Integrity Solutions LLC offers a variety of employee and staff performance development, coaching, and related services. Integrity is committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our clients, business partners, and others who share their personal information with us.
This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under applicable data protection laws. We may also provide other privacy notices on specific occasions when we are using your personal information in ways that differ from what we have described here, so that you are aware of how we are using such information and what your rights are with respect to such use.
This Policy does not apply to your use of any third-party site linked through the Services or any Integrity website.
Who is responsible for your information?
Throughout this Policy, “Integrity” refers to Integrity Solutions LLC (also referred to as “we”, “us”, or “our”). For some information you provide information to us directly, Integrity will be the entity responsible for your personal information (and the controller for the purposes of data protection laws). Some portions of the Services are provided as a component of the services which Integrity provides to its clients and are provided by Integrity as a processor, which means that Integrity’s client is the controller and remains primarily responsible for your information. In these circumstances, we may re-direct a query about our use of your information to our client.
This Policy contains the following information, which you can access by scrolling down or clicking the links below:
- When and how do we collect your information?
- What information do we collect?
- How do we use your personal information?
- Do we collect information from children?
- How long do we retain your personal information?
- Do we disclose your personal information?
- Do we transfer your personal information across geographies?
- What security measures do we have in place to protect your information?
- What choices do you have about your personal information?
- How can you update your communication preferences?
- Other rights regarding your data
- Contact us
- Changes to this Policy
When and how do we collect your information?
Integrity collects personal information in the following ways:
- When we perform services for our clients and you. Our services include a variety of knowledge and skills development and coaching services. In these cases, your personal information will normally be provided to us by our clients (or facilitators or service providers acting on behalf of our clients), although in some instances you provide us directly both personal information and non-personal information about you.
- When you register with or use any of our websites or applications.
- If you contact us.
- When you attend a conference or event or event that we co-sponsor. We partner with third parties on conferences and events and receive attendee contact information from such partners from time to time.
What information do we collect?
Information you provide to us
When you set up an account
When you create an account to access and use any application, tool or platform that is part of or related to the Services, such as our learning management platform, we ask that you provide accurate and necessary information including the following:
- Email address
- Company name
- User name
Other information you provide (e.g., subscribing to newsletter, providing your contact information, completing an assessment)
In addition, when you upload or otherwise provide data, information or materials through or in connection with the Services, all such information is collected by us or our providers in order to provide the Services, including for example assessment answers so that we can provide you assessment results, business contact information so that we can communicate with you, email newsletter subscriptions so that we can send you monthly email newsletters and related content, and when you download thought leadership content made available through our website.
When you contact us
Further, when you contact us, we may ask for your name, email address and/or other information so we may process and respond to your request.
Information we collect from clients or third parties
When we provide our knowledge and skills development and coaching services for our clients, we may collect personal information about you from them, such as your name, contact details, along with other related information. The personal information we receive relates to your participation in the Integrity services that our clients engage us to provide.
We also acquire contact information from third parties for attendees of conferences and events that we sponsor.
In addition, we also collect information from third parties in connection with our Services, including our learning management platform service provider.
Services Usage Information:
We also collect certain information when you are using our Services, some of which is personal information and some of which is non-personal information, such as:
- Information about your interactions with our Services, which includes the data and time of any information you enter into our Services, and your interactions with other users of our Services. For example, we use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with the Services. For more information about Google Analytics, please visit google.com/policies/privacy/partners.
- Technical data which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our Services, unique device IDs, device attributes (such as operating system), network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system. Further details about the technical data that is processed by us can be found below.
Cookies. Cookies are small data files that are downloaded onto your computer or mobile device when you use our Services, which are unique to your device or account. Cookies make it easier for you to use the Services by saving your preferences so that we can use these to improve your next and subsequent visits to our Services – for example, remembering your login information. Cookies help us learn which areas of our Services are useful and which areas need improvement.
Cookies may be either persistent or temporary (or session) cookies. A persistent cookie retains user preferences for a particular website, app or service, allowing those preferences to be used in future use sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Pixels, Web Beacons. We or third party partners may use invisible pixels or beacons on the Services to count how many users access or use certain pages, features or content. This information is collected and reported in the aggregate. We may use this information to improve our current Services offerings, develop new products or services, and target information to you that may be helpful and useful to you based upon your use of the Services.
How do we use your personal information?
The following is a summary of the purposes for which we use personal information.
Providing the Services to you
We use your personal information as well as Services usage information and anonymized technical information to provide the Services to you.
Administering our client engagements
We process your personal information in order to perform our knowledge and skills development coaching services to our clients, as set forth in our client agreement. This may affect you, for example, where you are the employee, contractor or facilitator working with our client. The precise purposes for which your personal information is processed will be determined by the scope and specification of our client engagement, and by applicable laws, regulatory guidance, and professional standards. It is the obligation of our client to ensure that you understand that your personal information will be disclosed to Integrity (or to service providers such as Integrity).
Contacting, transacting with and marketing to you
If you are a current client or user, we process your personal information in order to:
- contact you in relation to current, future and proposed engagements;
- send you newsletters, promotional material and other marketing communications; and
- invite you to events (and arrange and administer those events).
If you are not a current client or user, we process your personal information that you have provided to us to send you newsletters, promotional material and other marketing communications; invite you to events, and respond to your requests.
Conducting data analytics
Integrity is an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We use both non-personal information as well as personal information you provide us or Services usage information in order to improve our Services and develop new products and services, for example by reviewing your access to and use of our Services, including your interactions with applications or functionality made available, linked to, or offered through, our Services to learn what is most valuable and helpful to you. We take steps to ensure that your rights and the legitimacy of Integrity’s activities are ensured through the use of aggregated or otherwise de-identified data.
- Provide information and services as requested by you;
- Provide information and services as requested by clients;
- Understand and assess clients’ ongoing needs and offer products and services to meet those needs;
- Improve our products and services;
- Execute monitoring and training;
- Ensure technical functionality and proper operation of our Services;
- Develop new services; and
- Conduct processing necessary to fulfill other contractual obligations for you and/or our clients.
If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected, we will request your consent. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.
All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:
- the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients, or where we are required to make disclosures to courts or regulators); or
- the processing is in our legitimate commercial interests, subject to your interests and fundamental rights (e.g. where we use personal information provided to us by our clients to deliver our services).
In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you certain communications.
Do we collect information from children?
Our Services and websites are not directed to children and we do not knowingly collect personal information from children through our Services or our websites. Children are prohibited from using our Services.
How long do we retain your personal information?
How long we retain your personal information depends on the purpose for which it was obtained and its nature. We may store your personal information as long as you use our Services to provide you with such Services and for legitimate business purposes.
We may store your personal information following your cessation of using the Services to the extent required to comply with our legal, accounting, or reporting requirements and to provide information about our Services (such as your transaction or communications history) requested by you or our clients. Additionally, we may continue to store your personal information contained in our standard back-ups.
Upon your request, we will delete or de-identify your personal information unless we are legally required or allowed to maintain such personal information.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Do we disclose your personal information?
We may share your personal information for the activities listed above.
We do not rent or sell personal information about our online visitors with unaffiliated third parties for their own marketing use. We do not share your personal information with third parties, except in the circumstances discussed below.
We share your personal information with your company or organization, which is our client, on whose behalf you are accessing or using the Services.
We may disclose personal information to business associates, licensors, and certain service providers who provide certain specialized services to us, our clients, and/or you, or who cooperate with us on projects, or provide services that may be of interest to you based on your engagement with or use of our Services. These Business Associates operate as separate controllers, and are responsible for their own compliance with data protection laws. You should refer to their privacy notices for more information about their practices.
- Learning management platform
- Business associates that provide services that may be of interest to you based on content you choose to access or download through our Services
Authorized Service Providers
We may disclose your information to service providers we have retained (as processors) to perform services on our behalf (either in relation to services performed for our clients, or information which Integrity uses for its own purposes, such as marketing). These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. These activities could include any of the processing activities that we carry out as described in the above section, ‘How we use your personal information.’
- IT service providers who provide hosting and manage our IT and back office systems and telecommunications networks
- Data analytics providers
- Marketing automation providers
We receive assurances from such third parties that they appropriately safeguard your data, and their activities are limited to the purposes for which your data was provided.
Legal Requirements and Business Transfers
We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request. (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that Integrity is subject to a merger or acquisition, to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.
Do we transfer your personal information across geographies?
We may transfer certain personal information across geographical borders to Integrity entities, authorized service providers or Business Associates in other countries working on our behalf in accordance with applicable law. Our affiliates and third parties may be based locally or they may be overseas.
We store your personal information in the United States or other locations that may be outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. If you are located in a country outside the U.S. and submit personal information to us, you consent to the general use and disclosure of such information as provided in this Policy and to the transfer and/or storage of that information to the U.S. and other countries outside your home country.
Where we transfer your personal information outside Integrity or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information.
What security measures do we have in place to protect your information?
The security of your personal information is important to us and Integrity has implemented reasonable physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information. Our service providers and agents are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose.
What choices do you have about your personal information?
We offer certain choices about how we communicate with you and what personal information you elect to share with us. You may choose not to receive marketing communications from us by clicking on the unsubscribe link or other instructions in our marketing e-mails or contacting us as noted below.
In addition, as noted above in “What information do we collect” you can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Services may be impaired and some features may not work as they were intended.
You may select a “do not track” setting on your web browser. However, these features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Notice
How can you update your communication preferences?
You can update your communication preferences in the following ways:
If you have created a profile or account through the Services, you can update your contact information after you log into your account.
If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.
Contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes.
Other rights regarding your data
Depending on where you live, you may have the following rights with respect to your data under certain circumstances.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information you have requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.
We may not always be able to fully address your request; for example, if it would affect the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to Access
You have right to access personal information which Integrity holds about you, including the purpose of our use, the categories of such data we have used, and the parties to whom we have disclosed it.
Right to Correction
You have a right to request us to correct your personal information where it is inaccurate or out of date.
Right to be Forgotten (Right to Erasure)
You have the right under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.
Right to Restrict Processing
You have the right to restrict the processing of your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
Right to Data Portability
You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine-readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.
Right to Object to Processing
You have the right to object to the processing of your personal information at any time, but only where that processing has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to Withdraw Consent
You have the right to withdraw your consent to our use of “special categories” of personal data by notifying us and your employer (if applicable) and directing them to inform us that you have withdrawn your consent.
Right to Receive a Copy
You have the right to receive a copy of your personal information upon request.
Right to Decline Automated Decision Making
We currently do not use automated decision making (including automated decision making using profiling) when processing your personal information. If we ever use an automated decision making solution, you have a right to request that a decision based off your personal information cannot be solely decided via an automated process.
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of this Policy, please contact us at firstname.lastname@example.org or (615) 385-2246. Alternatively, you have the right to contact your local data protection authority (depending upon where you live).
Changes to this Policy
We may update this Policy from time to time. When we do, we will post the current version on the Services, and we will revise the version date located at the bottom of the document. For any material changes, we also will send you an email or post an alert upon your next login to the Services.
We encourage you to periodically review this Policy so that you will be aware of our privacy practices.
This Policy was last updated on December 17, 2018.