SERVICES PRIVACY

Last updated 1 April, 2023

LPI Digital is a subsidiary of Leadership Pipeline Institute. At LPI Digital (LPI) we are committed to protecting your personal information. This services privacy policy (“Services Policy”) outlines LPI’s privacy practices with respect to any information you provide to or is collected by LPI in connection with your use of our products and services. If you only visit our public website, this Services Policy does not apply to you.

When we use the term “Personal Information” in this Services Policy, we are referring to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, unique personal identifier, online identifier Internet Protocol address, and email address. Personal Information does not include publicly-available information and certain other information that is regulated by other applicable laws.

LPI owns the learning and learning analytics platform Learnalyze. If you are participating in a survey, learning journey or other activities via Learnalyze, you are called a “Participant” for the purposes of this Services Policy. Customers of LPI are referred to as “Customers” and authorized users of the Learnalyze software at each Customer company are referred to as “Users.”

We are providing different types of surveys such as

Learnalyze Participants

We collect the name and email address for all Participants. We have multiple different surveys related to our leadership and specialist development programs. You will be asked to provide responses to certain of these surveys.

We use the Personal Information we collect to provide a Leadership Performance index or Specialist Performance index to leaders and specialists and/or to enhance learning in our development programs. We keep this information for a reasonable length of time that allows us to provide the services to our Customer. However, your Personal Information is anonymized no later than 90 days following the end of our agreement with our Customer. Should you wish to anonymize your data before this, then please contact your employer (our Customer) or previous employer directly.

In addition to the Personal Information collected when you respond to a survey, we may also collect additional information if you voluntarily agree to answer optional research questions. In this case, the information requested may include the following: Customer-provided group designation, age, years of experience, ethnicity, gender, country of origin, education level, position level, company name, relationship to LPI Digital, title, occupation, and personal contact details to be included in further LPI Digital research. Such additional information is only collected with your express consent.

Customers and Users of the Learnalyze platform

We collect the following categories of Personal Information from Customers and Users:

Categories of Sources

When you visit our website, we collect Personal Information directly from you when you provide it to us and information that is automatically generated and collected. We also sometimes receive Personal Information from our Learnalyze Certified Partner network and other affiliate organizations, as well as third party service providers that provide Personal Information and non-personal information to us.

Our Business Purposes for Collecting Personal Information

• To provide the services to you

• To respond to requests and communications from you

• To improve our website and our services

• For targeting marketing campaigns

• To inform you about our products and services and to gather feedback from you on our website and services

• To understand how our services are accessed, used, and whether there are any potential security issues arising from such use

We use your Personal Information only in connection with performing the contract that we have entered into with you, your employer, or a third party, and in providing, managing and administering our Services.

LPI Digital may collect, store and use aggregated anonymous information from the administration of surveys and our other products and services in order to improve our business operations and our products. This information does not identify any individual. LPI Digital also uses log files and other generally available web tracking technologies in operating, maintaining, and improving our Learnalyze software platform and our website. This information does not contain any Personal Information and is not linked to any Personal Information that LPI Digital holds except when a Respondent voluntarily agrees to answer optional research questions.

Customer Collected Information

If you are a Customer, you may request and store other information from your Users and Respondents including job code, department code, occupation, status, language preference, or other freeform company-specific information configured by the Customer, if applicable. The Service is intended for business purposes only, and is not intended to collect or store any special categories of personal data or sensitive health or financial information. Please do not enter this type of information. LPI Digital does not make use of such information except in accordance with this Services Policy. If you voluntarily provide this company-specific information, you are consenting to our collection and use of this information as described in this Services Policy.

Customers receive Survey reports and associated reports processed by the Learnalyze software platform and then integrate these reports into their own Human Resources and personnel systems. LPI Digital does not own or control information contained in the Surveys or stored on the Learnalyze software platform by Customers. If you wish to access, amend, or delete any personal information connected with a Surveys or other Services that you may have taken, please contact the company who requested that you participate in the survey or other Services.

Third Parties We Share Personal Information With

LPI Digital maintains contracts with our Customers, distributors, and subcontractors requiring them to comply with the requirements of this Services Policy. These third parties must provide at least the same level of privacy protection as required under applicable law, including under European Union data protection laws.

LPI Digital does not sell or rent your Personal Information to any third party without your consent. We do not disclose any Personal Information to any other party except to fulfill the purposes for which the information was disclosed and as described in this Services Policy. To fulfill those purposes, LPI Digital discloses Personal Information as follows, to:

• You, your authorized representatives, legal agents, and other persons acting on your behalf or to whom you ask, instruct, or authorize us to disclose your Personal Information.

• Our employees, subcontractors, and contracted service providers who provide a service to or on behalf of us, such as analytics service providers, customer support, and website partners.

• Our auditors, consultants, accountants, attorneys and others providing professional advice to us.

• Our affiliates and business partners, including to our PI Certified Partners network (as defined above).

• Applicable governmental, regulatory, supervisory, law enforcement, tax or similar authorities or industry bodies.

• To third party software systems used by a Customer via a software integration, including but not limited to applicant tracking systems and other Human Resources information systems, if applicable.

• Any other person or entity we reasonably think is customary, necessary or advisable for the business purposes disclosed in our Services Policy or to whom we are obliged by applicable law or regulation to make the disclosure.

• Any other party where we have obtained your consent.

Permitted Disclosures

We may need to share your Personal Information for law enforcement or other legal purposes. This type of sharing may be necessary in connection with, but not limited to, a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter. In the event that we determine it is necessary to share your Personal Information, we shall limit such disclosure to only the information we determine to be reasonably necessary.

In the event of an acquisition, merger, sale, corporate restructuring, bankruptcy, or other similar event that involves LPI Digital, we may share Personal Information about you, including personal contact information. If such an event occurs, we will take reasonable steps to require that your Personal Information be handled in accordance with this Services Policy.

Free Trials and Services Demonstrations

If you are utilizing a free trial or participating in a demonstration of the Services, in addition to the uses outlined above, your Personal Information may be used by LPI Digital and/or its Learnalyze Certified Partners in connection with offering the Services to you and/or your organization for purchase. 

CA Residents

If you are a resident of California, the following shall also apply to you under the California Consumer Privacy Act of 2018 (“CCPA”).

Right to Know

You have the right to request that we disclose certain information to you about our collection of your Personal Information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of Personal Information we have collected about you;

• The categories of sources from which we have collected your Personal Information;

• Our business or commercial purpose(s) for collecting or selling your Personal Information;

• The categories of third parties with whom we have shared your Personal Information; and

• The specific pieces of Personal Information we have collected about you.

You have the right to request that we disclose certain information to you about our disclosures and sales of your Personal Information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of Personal Information we have collected from you;

• The categories of Personal Information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold; and

• The categories of Personal Information that we disclosed about you for a business purpose.

Right to Opt-Out

We do not sell your Personal Information now and have no plans to start, however, we are required to let you know that you have the right to opt-out of the sale of your Personal Information if we ever engage in such activity.

Right to Delete

You have the right at any time to request that we delete your Personal Information. However, in some cases we cannot delete all or some of your Personal Information as required or permitted by applicable laws.

Right to Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you.

Contact

To submit a request to exercise any of your rights provided in this notice, please email us via: support.learnalyze@LP-Institute.com. We will evaluate the request and take action where required to do so.

Depending on the nature of your request, we may have to verify your identity when you contact us. We may do this by asking you to confirm information that we already have about you.

We always aim to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof to us that they are authorized to act on your behalf, and we may also require your authorized agent to verify their own identity. To appoint an authorized agent, please contact us at support.learnalyze@LP-Institute.com.

Last modified 1 April, 2023