Privacy Policy

1) Introduction

The Circle of Growth (“CoG”, “we”, “us”, or “our”) provides leadership assessments, learning experiences, analytics dashboards, and advisory services. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit our sites, complete surveys or assessments, or interact with our products and services.

2) Information We Collect

A. Information you provide

• Contact & Profile: name, email, role/title, company/organization, department, location, and team/organization codes.
• Assessment & Survey Responses: ratings, selections, free-text responses, and related context you submit.
• Support/Intake: messages and details shared when requesting help or scheduling sessions.

B. Information collected automatically

• Device/Usage: IP address, browser, device type, timestamps, pages viewed, UTM parameters, and referral source.
• Cookies & Similar Tech: used for session continuity, preferences, analytics, and performance.

C. Information from partners

• Payment, communications, and analytics providers (e.g., email platforms, CRM, analytics, hosting).
• When authorized by your organization, limited HRIS or roster metadata (e.g., team/manager mapping) to group results.

3) How We Use Information

• Quantitative insights: transform survey data into leadership & culture analytics and dashboards (e.g., via Microsoft Power BI).
• Personalized guidance: generate recommendations, training paths, and reports for you and your organization.
• Research & benchmarking: build de-identified aggregates to improve instruments and compare trends over time.
• Operations: deliver services, process scheduling and support requests, communicate updates, and improve our sites.
• Security & compliance: detect abuse, prevent fraud, and comply with legal obligations.

4) Legal Bases (EEA/UK only)

Where applicable, we rely on one or more of the following: consent (e.g., optional surveys), contract (to provide requested services), and legitimate interests (service improvement, security, de-identified analytics), balanced against your rights.

5) How We Share Information

We do not sell or rent personal information. We may share as follows:

• Service Providers (processors): secure hosts, analytics (e.g., Microsoft Power BI), email and CRM tools, form and integration platforms, and payment processors—solely to operate our services.
• Your Organization: when your assessment is part of an employer-sponsored program, results may be shared in aggregated or role-appropriate formats per the engagement scope.
• Legal & Safety: to comply with law, enforce agreements, or protect rights, security, or safety.
• Business changes: during mergers, acquisitions, or reorganization, subject to continued protections.

6) Data Minimization, De-Identification & Retention

• We minimize direct identifiers in analytics and favor aggregated/de-identified reporting whenever possible.
• Raw survey responses: typically retained up to 24 months from collection (or as required by contract/law).
• Account/contact data: retained while your account/engagement is active and up to 36 months after inactivity.
• Aggregated trends & benchmarks: may be retained without personal identifiers to improve the model over time.

7) Cookies & Tracking

We use necessary cookies for core functionality and optional analytics to improve performance. You can manage cookies via your browser settings or any cookie banner we provide. Disabling some cookies may limit features.

8) Your Rights & Choices

• Access/Portability: request a copy of the personal data we hold about you.
• Correction: ask us to correct inaccurate or incomplete data.
• Deletion: request deletion where legally permissible.
• Objection/Restriction: object to or restrict certain processing.
• Marketing: opt out of non-essential emails at any time using unsubscribe links.

To exercise rights, contact us using the details below. We may verify your identity before fulfilling requests.

9) Security

• Encryption in transit (TLS) and, where supported by providers, encryption at rest.
• Least-privilege access, role-based controls, and audit logging for administrative actions.
• Vendor due diligence and periodic reviews of our security posture.

Important: The Circle of Growth is not a medical, financial, or legal service and does not process protected health information (PHI). Do not submit sensitive medical data through our surveys.

10) International Data Transfers

Your information may be processed in the United States and other countries where our vendors operate. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) with our processors.

11) Children’s Privacy

Our services are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child provided data, contact us and we will take appropriate action.

12) Automated Decision-Making

We use analytics to generate insights; we do not make decisions that have legal or similarly significant effects based solely on automated processing.

13) Third-Party Links

Our sites may link to third-party websites. Their privacy practices are governed by their own policies; review them carefully.

14) Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date shows the latest revision. Material changes will be communicated by posting an updated policy and, where appropriate, additional notice.