Integrative Enneagram Solutions (IES) Data Protection and Privacy Policy

(in accordance with the EU General Data Protection Regulation)

What this Policy Covers

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you.

This policy is intended to help you understand:

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with us (for example, by attending our events or training), unless a different policy is displayed.

“IES, we and us” are used to refer to Integrative Enneagram Solutions throughout this policy. We offer a wide range of products and refer to all of these products, together with any services we may offer as “Products” in this policy.

This policy also explains your choices about how we use your information. Your choices include how you can object to certain uses of information and how you can access and update certain information about yourself. If you do not agree with this policy, do not access or use our Products or interact with any other aspect of our business.

Where we provide the Products under contract with an organization (for example your employer) that organization controls the information processed by the Products. For more information, please see the “Notice to End Users” below.

WHAT INFORMATION WE COLLECT ABOUT YOU

We collect information about you when you provide it to us, when you use our Products, and when other sources provide it to us, as further described below.

Information you provide to us
We collect information about you when you input it into the Products or otherwise provide it.

Account and Profile Information: We collect information about you when you make purchases through our website. For example, you provide your contact information and, in some cases, billing information when you select to purchase Products. You also have the option to select the language for the Products. We keep track of your preferences when you select settings within the Products.

Content you provide through our products: The Products include the IES products you use, where we collect and store content that you supply when you complete the relevant questionnaire. This content includes basic demographic information. We collect content using analytics techniques that hash, filter or otherwise scrub the information to exclude information that might identify you or your organization; and we collect clickstream data about how you interact with and use features in the Products.

Content you provide through our website: The Products also include our website and include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, activities or events.

Information you provide through our support channels: The Products also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Product. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to: provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Payment Information: We collect certain payment and billing information when you register for certain paid Products. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

Information we collect automatically when you use the Products:
We collect information about you when you use our Products, including browsing our website and taking certain actions within the Products.

Device and Connection Information: We collect information about your computer, mobile phone, tablet, or other devices you use to access the Products. This device information includes your connection type and settings when you use our Products. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Products.

Cookies and Other Tracking Technologies: IES and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., Google, and Facebook) to provide functionality and to recognize you across different Products and devices. For more information, please see our Cookies and Tracking Notification which includes information on how to control or opt out of these cookies and tracking technologies.

Information we receive from other sources
We receive information about you from other Products users, from third-party services, from our related companies, and from our business and channel partners.

Other users of the Services: Other users of our Services may provide information about you when they submit content through the Products. For example, you may be identified as a respondent in a 360 Questionnaire. We also receive your email address from other Products users when they provide it in order to invite you to the Products. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your company’s account.

IES AccreditedPractitioner: We work with a global network of IES Accredited Practitioners who provide consulting, implementation, training and other services around our Products. Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We receive information from these partners, such as billing information, billing and technical contact information, company name, IES products you have purchased or may be interested in, evaluation information you have provided, events you have attended, and what country you are in.

Other Partners: We receive information about you and your activities on and off the Products from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Products and online advertisements.

HOW WE USE INFORMATION WE COLLECT

How we use the information we collect depends in part on which Products you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

To provide the Products and personalize your experience: We use information about you to provide the Products to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Products. Where you use multiple Products, we combine information about you and your activities to provide an integrated experience.

For research and development: We are always looking for ways to make our Products smarter, faster, secure, integrated, and useful to you. We use collective learnings about how people use our Products and through feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Products. In some cases, we apply these learnings across our Products to improve and develop similar features or to better integrate the Products you use. We also test and analyze certain new Products with some users before rolling them out to all users.

To communicate with you about the Products: We use your contact information to send transactional communications via email, including confirming your purchases, responding to your comments, questions and requests, providing customer support, and sending you updates, security alerts, and administrative messages. We also provide tailored communications based on your Product usage and interactions with us. These communications are part of the Products and in most cases, you can opt out of them; you will find that option within the communication itself or in your account settings.

Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Products.

For safety and security: We use information about you and your Product use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of use policies.

To protect our legitimate business interests and legal rights: Where required bylaw or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we use your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use, although in some cases, this may mean no longer using the Products.

HOW WE SHARE INFORMATION WE COLLECT

We are an innovative Enneagram solutions provider. We integrate the art and science of self- discovery and transformation through the practical application of intelligent technology and holistic people development and we want our Products to work well for you. This means sharing information through the Products and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.

Sharing with third parties
Integrative Enneagram Solutions has entered into an arrangement with FourthWalnut (Ian Morgan Cron’s company) wherein certain of your personal information, including your name, email address and core enneagram type will be collected by Integrative Enneagram Solutions and transferred to the other party pursuant to such agreement. When this happens both Integrative Enneagram Solutions and the other party make assurances that steps are taken to protect any data being transferred.

Service Providers: We work with third party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.

IES Associates and Accredited Practitioners: We work with third parties who provide consulting, sales, and technical services to deliver and implement customer solutions around the Products. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.

Links to Third Party Sites: The Products may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect IES, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

HOW WE STORE AND SECURE INFORMATION WE COLLECT

Information storage and security
We use data hosting service providers in the Netherlands to host the information we collect, and we use technical measures to secure your data. For more information on where we store your information, please contact us using the contact information at the end of this document.

While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account information: We retain all account information; to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Products. Where we retain information for Product improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Products, not to specifically analyze personal characteristics about you.

Managed accounts: If the Products are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account. For more information, see “Managed accounts and administrators” above.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Products, such as when you last opened an email from us or completed a questionnaire. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

HOW TO ACCESS AND CONTROL YOUR INFORMATION

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.

Your Choices:
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. Where the Products are administered for you by an administrator (see Notice to End Users below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Delete your information: Our Products give you the ability to delete certain information about yourself. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we do not have the appropriate rights to do so. For example, if you believe a Product was purchased for you without your permission or you are no longer wish to utilize the Product, you can request that we delete your details as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).

Opt out of Communications: You may opt out of receiving promotional communications from us in two ways: by using the unsubscribe link within each email or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.

Turnoff Cookie Controls: Relevant browser-based cookie controls are described in our Cookies and Tracking Policy Notice.

Send “DoNotTrack” Signals: Some browsers have incorporated Do Not Track (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our platform does not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.

Data Portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with relevant data.

HOW WE TRANSFER INFORMATION WE COLLECT INTERNATIONALLY

International transfers of information we collect
We collect information globally and primarily store that information in the Netherlands. We transfer, process and store your information outside of your country of residence, to wherever we or our third party service providers operate, for the purpose of providing you the Products. Whenever we transfer your information, we take steps to protect it.

International transfers to third parties: Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or Switzerland, we comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer. Please see our Privacy Shield Notice below.

Privacy Shield Notice
IES participates in and comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and the Privacy Shield Principles regarding the collection, use, and retention of information about you that is transferred from the European Union or Switzerland (as applicable) to the U.S. We ensure that the Privacy Shield Principles apply to all information about you that is subject to this privacy policy and is received from the European Union, the European Economic Area, and Switzerland.

Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the EU and Switzerland and onward transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers. Moreover, we remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles. We are not liable if we prove that we are not responsible for the event giving rise to the damage.

To learn more about the Privacy Shield Program, please see here www.privacyshield.gov. We encourage you to contact us as provided below should you have a Privacy Shield-related (or general privacy-related) complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us immediately.

We are also committed to cooperating and complying with the information and advice provided by an informal panel of data protection authorities in the European Economic Area and/or the Swiss Federal Data Protection and Information Commissioner (as applicable) in relation to unresolved complaints (as further described in the Privacy Shield Principles). You may also contact your local data protection authority within the European Economic Area or Switzerland (as applicable) for unresolved complaints.

Under certain conditions, more fully described on the Privacy Shield website, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

OTHER IMPORTANT PRIVACY INFORMATION

Notice to End Users
Many of our Products are intended for use by organizations. Where the Products are made available to you through an organization (e.g. your employer), that organization is the administrator of the Products and is responsible for the products over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Products is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different from this policy.

Even if the Products are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Products then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your Products at a later date. You will be notified if this happens.

If you do not want an administrator to be able to assert control over your Products, use your personal email address to register for or purchase the Products. If an administrator has not already asserted control over your Products, you can update the email address associated with your account by contacting the IES Support Team. Once an administrator asserts control over your Products you will no longer be able to change the email address associated with your Products without administrator approval. Please contact your organization or refer to your administrator’s organizational policies for more information.

Our Policy Towards Children
The Products are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

Changes to our Privacy Policy
We may change this privacy policy from time to time and will notify clients via email of any privacy policy changes. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Products to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Products and request that your information be deleted as outlined above.

CONTACT US

Your information is controlled by Integrative Enneagram Solutions. If you have questions or concerns about how your information is handled, please direct your inquiry to the IES Support Services, who are responsible for facilitating such inquiries.