Effective Date: 12/13/2012

The Growth Strategy Company LLC (Henceforward “Growth Strategy”, “We”, “Us”), takes your privacy very seriously. This Privacy Policy covers our collection, use and disclosure of information we collect through our website http://www.growthstrategy.com/, our GrowthThinker™ Index and Growth Posture Index® services (Henceforward “Services”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. The use of information collected through our Services shall be limited to the purpose of providing the service for which our customers have engaged Growth Strategy.

You should read this Policy before you submit any personal information to us. By using our services or registering your interest in us online, you consent to the collection and use of your personal information as outlined in this Policy. If you do not agree with the content of this Policy, you should refrain from using our Sites.

Growth Strategy has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program covers only information that is collected through this Web site, http://www.growthstrategy.com/ and the Growth Strategy Services.

TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please Contact Us. If you are not satisfied with our response you can contact TRUSTe here.

U.S. – E.U. and U.S. – Swiss Safe Harbor

The Growth Strategy Co. complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. The Growth Strategy Co. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view The Growth Strategy Co. certification, please visit http://www.export.gov/safeharbor/.

1. INFORMATION COLLECTION AND USE

When you register for our services, sign up for our newsletter or fill out one of our Assessments, the information that we may collect from you includes (but is not limited to) the following:

• Contact Information such as name, email address, mailing address, phone number
• Unique Identifiers such as user name and password
• Information about your business such as company name, address, company size, business type

 

In General. We use the information we collect about you for the following purposes:

• for the purposes for which you provided the information;
• to customize the content you see, including the display of targeted content;
• to send you information about our offerings that you have requested from us;
• to administer your membership in any of our offerings and facilitate your access to and provide you with resources, decision-support tools, and other materials available to you;
• to attribute content that you make available through the Sites;
• to respond to inquiries that you submit to us via the online “contact us” feature and determine which offerings are appropriate for your needs;
• to enforce the legal terms that govern your use of the Sites;
• to enhance our offerings based on your feedback;
• to ensure the technical functioning of the Sites;
• to communicate with you about exclusive opportunities offered by TGSCO and its subsidiaries, partners, and affiliates, including information about other offerings in which you may be interested;
• to engage in research and analysis in order to maintain, protect and improve our offerings and develop new offerings; and
• to generate anonymous and/or aggregated reporting and research outputs.

 

Utilization information. We may share non-personally identifiable information with our Members about how their employees use the Sites and the resources available to them through the Sites (e.g., how many Member employees used certain features of the Sites, utilization trends, which features were most popular with the employees of the Member organization).

You may choose to use the “share” functionality on our website or in some of our services to send information from Growth Strategy. In order to fulfill this request, we will ask you for the names and email addresses for you and the individual that you wish to share with. We do not retain this data after the email is sent.

2. INFORMATION SHARING

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties.

Service Providers

We may however provide your personal information to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal information only as necessaryto provide these services to us. When we engage service providers to process personal information on our behalf, these service providers are required to implement adequate technological and organizational privacy and security measures before they can receive any personal information from us.

Legal Disclaimer

We may also disclose your personal information:

• as required by law, such as to comply with a subpoena, or similar legal process
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
• if Growth Strategy is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
• for legitimate business purposes connected with the provision of goods, services, and benefits for customers of Growth Strategy. Where information is shared with a third party for a legitimate business purpose, we will seek assurances from that third party that the personal information will be processed for legitimate reasons and appropriately protected.
• to any other third party with your prior consent to do so.

 

3. USER ACCESS AND CHOICE

If your personally information changes, or if you no longer desire our service, you may correct, update, amend or request it be deleted/removed by making the change in your account settings page, via the website on our Contact Uspage, or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active, as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Opt-out Preferences

If you wish to subscribe to our newsletter, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can Contact Us.

Access and Choice regarding Data Controlled by our Clients:
Growth Strategy collects information under the direction of its business clients, and has limited direct relationship with the individuals whose personal data it processes. Businesses that register for our Service may send invitations to take one of our Assessments to various employees or other relevant parties. If you are invited to take an Assessment but choose to opt-out and would no longer like to be contacted, please inform the Growth Strategy client that you interact with directly.

An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to the Growth Strategy client they interact with directly (the data controller). If the client requests Growth Strategy to remove the data, we will respond to their request within 30 days.

Growth Strategy will retain personal data we process on behalf of our clients for as long as needed to provide services to our client and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

4. TRACKING TECHNOLOGIES / COOKIES

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use do not use cookies on this site. We do/do not link the information we store in cookies to any personally identifiable information you submit while on our site.
We use [both] session ID cookies [and/or] persistent cookies. A session ID cookie expires when you close your browser. Through the use of a cookie, we may automatically collect information about your online activity on our Sites, such as the web pages you visit, the links you click, and the searches you conduct. A persistent cookie remains on your hard drive for an extended period of time. Whenever you sign into our Sites, we will record your user ID in a cookie file on your computer. If applicable, we may also record your password in this cookie file, if you checked the box entitled “Save this password for automatic sign-in.” You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.

Web Beacons / Gifs

Some of our service providers my employ a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Analytics / Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

3rd Party Tracking

The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as Twitter, or Google) on the site is not covered by our privacy policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies. We do not tie the information gathered to our Customers’ or Users’ personally identifiable information.

5. SECURITY

The security of both our clients’ and general assessment takers’ personal information is important to us. When you enter sensitive information (such as log-in credentials) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We have implemented reasonable technical and organizational security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure, and we assume no liability for any damage suffered by you caused by the interception, alteration, or misuse of information during transmission.

We make reasonable efforts to restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our offerings. We subject our third-party agents to contractual controls to ensure that they apply suitable protections to any personal information they access or receive from us. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can Contact Us.

Please note that the effective security with respect to our Sites depends, in part, on you ensuring that any IDs and passwords that you have been issued by us are kept confidential and secure and that you adhere to the restrictions on password and ID-sharing set forth in our Terms of Service.

6. ADDITIONAL INFORMATION

Links to 3rd Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of Growth Strategy. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single Sign-On

You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

Changes To This Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any additional questions or concerns, please contact us Here, or:

Call 855-806-3760

GrowthSpace Arlington
1735 Clarendon Boulevard
Arlington, Virginia 22209