Privacy Policy
Last Updated: October 2024
The Leadership Consortium (“TLC,” the “Company,” “our,” “we,” or “us,”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (the “Policy”). We take your privacy very seriously and want you to feel secure when visiting or using the TLC programs or services via our platforms (collectively, the “Services”). In order to provide you with relevant information, respond to your requests, and increase the benefits you receive from the Services, we sometimes request that you provide us with information about yourself. By describing who we are, how and why we collect, store, use, protect and share your personal information, this Policy explains our practice of doing so. It also describes your rights in relation to your personal information.
This Policy applies to and describes the types of information we may collect from you or that you may provide to us when you visit and use the Services.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing, interacting with and/or using the Services, you agree to all of the terms in this Policy. If you do not agree with our policies and practices, your choice is to not use the Services. This Policy may be changed or modified from time to time without prior notice. Any modifications will be effective immediately. You can determine when the Policy was last revised by referring to the “Last Updated” legend at the top of this page. Your continued use of the Services after we make any such changes is deemed to be acceptance of those changes. Please regularly check the Policy for updates.
What Personal Data Do We Collect?
Personal Data
We may collect and transmit personally information that you voluntarily provide to us through the Services. Personally information that we collect and transmit may include, but will not be limited to: first and last name, company name, job title, e-mail address, location information, program selection, membership registration information, membership username and password, information contained in any e-mail or other communication you send to us, information you give to us in any other way and any other identifier that permits us to identify or contact you (“Personal Data”).
This information may be collected through various portions of the Services. Some of the ways in which we may collect Personal Data from you include, but are not limited to, our:
Email
Website Collection
Information provided by your employer
Information you provide through interactions with our Services or with third parties we use to provide you Services
Information provided by you when registering for our membership Service.
Through written transcripts or recordings of certain Services. TLC reserves the right to collect and maintain transcripts or recordings of the Services for its business purposes.
When you make payments through the Service, you may need to provide Personal Data to our third-party service providers, such as your credit card number. We use a third party service provider to process payments on our behalf. You may need to submit your name, your credit card number, bank account number or other payment information, and billing information for payment verification purposes. This information allows our payment processor to process and fulfill your payment. TLC does not have access to your credit card number or other payment or billing information. Your sharing of such information is governed by our payment processors applicable privacy policy and terms of use. Our service provider may store your payment information for your convenience.
Usage Data
Data may be collected from you automatically when you access or interact with the Services. We may collect information about how you access and use the Services ("Usage Data"). Usage Data may include information such as the date and time of your visit, the pages you access, the time spent on those pages, the name of your Internet Service Provider, your device’s Internet Protocol address (“IP address”), the type of browser or application you are using to access the Services, the browser version and operating system, the Internet address from which you linked to our Services, unique device identifiers and other diagnostic data. We may also collect information regarding the device(s) you use to access or use the Services.
When you use the Services with a mobile device, we may collect certain information automatically, including, but not limited to: the type of mobile device you are using, your mobile device unique ID, the IP address of your mobile device, your mobile device operating system, the type of mobile internet browser you are using, unique device information and other diagnostic data.
Cookies and Web Beacons
We use cookies or other tracking technologies to collect usage data and track how you use the Services. Cookies are small files used for authenticating, tracking, and maintaining certain information about users which contain the details of your browsing history and Services preferences. Cookies help us track usage patterns in order to improve and manage the Services and to help us provide personalized service and deliver content specific to your interests. Cookies are also used for statistical reporting for the Services and for other purposes relating to making our Services available to you.
For more information about the cookies we use and your choices regarding cookies, please review our Cookie Policy https://tlcleaders.com/cookies-policy.
Web beacons similarly help us understand how visitors interact with the Services. Web beacons may be used to deliver the cookie and to compile statistics about the Services, such as how many people visited a particular page or clicked on a particular link. This information may be used for online preference marketing purposes. This information may include date and time of banner advertisement shown, related cookies, and the first three octets of the IP address. TLC may share aggregated statistics about usage data with third parties.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some features of this website or our Services may be unavailable to you.
Special Category Data
We do not intend to collect Personal Data that is identified under the European General Data Protection Regulation (“GDPR”) as special category data. Special category data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, personal or political opinions, trade union membership, information about your health, and genetic and biometric data. If we must collect special category data, we will only process special category data where we have a lawful basis for doing so.
Why Do We Collect Personal Data and How Do We Use It?
Most of the Personal Data we collect is provided to us directly by you so that we can bring our products and Services to you. Personal Data is collected and used for our legitimate business interests or those of our service providers. We collect and use Personal Data for the following reasons:
● To provide, operate, and monitor our Services
● To provide customer support and respond to the requests you direct to us
● For the performance of a contract with you: for example, to deliver you a product, program or Services that you have purchased from us
● To provide faculty and staff with the information necessary to provide Services to you
● To maintain the quality of our Services
● To ensure the Services is relevant to your needs
● For promotional communications such as newsletters, special offers and general information, provided you have not opted out of receiving such communications
● To allow you to publicly comment and generate feedback for improvement of the Services
● To send you information or contact you about the Services you are using or that we believe may be of interest to you
● To detect, prevent, and remedy technical issues
● To generate and analyze statistics regarding the use of the Services so that we can improve its quality and make it more beneficial to you
● To prevent and detect criminal and/or fraudulent activity that would be damaging to you and us.
● To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
● For any other purpose with your consent.
Third Parties – Who Do We Share Personal Data With?
When you give us your Personal Data, we will only share that information for the limited purposes set forth in this Policy. We also utilize the services of other third parties that help us manage the data we collect.
We may disclose Personal Data in the following situations:
● With Faculty and Staff
● With other Participants in the Services
● With Services Providers
● With affiliates and/or subsidiaries
● With business partners
● With third party vendors
After an individual ceases to be a participant, their Personal Data resides in an archived form in our participant database unless we are explicitly instructed to remove it. Subject to certain exceptions permitted by law, individuals may instruct us to remove their data from our database by emailing privacy@tlcleaders.com or by contacting us by telephone at 1-(866)-852-7748.
Law Enforcement
We may disclose and exchange Personal Data if we are required by law to do so or in response to legitimate requests of public authorities (e.g. law enforcement, a court, or government agency).
Business Transfers
We may buy, merge, or partner with other companies or businesses and in so doing, acquire or transfer information. Personal Data collected through the Services may be among the transferred business assets. In the event of an acquisition or merger, your Personal Data may be transferred so that we may continue to provide Services to you. In the event that a portion or substantially all of our assets are sold or transferred to a third party, Personal Data would likely be a transferred business asset. You hereby agree to such transfers.
Data Transfer
Your information, including Personal Data may be transferred to — and maintained on — servers and computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. TLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. For more information about GDPR transfers, please see the GDPR specific section below.
Other Reasons for Disclosure
We may disclose Personal Data in the good faith belief that such action is necessary to:
● Comply with a legal obligation
● Protect and defend the rights of the Company
● Prevent or investigate possible wrongdoing in connection with the Services
● Protect the personal safety of users of the Services or the public
● Protect against legal liability
Analytics
We may use third-party Services Providers to monitor and analyze the use of our Services.
Google Analytics
Google Analytics is a web analytics Services offered by Google that tracks and reports Services traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google Services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Third Party Links & Services
In general, the third parties with whom we share Personal Data will only use, collect, and disclose Personal Data to the extent necessary for them to perform the services they provide to us.
We may use certain third-party Service Providers to assist with providing Services to you. These Service Provider may collect, process, and use Personal Data from you in order to perform Services. We recommend that you read their privacy policies so you can understand the manner in which your Personal Data will be handled by these parties. The Personal Data you provide to these Service Providers is subject to privacy policies and terms of each Service Provider. The Service Providers we use may include, but are not limited to, the following:
Zoom: We may use Zoom’s services to provide you with educational programs and our Services through Zoom’s conferencing services. You can find Zoom’s privacy policy here: https://www.zoom.us/privacy
SurveyMonkey: We may use Momentive to request survey data for the performance of our programs and Services. You can find SurveyMonkey’s privacy policy here: https://www.surveymonkey.com/mp/legal/privacy/
Box.com: We use Box to securely transfer documentation and information. You can find Box’s privacy policy here: https://www.box.com/legal/privacypolicy
Google: We may use Google to interact with program participants and to provide Services to you. You can find Google’s privacy policy here: https://policies.google.com/privacy
Element451: We may use Element451 to interact with program participants and program alumni and to provide Services to you. You can find Element451’s privacy policy here: https://element451.com/privacy-policy
Coaching.com: We may use Coaching.com for engagement between TLC Coaches and TLC coaching participants and to provide Services to you. You can find Coaching.com’s privacy policy here: https://www.coaching.com/privacy-policy
HubSpot: We may use HubSpot to process payments on our behalf. You can find HubSpot’s privacy policy here: https://legal.hubspot.com/privacy-policy
The Services may also contain links to third party websites or content that we do not control. TLC is not responsible for the content of such third parties, or for the privacy policies and practices of any such third party. Even if an affiliation exists between TLC and a third-party provider, each linked website maintains its own independent privacy and data collection policies and procedures. While we expect our affiliates to respect the individuals’ privacy, we cannot be responsible for the actions of third parties. We encourage you to read the linked website’s privacy policy before providing your Personal Data.
Choices About How We Use and Disclose Your Information:
We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:
● Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
● Promotional Offers from TLC: We may use your Personal Data to provide you with newsletters, marketing, or promotion materials. If you do not wish to have your email address used by TLC to promote our Services, you can opt-out by sending us an email stating your request to privacy@tlcleaders.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
● Personal Data: If you choose to provide your Personal Data through the use of the Services, and later decide that you want to opt out of us having your information, just let us know by emailing privacy@tlcleaders.com or by contacting us by telephone at 1-(866)-852-7748. For more information about specific rights under the European Union General Data Protection Regulation (“GDPR”), please visit that specific section below.
Data Security
It is our intent to strictly protect the security of your Personal Data, honor your choices for its intended use, and carefully protect your Personal Data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. We have taken appropriate steps to safeguard and secure the Personal Data and other information we collect online. Even so, no company, including us, can fully eliminate security risks associated with the transmission of Personal Data over the Internet. You should always take into consideration that the Internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessible by people other than those you intended to access it.
We restrict access to your Personal Data to our employees, faculty and staff, Service Participants, Service Providers and third parties who need the information in order to process it on our behalf. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes, or fail to follow policies. Therefore, while we use commercially reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security. If an applicable law imposes any non-disclaimable duty to protect your Personal Data, you agree that intentional misconduct will be the standard used to measure our compliance with this duty.
While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Services, we cannot guarantee that these efforts will always be successful. We do not represent, warrant, or guarantee that our safeguards will protect the total privacy of your Personal Data disclosed on the Services. Your Personal Data may be accessed and viewed by other Internet users without your knowledge or permission while in transit to or from us. We cannot and do not ensure, represent, warrant, or guarantee the security of any information you transmit through the Services.
Children, Age of Consent
We do not intentionally collect Personal Data from individuals under 13 years old. In compliance with the Children’s Online Privacy Protection Act, any information we receive from users we believe to be under the age of 13 will be deleted as soon as possible.
This Service is not intended for use by those under the age of 18, nor is it targeted to those under the age of 18. If you use the Services, you hereby represent and warrant that you are at least 18 years of age. No one under the age of 18 may provide any Personal Data to or on the Services. We do not knowingly collect Personal Data from those under the age of 18, nor do we knowingly sell or otherwise disclose the Personal Data of those under the age of 18. If you are under the age of 18, do not (i) use or provide any information on the Services or through any of its features, (ii) use any of the interactive or fillable features of the Services, or (iii) provide any information about yourself to us, including your name, address, telephone address, e-mail address or any other information that could be used to identify you. Any information we receive from users we believe to be under the age of 18 will be purged from our database.
State Consumer Privacy Laws
TLC respects your privacy. As a service provider to organizations that are subject to state consumer privacy laws, TLC shall comply with such laws as necessary to provide the services to such organizations, and shall assist with any individual rights requests as applicable and if required.
California’s Shine the Light Law
In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Data to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of Personal Information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received Personal Information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information) . If you are a California resident and would like to make such a request, please email us at privacy@tlcleaders.com.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
The Services does not respond to or support Do Not Track (“DNT”) signals.
Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
European General Data Privacy Regulation (GDPR)
If you are a resident of the European Union (EU), you have certain data protection rights under the European General Data Protection Regulation (GDPR).
Legal Basis for Processing Personal Data Under GDPR
To process your Personal Data, we must have a legal basis for doing so. We may process your Personal Data under the following conditions:
● Consent: You have given your consent for processing Personal Data for one or more specific purposes.
● Performance of a contract: The Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
● Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
● Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
● Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
● Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
Your Data Protection Rights Under GDPR
In certain circumstances, you have the following data protection rights with respect to the Personal Data that we collect and process:
● The Right to Request Access. You have the right to access, update, or delete the information we have about you.
● The Right of Rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
● The Right to Object. You have the right to object to our processing of your Personal Data.
● The Right to Restrict Processing. You have the right to request that we restrict the processing of your Personal Data.
● The Right of Erasure. In certain circumstances, you have the right to ask us to remove or delete your Personal Data.
● The Right to be Forgotten. You have the right to request that we delete your Personal Information, in certain situations.
● The Right to Transfer. Upon request we will provide you (or a third-party you have chosen) the Personal Data we have collected about you. Your Personal Data will be provided in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.
● Withdraw Your Consent. You have the right to withdraw your consent at any time where TLC relied on your consent to process your Personal Data.
Data Transfers outside of the European Economic Area (“EEA”) or United Kingdom (“UK”)
If you are located in the EEA or UK, we have implemented secured transfer mechanisms, and where applicable, additional technical, contractual and/or organizational measures to secure the transfer of your Personal Data to jurisdictions that the European Commission or Information Commissioner’s Office (ICO) does not consider to provide the same privacy protection as in the EU or UK. We are based in the United States of America. We may process, store, and transfer the Personal Data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own, including the United States of America.
By submitting your Personal Data or engaging with our Services, you consent to this transfer, storing, or processing.
Exercising Your Rights Under GDPR
You may exercise any of the rights enumerated above by contacting us at privacy@tlcleaders.com. Please note that we may ask you to verify your identity before responding to such requests.
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area or you can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If a Data Processing Addendum (DPA) is required, that can be requested using the information below.
Changes to our Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' Personal Data, we will notify you by email. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
Contact Us
If you would like to access, correct, amend or delete any Personal Data we have about you, register a complaint, or simply want more information, please contact us by emailing privacy@tlcleaders.com or by telephone at 1-(866)-852-7748.