PRIVACY POLICY

Leadership Counseling Services, LLC Privacy Policy

Leadership Counseling Services, LLC ("LCS", "we" or "us") knows that you care how your information is used and shared. We appreciate your trust that we will use your information carefully and sensibly. This Privacy Policy ("Privacy Policy") describes our policies with respect to your personal information that LCS collects through its website at www.inside8.com ("Website"), any personality assessment you take that is made available through the website (each, an “Assessment”), and any other tools, assessments, or services we make available to you (collectively, the “Services”).

This Privacy Policy should be read in conjunction with our Terms & Conditions and Data Assessment Policy, if applicable.  All terms not specifically defined herein shall have the same meaning as set forth in the Terms & Conditions or the Data Assessment Policy.  In the event of a conflict between any of the terms in this Privacy Policy and either the Terms & Conditions or Data Assessment Policy, this Privacy Policy shall prevail to the extent of such conflict.

By using and visiting our Services you agree to this Privacy Policy, and you hereby consent to our collection, use, disclosure, transfer, and storage of information in accordance with this Privacy Policy.

INTRODUCTION

LCS respects the privacy and confidentiality of personal information of visitors to our Website or users of the Services. LCS treats personal data in the strictest confidence and operates a strict privacy policy. This Privacy Policy describes the information we collect when you visit or use our Services, how we use that information, and under what circumstances we share or disclose it. LCS will only process personal data as set out in this Privacy Policy. This Privacy Policy also gives you more information about how you can manage the personal information you provide to us. 

INFORMATION WE COLLECT

Automatically Collected Device Information

When you visit or use the Services, you can explore pages of the Website without providing any information about yourself.  However, when you visit or use the Services, LCS automatically receives and records information from your device and use of the Services, including information about your web browser, IP address, cookie information, unique device identifiers, software and hardware attributes (including the type of operating system you use), mobile network information, what websites or search terms referred you to the Website, date and time of your request and referral to the Website, pages or products that you view, and information about how you interact with the Website and Services. We refer to this information as “Device Information.”

We collect Device Information using the following technologies:

1. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. A cookie may enable the website owner to track how a visitor navigates through its website and the areas in which they show interest. This is similar to a traffic report: it tracks trends and behaviors, but does not identify individuals. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
2. “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
3. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Website.

We also use two third party services, Google Analytics and Piwik, to collect certain Device Information.

LCS websites do not currently allow any third party cookies. You can choose to disable LCS cookies. Allowing cookies will provide a user with the best possible experience on the LCS Website. If you choose to disable cookies, certain sections of the Website will not work properly. If you use different devices to view and access the LCS Website (e.g. your computer, smartphone, tablet, etc.) you will need to ensure that the browser on each device is adjusted to suit your cookie preferences.

Information You Provide

In addition to Device Information, there are instances in which we either collect or require you to disclose “Personal Information.”  Personal Information is information that could personally identify you, for example, your name, address, phone number, e-mail address, birth year, and requested payment information.

Although you may browse the Website or Services without providing Personal Information, in the following instances, we need you to actively submit Personal Information: 

• In order to purchase the Primal Personality Assessment® (the “Assessment”) or sign up for our mailing list, you must create an account for the Website.  When you create your account, you must provide your email address, username, and password to us.
• When you purchase or attempt to purchase the Assessment, or otherwise wish to complete an assessment or consumer survey on our Website, you must provide us with your name, year of birth, gender, email address, country, and zip code/post code. We use this information to process your assessment data.
• When you complete the Assessment (or any other assessment made available via the Services), we collect the information set forth above as well as your specific responses (which may include additional demographic details).  We use this information to score the Assessments and generate detailed reports and other data, including the assessment and related findings (i.e. personality group), for your own review as well as our internal business purposes (such as improving the Assessment itself).
• When you contact us with a question or concern (either via email or phone), in order to better serve your needs, a representative may ask you to provide certain personal information like your name, mailing address, telephone number, mobile number, and/or email address. We use this information to answer your question or address your concern.
• When you purchase merchandise, you may be asked to provide your name, address, phone number, email address, and billing and shipping information.  We use this information to process and fulfill orders (either directly or with our third party vendors).

Information We Receive or Collect from Third Parties

We may receive or collect information about you from third parties and store it on our servers with other information we may have already received or collected from you, such as publicly available information you provided to third party platforms.  LCS is not responsible for, and will assume no liability, if a business partner or other entity whom you have authorized collects, uses or shares any information about you in violation of its own privacy policy or any applicable laws, rules, or regulations.

OUR USE OF YOUR INFORMATION 

Device Information

We use your Device Information to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Website.  We do this, for example, to generate statistics on website traffic and website activity, customize the advertising and content visitors see, fulfill your requests for products and services, and conduct research and assess the performance of any marketing or advertising campaigns.

Personal Information

We use and store the Personal Information you provide us for the reasons set forth above.  More generally, we use this information in order to fulfill orders (including arranging for shipping, facilitating payment to our third party providers, and providing you with invoices and/or order confirmations), manage customer complaints, and process requests to access testing data.    

We also use the Personal Information you provide us in connection with an Assessment to process the assessment data as well as conduct comparative analytics.  We may strip your assessment data of any personally identifiable information and combine it with other users for research and evaluation purposes.  We do not share your Personal Information provided in connection with an Assessment to third parties without your explicit prior consent.

In addition to the foregoing, we may also use your Personal Information for legitimate business purposes, including to:

• Communicate with you or send you promotional items (as described in our “Communications” section of this Policy).
• Operate, evaluate and improve our business, our Website, and other products and services we offer.
• Tailor the content we display in our communications with you.
• Administer surveys and other market research.
• Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests).
• Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our Website), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.

INFORMATION SHARING AND DISCLOSURE

We do not rent or sell your Personal Information without your permission.  However, we may share your Personal Information for the purposes described herein:

• We may share your Personal Information whenever you consent to us doing so.  For instance, we may seek to feature you on our Website (with your specific consent).   
• We do not directly collect or store payment information (such as your name, credit card information, bank account information, or billing details) (collectively, “Payment Information”).  However, we use Coggins Promotional Advertising, Inc. (“Coggins”) to power our online merchandise store.  Coggins assists with order processing and fulfillment.  You may be required to share with them your name, email address, phone number, and shipping address when you’re placing an order.  Coggins also will collect your Payment Information.  For more information on how Coggins uses your Personal Information (which includes Payment Information), see:  http://shop.inside8.com/Content/Privacy.htm.
• We use PayPal, Inc. to process credit card transactions for the Assessment.  You share your Payment Information directly with them.  For more information on how PayPal uses your Personal Information, see:  https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
• We share your name, username, and email address with MailChimp to assist with our email and marketing communications.  For more information on how MailChimp uses your Personal Information, see:  https://mailchimp.com/legal/privacy/.
• We share your Personal Information and Device Information (including assessment data or findings) with our web development team, Jackson Blason Hunt Limited, in order to manage the Website and improve our Services to you.  They do not, however, have access to your Payment Information.  This information is shared on a confidential basis and our developers do not have any independent right to use or share this information.
• We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
• We may disclose Personal Information you provide via the Website in connection with the sale, assignment, or other transfer of the business or a portion of the business of the Website, including a corporate merger, consolidation, restructuring, sale of assets, or other corporate change of our company.

Any third parties to whom we may disclose Personal Information (identified herein) may have their own privacy policies which describe how they use and disclose your Personal Information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

AGGREGATION AND/OR ANONYMIZATION

In addition to the uses and sharing of information set forth above, we may also aggregate and/or de-identify any Personal Information or Device Information (including assessment data) that we collect, such that the information no longer identifies any specific individual. When we do this, we may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.  We may also share this aggregated and anonymized data with third parties for marketing purposes, and you may see advertisements from companies that align with your interests.

COMMUNICATIONS

In General

When you register for our Services, you may elect to receive promotional, marketing, or other similar emails or notifications that we think you will find useful and interesting, including newsletters, new blog posts, eBooks and other updated content, as well as notifications about our products and services (“Marketing Communications”).  If you voluntarily opt-in to receive such Marketing Communications, you consent to receive these communications from us. 

Opt-Out

Regardless of where you live, you may choose to opt out of receiving Marketing Communications any time by following the instructions provided in any Marketing Communication you receive, by contacting us at connect@inside8.com, or by writing us at Attn: Customer Service Dept., P.O. Box 617691, Chicago, Illinois 60661. 

Please note that even if you opt-out of receiving Marketing Communications, you may still receive necessary business-related communications, such as transactional emails.

SECURITY OF INFORMATION

We take all reasonable action to ensure the safety of your Personal Information in agreement with this Privacy Policy. The Website has industry standard security measures in place to protect the loss, misuse, and alteration of the information under our control. The information we are provided will be stored on secure servers. Transaction data is encrypted for your safety.

You should understand data via online transmission is not completely secure. We cannot guarantee full protection and security of data, only that we take all reasonable action to protect information sent to us electronically. Transmission of any data by you is at your own risk. Where applicable you may be given access to sections of our Website that require a password. You are responsible for the password’s safety and confidentiality.

THIRD PARTY LINKS

Third party links may be discovered on our Website. These third party links have their own privacy policy, which you agree to when you click on the link. We are not responsible nor do we accept responsibility for third party links. Our liability covers us only on our Service, and thus we do not accept liability for third party links, their privacy practices, or the content of such web sites, as we have no control over them.

DO NOT TRACK

Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS TO THE PERSONAL INFORMATION YOU PROVIDE

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. You also have the right, where technically feasible, to have Personal Information that you provided based solely on consent to be transferred to you. If you would like to exercise these rights (which you may do at any time) or inquire as to any additional rights you may have under applicable law, please contact us through the contact information below.  We will respond to any request as promptly as possible.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for instance to fulfill an order), based on your express consent herein, or otherwise to pursue our legitimate business interests listed above. 

Finally, please note that your Personal Information will be transferred outside of Europe, including to the United States, where it is stored.  When we transfer your information to the U.S., we will protect it as described in this Privacy Policy.  We also are working to and have worked to incorporate appropriate safeguards such as standard contractual clauses with any third party processors identified herein.  We further will make best efforts to protect information from EU residents in accordance with applicable law.   

DATA RETENTION

When you purchase the Assessment through our Website or otherwise use our Services, we will maintain your Personal Information for our records unless and until you ask us to delete this information. We may also retain any anonymized and/or stripped data that is not personally identifiable for so long as we deem necessary for our research, analysis, and business planning purposes.  

MINORS

The Services are not intended for individuals under the age of 18, and we do not knowingly collect any personal information from users under the age of 18 years. 

YOUR CONSENT AND FEEDBACK

By using our Services, you consent to the processing and use of your Personal Information in accordance with this Privacy Policy. Our goal is to protect your privacy. To help us improve our Privacy Policy, please give your feedback via email to connect@inside8.com.

PROTECTING YOUR INFORMATION

You have several options when deciding how you can best protect your Information.  One option is simply not to volunteer it.  This approach would allow you to still visit our Services, although it may prevent you, for example, from placing orders or taking the Assessment.  The Federal Trade Commission’s website, www.ftc.gov, also offers useful information about how to protect personally identifiable information provided to a website. 

SUSPECTED VIOLATIONS

If at any time you believe we have not adhered to the policies and principles set forth in this Privacy Policy, please notify us using the contact information provided below.  We will make all commercially reasonable efforts to promptly respond to your concerns. 

CHANGES IN THIS POLICY

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.  We suggest that you review the current Policy at the start of each visit to our Website.  We will also notify you of material changes to this Policy by posting them to the Website or via email. Unless we clearly express otherwise, we will use Personal Information in accordance with the Policy then in effect.  YOU ARE HEREBY ADVISED THAT YOUR CONTINUED USE OF OUR WEBSITE CONSTITUTES YOUR ACCEPTANCE OF ANY AMENDMENTS TO AND THE MOST RECENT VERSION OF THIS POLICY.

 

CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that LCS has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting LCS by sending an e-mail to connect@inside8.com, or by writing us at Attn: Customer Service Dept., P.O. Box 617691, Chicago, Illinois 60661.

CONTACTING US

Please feel free to contact us with queries, requests, or comments you may have about our Privacy Policy. We welcome any communication via our contact form, by sending us an email at connect@inside8.com, or by writing us at Attn: Customer Service Dept., P.O. Box 617691, Chicago, Illinois 60661.

Effective Date: August 14, 2018.