Privacy Policy
1. Overview
This Privacy Policy describes how Personal Data (defined below) are collected, used, shared, and otherwise processed about:
- Visitors to this website, Leadership Transformation Platform, other SaaS tools, mobile applications, and online properties (each, the “Site”).
- Contact persons for organizations and/or individuals.
- Contact persons for suppliers of goods and services.
- Any other individuals about whom the Personal Data are obtained.
In this Privacy Policy, “Personal Data” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognized directly or indirectly. The Privacy Policy also covers cookies (Section 6) and data security (Sections 8,9) provisions related to the Site.
Unless specifically stated otherwise in Section 5, Daniil Klyuchnikov, is the data processor of the Personal Data of organizations and individuals through the Leadership Transformation Platform. He is responsible for ensuring compliance with applicable data protection laws for the Site’s systems and processes. Having successfully completed data protection training, he is accountable for adhering to this Privacy Policy and associated policies when handling Personal Data.
2. Collection of Personal Data
The following categories of Personal Data about the Site’s visitors, organizations, individuals, suppliers, and other third parties may be processed by the data processor:
- Basic data: Name, gender, title, organization, job responsibilities, phone number, mailing address, email address, contact details.
- Registration data: Newsletter requests, event/seminar registrations, subscriptions, downloads, and username/passwords.
- Research data: Personal Data received from organizations in respect of their employees, organizations themselves or other individuals, and feedback from organizations or individuals.
- Transaction data: Personal data contained in documents, correspondence or other materials provided by or relating to transactions conducted by organizations or individuals.
- Device data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Site (Usage Data).
Where the Personal Data is received from organizations about employees, organizations themselves, or other individuals, the organizations and / or individuals are responsible for ensuring that any such data is transferred to the data processor in compliance with applicable data protection laws.
3. Use of Personal Data
The purposes for which the Personal Data is used, and the legal bases for such processing, are as follows:
- To manage research operations and administer relationships with organizations and individuals, basic data, special categories of data, registration data, other research data are used. This processing is necessary to perform obligations under research engagements with organizations or individuals and suppliers.
- To make the Site more intuitive and easy to use, device data are used. It is necessary for our legitimate interests to monitor how the Site functions to improve the layout and information available, providing a better service to the Site’s users.
- To protect the security and effective functioning of the Site and information technology systems, basic data, registration data, and device data are used. It is necessary for legitimate interests to monitor how the Site functions to detect and prevent fraud, other crimes, and the misuse of the Site. This helps ensure that you can safely use the Site.
- To address compliance and legal obligations, such as compliance data, basic data, registration data, and device data are used. This processing is necessary for complying with legal requirements to which the data processor is subject.
4. Sharing of Personal Data
The Personal Data may be shared with the following categories of recipients:
- Suppliers and service providers: Personal Data may be shared with suppliers and service providers to enable them to perform functions under clear instructions for the purposes identified above. These include, for examples, infrastructure and IT services providers. These parties are contractually obligated to provide reasonable security for Personal Data and to use and process such data on behalf of the data processor only.
- Mandatory disclosures and legal claims: Personal Data may be shared to respond to any subpoena, court order, or other legal process, comply with requests from regulators or governmental entities, or fulfill any other legally enforceable demand. Personal Data may also be shared to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
If you have questions about the parties with which Personal Data are shared, please contact the data processor as specified below.
5. Cookies
Certain providers may use and engage to use cookies, (collectively, “cookies“) on Site.
What are cookies?
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to the Site.
How cookies are used?
Cookies are used on the Site, and certain third parties are allowed to place them, to provide the Site and services, gather information about your usage patterns as you navigate the Site to enhance your personalized experience, and to understand usage patterns for the purpose of improving the Site, products, and services.
Cookies on the Site are generally divided into the following categories:
- Necessary Cookies: These cookies are necessary for the Site to function and cannot be switched off in systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
- Functional Cookies: These cookies enable the Site to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services are added to the Site. If you do not allow these cookies then some or all of these services may not function properly.
- Performance Cookies: These cookies allow to count visits and traffic sources so the performance of the Site to be measured and improved. They help to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies it is unknown when you have visited the Site, and its performance cannot be monitored.
- Targeting Cookies: These cookies may be set through the Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
- Social Media Cookies: These cookies are set by a range of social media services that might be added to the Site to enable you to share available content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
What are your options if you do not want cookies on your computer?
When you first visit the Site, you will be asked for your consent to the use of any cookies which are not classed as strictly necessary. You can manage your choices using the consent management tool provided. If you change your mind, you can adjust your preferences at any time using the manage cookies link in the footer of the Site.
6. Data Subject Rights
If you are in the European Economic Area (EEA) you have the following rights:
- Access. Subject to certain exceptions, you have the right to request a copy of the Personal Data processed about you, which will be provide to you in electronic form. You may be required to prove your identity before providing the requested information.
- Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended.
- Deletion. You have the right to request that your Personal Data is deleted, unless there is a legal requirement to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to request that processing of your Personal Data is restricted where:
- you believe such data to be inaccurate;
- such processing is unlawful; or
- there is no longer need to process such data for a particular purpose, but it is impossible to delete the data due to a legal or other obligation or because you do not want to delete it.
- Portability. You have the right to request that your Personal Data processed is transmitted to another data processor, where this is:
- personal information which you provided; and
- the Personal Data is processed on the basis of your consent or in order to perform obligations under contract to you (such as to provide legal services).
- Objection. Where the legal justification for the processing of Personal Data is based on legitimate interests, you have the right to object to such processing on grounds relating to your particular situation. The request will be abided by unless there are compelling legitimate grounds for the processing that override your interests and rights, or if there is a need to continue processing the data for the establishment, exercise, or defense of a legal claim.
- Withdrawing Consent. If you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from messages that you receive from us.
If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. You can access the list of local data protection authorities in EEA countries by clicking the link incorporated in this sentence.
7. Data Security
Organizational measures have been implemented to ensure the protection of Personal Data. Such measures include restricting access to Personal Data to service providers on a need-to-know basis.
Striving to ensure the security of systems, sites, operations, and information against unauthorized access, use, modification, and disclosure, it’s important to acknowledge that, given the inherent nature of the Internet as an open global communications vehicle and other risk factors, no absolute guarantee can be provided for the complete safety of any information during transmission or while stored on systems, making it susceptible to intrusion by others.
You also have an important role in protecting your Personal Data. You should not share any username, password, or other authentication data provided to you with anyone. It is recommended that you do not reuse passwords across more than one website or application. If you have any reason to believe that your username or password has been compromised, please contact support@meaningful-performance.com as soon as possible.
8. User Accounts
- The password must be created at the first login.
- It must must contain at least 12 characters.
- The password must include at least 3 of the following character types: lowercase letters (a to z), uppercase letters (A to Z), numbers (0 to 9), and special characters (e.g., !@#$%^&*()_+|>:”?<;).
- It is not allowed to use trivial, common, or default passwords.
- User passwords must not contain the corresponding username or any parts of it.
- Passwords must not be similar to the previous one by changing characters in a predictable numerical sequence.
- Passwords must be different from the last 5 passwords set.
- After a password change, it cannot be altered for the next 24 hours.
- Passwords must be changed at least every 180 days.
- The account must be locked after 5 failed login attempts for security reasons, for a timeframe of 10 minutes.
9. Cross-Border Data Transfers
Personal Data may be transferred to other jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country.
In the case of transfers from the European Economic Area (“EEA”) to the United States and other non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission and other appropriate solutions to address cross-border transfers, as required or permitted by Articles 46 and 49 of the General Data Protection Regulation. If necessary under such laws, you may request a copy of the suitable mechanisms we have in place by contacting us using the details provided below.
11. Other Issues
- What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Privacy Policy to use the Site or to interact offline, but certain functionality will not be available if you do not provide Personal Data. If you do not provide Personal Data, your request may be left without a response. - Is automated decision-making conducted without human intervention?
Automated decision-making, including profiling, does not occur without human intervention in a way that produces legal effects or significantly impacts you. - Does the site honor ‘Do Not Track’ (DNT) signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, there is no response to DNT signals at this time. - How long are Personal Data retained?
Personal Data is typically retained for as long as you accept communications, and such data will be securely deleted, in accordance with applicable law, upon request. For personal data collected and processed for other purposes, it is typically retained for as long as necessary to fulfill the purposes outlined in this Privacy Policy and as specified in applicable record retention policies and procedures. - How are employee and contractor privacy issues handled?
Personal Data about employees and contractors are outside the scope of this Privacy Policy. - How changes to this Privacy Policy are handled?
This Privacy Policy may be updated periodically to reflect changes in our services and privacy practices, or as required by law. The effective date is posted below, and you are encouraged to visit the site periodically to stay informed about privacy practices. The updated version of the Privacy Policy will be posted on the site, and you will be asked for consent to the changes if legally require
11. Contact Information
If you have questions or comments regarding this Privacy Policy or privacy practices, please contact:
Data processor: Daniil Klyuchnikov
Address: Wagengasse 2A, 65929 Frankfurt am Main, Germany
Phone: +49 152 22160900
Email: info@meaningful-performance.com