This Privacy Policy is designed to inform you about the practices regarding the collection, use, and disclosure of information about you throughout your participation in assessments provided by Kaiser Leadership Solutions, LLC (KLS). To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used.
KLS may revise the terms at any time by updating this posting. You should review this page from time to time because the policy is binding. Certain provisions of these terms may be superseded by expressly designated legal terms located on particular pages at this site.
Information Collection
This notice applies to all information collected or submitted on the assessment survey sites for the Leadership Versatility Index®, Pulse Check®, and Progress Report®. KLS collects only as much personal information as we need for specific, identified purposes, and we will not use it for other purposes without obtaining your consent.
We use security techniques, including encryption and secure servers, to protect against unauthorized access to transmitted information used for assessment and research purposes. KLS does not store, use or share your information for any other purpose.
Internal Policies & Procedures
KLS collects only the information necessary to perform the assessment sought by its clients, who are generally employers seeking assessments of its leadership personnel. For any of the categories of data subjects, KLS might collect, store, and process the following categories of personal data:
- name
- username
- password
- records regarding to consents and preferences (such as consent to use the platform)
- gender
- position
- leadership experience
- time of employment in current position
- identity of employer
- assessments and characterizations of self (for individuals to be rated) or of others (for raters or any other data subjects)
- reports including the previously mentioned personal data
Use of Information
We use the information you provide about yourself for assessment and research purposes, as instructed by our clients, who are generally employers seeking to perform assessments of their personnel. KLS keeps your personal information for as long as required to fulfill the purposes for which it was collected, or as permitted by law.
KLS discloses the information you provide about yourself to the following entities for the purposes noted immediately above:
- Performance Programs Inc.
- Amazon Web Services
- Box
- Qualtrics (Survey Platform)
- SendGrid
- Network Solutions
- Microsoft Corporation
- Intuit
- Salesforce
- Avankia
- Mailchimp
- Hogan
- KLS Customers
- Distributors of our services and products
Some of these third parties may be located outside of the United States. However, before transferring your personal data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your personal data that we do. We remain liable for the protection of your personal data within the scope of our Data Privacy Framework certification that we transfer to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.
Other Disclosure of Your Personal Data
We may disclose your personal data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your personal data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. If we have to disclose your personal data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your personal data.
Information Security
We are very much aware of Internet users’ concerns about security. KLS takes technical, contractual, administrative and physical steps to protect against unauthorized access to and disclosure of individually identifiable information. These steps can include firewalls, secure socket layers, password verification, etc. You can determine when you are in a secure environment by locating the key (Netscape browsers) or lock (Microsoft browsers) symbol at the bottom of the browser page. When the key or lock is complete, the information provided by you is encrypted, restricting access by anyone else. If your browser does not support secure transactions, there is a chance that others may view any information that you send. You can check your browser’s help button to learn more about secure transaction support.
Children’s Privacy
The assessment is not intended for persons under the age of 18. Therefore, we do not knowingly collect personal information directly from such persons. We encourage parents to talk to their children about their use of the Internet and the information that they disclose.
External Links
KLS is not responsible for the privacy policies of web sites to which the KLS web site may link or for those of any downstream linkages.
Use of Cookies
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and to provide necessary assessment features such as language selection.
Access & Review
If we process your personal data, you may have the right to request access to (or to update, correct, or delete) such personal data. If we have received your personal data in reliance on the EU-U.S. DPF or UK Extension to the EU-U.S. DPF, you may also have the right to opt out of having your personal data shared with third parties and to revoke your consent to our sharing your personal data with third parties. You may also have the right to opt out if your personal data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you subsequently authorized. To submit these requests or raise any other questions, please contact us by using the information in the “Contact” section below.
Data Privacy Framework
KLS complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. KLS has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Dispute Resolution
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, KLS commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact KLS by using the information in the “Contact” section below.
If a privacy complaint or dispute relating to personal data received by KLS in reliance on the Data Privacy Framework (or any of its predecessors) cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/.
European Economic Area Supervisory Authority Oversight
If you are a data subject whose personal data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Economic Area Member States. If you are in the United Kingdom or Gibraltar, your complaint would be lodged with the Information Commissioner’s Office or the Gibraltar Regulatory Authority, respectively.
Additionally, if your dispute or complaint cannot be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you under the Data Privacy Framework’s “Recourse, Enforcement and Liability Principle” and Annex I of the Data Privacy Framework.
U.S. Regulatory Oversight
KLS’s compliance with the EU-U.S. DPF Principles is subject to the investigatory and enforcement powers of the United States Federal Trade Commission
Contact
Should you have other questions or concerns about the Informed Consent or privacy policies, please call us at 1-336-217-2740 or send us an email at info@kaiserleadership.com.