we have no responsibility for the storage, use or protection of that data.
- If completed as part of a workshop/training/coach initiative managed by Us:
In the case where you share your report with Us in preparation for a workshop, coach session or other initiative we are managing or facilitating, your data will not be stored, shared or used for any other purpose other than for printing of the report or using your anonymous scores to collate a team report for use in that session. Your report will be managed according to our data protection policies and processes and will be securely deleted at the completion of the initiative. You will maintain complete control of who, how and when it is shared within the scope of the engagement.
- Assessment Validation and Norming: your data will also be used for analysis, validation and norming of the SAFETY assessment. All identifiable personal data (ie first name, last name, email) is deleted before processing.
Data collected through marketing campaigns
The data collected through marketing campaigns is used in the following ways:
- In future marketing campaigns that might be suited for them such as invitations to webinars and events, content marketing campaigns, campaigns related to our platforms and blogs, research campaigns related to our platforms, blogs, and industry.
We may share your personal information in the following situations:
- With Service Providers:We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to help support and maintain our products and services, for email marketing campaigns, for payment processing for products and services, for registrations and subscriptions, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
- For Business transfers:We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With other users:when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see You name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
We do not make any automated decisions soley through automated means.
How long do we store data
The retention periods of your personal information depend on the respective purpose for which the data is processed and the respective tool/product in which the personal information is processed in. It is not possible to outline the various retention periods in a reasonable intelligible format under this Policy. The criteria used to determine the applicable retention period are that we will retain the personal information set out in this policy for as long as:
- Necessary for the respective purpose
- Necessary to carry out our business relationship with you
- You have consented to, and/or
- Required by applicable statutory retention laws
For further details on our Retention Policy and specific data retention periods please contact us at email@example.com.
Transfer of your personal data
Your information, including Personal Data, is processed at ABL’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Sharing your personal data
To facilitate our efficient use of your information, and to provide you with the content and/or resources, we disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
Suppliers, contractors and agents: we may engage or employer other companies and individuals to perform functions on our behalf. Examples could be data analysis, hosting and/or maintaining website content, the provision of certain features contained on the website, or the provision of marketing or support services. Third parties are provided only the information required to perform their function and are not permitted to use personal data for any other purposes. Third parties are subject to contractual confidentiality obligations and data protection agreements.
Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements: The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Where do we store your personal data
As explained in the “Sharing Your Personal Data” paragraph above, your personal data may be collected and stored with Third-party suppliers, contractors, agents. Where we use a third-party supplier, contractor or agent your personal information remains under our control and we have controls in place to ensure your personal information is adequately protected.
We endeavour to take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy.
The security of Your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. For this reason, any transmission is at your own risk. We use strict operational procedures and adequate technical and organizational security measures to prevent any unauthorised access, change, deletion or transmission of this personal information.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent:You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract:Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations:Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Legitimate interests:Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
How you can access, correct and delete your personal information
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the information we have on you. You can access, update or request deletion of your personal data by making a request at firstname.lastname@example.org. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You.You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of Your Personal Data.This right exists where we are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes you want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Right to be forgotten/Request erasure of Your Personal Data.You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. You may make such a request at any time and we will evaluate whether your request should be granted. However, this right is subject to any legal rights or obligations we may have to retain data. For situations where, in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
- Request the transfer of Your Personal Data.We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Your consent.You have the right to withdraw your consent on using your personal data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before receipt of such withdrawal.
- California Residents are entitled to ask for a notice identifying the categories of personal information that we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. Please note that we do not rent, sell, or share in any manner, your personal information in personally identifiable form to anyone for marketing purposes.
You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising your data protection rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
To exercise your rights email us at email@example.com.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Links to other websites
Where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by click the ‘unsubscribe’ or ‘opt-out’ function in the email. In addition, you can also exercise your opt-out right at any time by emailing us at firstname.lastname@example.org with ‘UNSUBSCRIBE’ in the subject line, or contact us at +1 41 5935 4027.
Changes to this policy
Questions, comments and requests regarding this Policy are welcomed and can be addressed to us by mail at: The Academy of Brain-based Leadership LLC, 50 Via De La Mesa, Rancho Santa Margarita, CA 92688 USA, or by email email@example.com.
For requests related to your personal data email us at firstname.lastname@example.org