Effective Date: May 24, 2018
1. Important information and who we are.
Purpose of this privacy notice
1. The right to have IPL permanently delete any of your personal data.
2. The right to review any personal data that we’ve collected from you.
3. The right to voluntarily and affirmatively “opt-in” to any newsletters, emails, or marketing materials sent to you by IPL.
4. The right to receive a copy of your personal data.
5. The right to have control and access over your personal data.
6. The right to have your personal data protected, transferred and stored in compliance with GDPR’s data protection requirements.
7. The right to have your personal data automatically destroyed after it is no longer being actively used by IPL.
8. The right to only receive communications from IPL pursuant to a “Lawful Basis” under GDPR. The two most common Lawful Bases pursuant to which you may receive IPL communications are: (i) that you requested, subscribed or affirmatively consented to the receipt of the communications, and (ii) the communications are necessary for IPL’s “legitimate interests” that are not overridden by your interests or fundamental rights and freedoms that require protection of personal data.
9. The right to have IPL appoint a Data Protection Officer (“DPO”) to manage IPL’s compliance with GDPR and to respond within 72 hours to any inquiries, complaints, or requests that you make regarding your personal data. At any time, you may contact our DPO at email@example.com.
10. As required by GDPR, our authorized subscribers have affirmatively and voluntarily “opted in” pursuant to GDPR requirements to receive newsletters, emails, and marketing communications from IPL. If you believe that you did not opt in to receive these communications from IPL, please contact our DPO as soon as possible at firstname.lastname@example.org.
We will arrange for you to either affirmatively opt in or not receive any further communications from us. Additionally, all of our newsletters, emails to subscribers, and other related communications contain an opt-out (unsubscribe) button at the bottom. At any time, you may unsubscribe from all IPL communications by clicking on the button.
We take your personal data and privacy seriously. If you have any questions regarding your rights, your personal data, or IPL’s obligations, please contact IPL’s Data Protection Officer at email@example.com.
Your rights under GDPR are further described below in Section 11. Some of your rights described in this policy may be subject to certain rights of IPL such as legal, accounting, and archiving requirements.
For more details regarding your rights and IPL’s obligations under GDPR, this Wikipedia article offers a good summary: https://en.wikipedia.org/wiki/General_Data_Protection_Regulation.
Detailed information regarding GDPR and related legislation and directives, may be viewed at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.
Institute for Personal Leadership LLC
Attention: Legal Department
170 West 81st Street, Ste. 8D
New York NY 10024
The Mentora® App
2. The Information We Collect About You.
Information We Collect Automatically
When you visit our website or app, our servers automatically collect certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:
Information You Provide
In order to access or use certain portions of IPL’s website, Mentora® app, or other IPL portals, or otherwise conduct business with us, you may be prompted to provide certain personal data to us in the following ways:
Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to resolve any inquiries or complaints. With respect to the Mentora app, your personal data may include videos that you shoot of yourself, and information that you supply, and upload to the Mentora servers as part of how the app is designed to be used.
Personal data may also be required to enter into an agreement with you or to perform an agreement with you (such as to provide services at your request), and failure to provide any information may result in our inability to provide requested services or products.
Mentora - Videos and information you submit.
When you use our Mentora app, you record your video responses to role-play challenges and provide other information. The videos you record of yourself and some of the information you provide is considered personal data. Your videos and other information are uploaded to secure third-party servers in the United States maintained by Kaltura and Microsoft Azure in accordance with the highest security standards. Your videos and information are then viewed by your peers and supervisors to give feedback and in turn, you view videos and information of your peers and give them feedback. We will use your video responses and information within your own classroom or group and for our internal research purposes only. If we want to use your videos in any other way, we will obtain your written permission before doing so.
IPL relies on trustworthy third-party vendors located in the United States to provide much of the data storage and usage requirements for Mentora. User-provided videos, including related content, are stored with Kaltura Inc. http://corp.kaltura.com/. Information is transmitted to Kaltura over HTTPS, an encrypted protocol. The information stored within Kaltura is stored behind credentials and can be delivered to customers over HTTPS as well, securing encryption on outgoing traffic. IPL is working with Kaltura to meet the highest standards of safely storing and transmitting video and other data using state-of-the-art technology and encryption.
All Mentora personal data, other than videos stored at Kaltura, is stored in Microsoft Azure https://azure.microsoft.com/en-us. Microsoft states that it has made an industry-leading commitment to the protection and privacy of its clients’ data. Microsoft was the first cloud provider recognized by the European Union’s data protection authorities for its commitment to rigorous EU privacy laws. Microsoft was also the first major cloud provider to adopt the new international cloud privacy standard, ISO 27018.
The personal data you submit to us through our Contact Us page and email sign-ups on our website is stored and processed at www.mailchimp.com in compliance with GDPR.
IPL may change what third-party data processors it uses. IPL will perform due diligence on any new processors that it uses, and make sure that they meet the highest quality of privacy and security standards, including GDPR.
Information From Other Sources
We may receive information about you if you use any of the other websites and portals we operate, any other services we provide, seminars or classes we teach, or from our business partners or data processors instructed to collect information on our behalf.
3. Use of Personal Data.
The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or agreement.
All processing and use of your personal data is justified by a "condition" for processing. In the majority of cases, processing will be justified on the basis that:
We use the personal data we collect to conduct and develop our business with you and with others, as more fully described below:
IPL will not sell or rent your personal data to third parties.
4. Disclosure of Personal Data.
IPL will share personal data with its appointed third-party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving our products, services, the website, or our Mentora app. IPL may share your personal data with these affiliates and third parties to perform services that the third parties have been engaged by IPL to perform on IPL's behalf, subject to appropriate contractual restrictions and security measures, or if we believe it is reasonably necessary to prevent harm or loss, or if we believe that the disclosure will further an investigation of suspected or actual illegal activities.
We are also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose personal information that we handle in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If your personal data is transferred outside the EU to IPL or its third-party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by assuring that IPL and its service providers have entered into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. For transfers of personal data among IPL and its service providers we will make sure that the service providers have in place European Commission approved Standard Contractual Clauses. The list of all the countries to which your personal data is transferred is set forth here: United States and India. Be advised that upon information and belief, neither of these countries has currently received a decision of the European Commission determining that its laws provide adequate protection to personal data. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU by contacting firstname.lastname@example.org.
IPL reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.
5. EU-U.S. and Swiss-U.S. Privacy Shield
IPL, although not a member, complies with the data protection principles of the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries and Switzerland. IPL adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, and access. To learn more about the Privacy Shield principles, please visit https://www.privacyshield.gov/.
IPL conducts in-house verifications to ensure that its attestations and assertions with regard to its treatment of personal data are accurate and that the company has appropriately implemented these practices.
The website is not for use by children under the age of 16 years and IPL does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify IPL and IPL will delete all such personal data.
7. Marketing emails.
Where lawful to do so, and subject to your consent where required, we may communicate with you by email to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the 'unsubscribe' link provided in our emails, or otherwise contact us directly and we will stop sending you communications.
IPL aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and IPL utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by IPL are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.
9. Retention of Your Personal Data.
We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us.
However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.
10. External Links.
The website may contain links to third party sites. Since IPL does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third-party sites. This policy applies solely to personal data collected by our website or Mentora app, or in the course of our business activities.
11. Your Rights.
Under applicable law, you may have the following rights:
For further information regarding your data privacy rights under GDPR, please see the following link: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
Your California Privacy Rights.
For California residents only. We may disclose your personal information to our affiliates or other related third parties for their use in marketing to you. Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please send an email to email@example.com to request a copy of our disclosure pursuant to California law.
12. Dispute Resolution and Other Legal Matters
You may also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law and IPL is subject to the jurisdiction of such supervisory authority.
Further, in accordance with the Privacy Shield Principles, IPL commits to promptly resolve complaints about privacy and our collection or use of personal information. Individuals with questions or concerns about the use of their personal data should contact us at: firstname.lastname@example.org and identify the company or other organization with whom they are affiliated or for whom their data was collected, if collection was for an IPL customer.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, we will have the matter submitted to our US-based third-party dispute resolution provider (free of charge).
13. Changes to this Policy
Any changes or updates we may make to this policy will be posted on this page. If we have your contact details on file we will endeavor to notify you in advance of any changes to this policy that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this policy.