Effective Date: 12/19/2013
Business and related data that you submit in connection with your use of our Services is covered by this Policy. However, such data is the property of your business, and our use of it to provide services to you is addressed in the applicable Growth Strategy terms of service or agreement as well as this Policy.
You should read this Policy before you submit any personal information to us. By using our Services, you agree to the terms and conditions of this Policy.
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 use our Services, such as when you register, sign up for our newsletter, fill out one of our Assessments or subscribe to our propriety web-based suite of tools, the information that we may collect from you includes (but is not limited to) the following:
In General. We use the information we collect about you for the following purposes:
Utilization Information. We may share non-personally identifiable information with our members about how their employees use the Services (e.g., how many member employees use certain features, utilization trends).
Share Functionality. 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. Your name and email address are used to identify you to the recipient of your request. We do not use this information in any way other than to facilitate sharing functions as initiated by you.
We may use and disclose information that does not reveal your specific identity or does not directly relate to you for any purpose.
2. Information Sharing
We may provide your personal information to companies that provide services to us, such as offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us. When we engage service providers to process personal information on our behalf, these service providers are contractually required to implement reasonable security measures before they can receive any personal information from us.
We may also use and disclose your personal information:
3. User Access and Choice; Retention
If your personal information changes, or if you no longer desire our service, you may correct, update, amend or request that the personal information you have submitted to us be deleted by making the change in your account settings page, via the website on our Contact Us page, or by contacting us by telephone or postal mail at the contact information listed below. We will try 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, unless a longer retention period is required or permitted by law.
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 does not have a direct relationship with the individuals whose personal data it processes on behalf of such clients. Businesses that use our services may send invitations to take our assessments to their employees or others. If you would prefer not to receive such invitations, please inform the Growth Strategy client that has sent you the invitation. Similarly, to access, correct, amend, or delete the personal information collected by one of our clients, please direct your query to the Growth Strategy client with which you have directly interacted. If the client requests Growth Strategy to remove the data, we will try to 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
We use both session ID cookies and 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 Services, such as the web pages you visit, the links you click, and the searches you conduct for security purposes, to facilitate navigation, display information more effectively, to personalize your experience, to improve the Services, to understand how the Services are used. A persistent cookie remains on your hard drive for an extended period of time. Whenever you sign into our Services, 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 Services, but your ability to use some areas will be limited.
We may use Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.
Some of our service providers may employ a software technology called clear gifs (a.k.a. web beacons) that help us better manage content on our Services 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.
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.
The security of your personal information is important to us. When you enter sensitive information 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 within our organization. Unfortunately, no data transmission or storage system 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 the personal information we have collected from or about you. If you have any questions about security on our site, you can Contact Us.
Please note that effective security depends, in part, on your 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
You may be able to log in to our Services 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 social media profile page to share with others within your network
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any jurisdiction other than that of the United States.
7. Contact Us
If you have any questions or concerns, please contact us here, call us at 855-806-3760, or write to:
1735 Clarendon Boulevard
Arlington, Virginia 22209