Last updated: September 25, 2022
Perry Gladstone Consulting cares deeply about your privacy and the security of your information. We appreciate the trust you have placed in us.
You may also view the Terms and Conditions of our website for additional information about the use of Perry Gladstone Consulting’s Services.
Interpretation and Definitions
Capitalized words have the following defined meanings. These definitions shall have the same meaning if they appear in singular or in plural.
You means the individual accessing or using the Service, or the Company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
Perry Gladstone Consulting (referred to as either "Perry Gladstone", "We", "Us" or "Our" in this Agreement) refers to Perry Gladstone Consulting, 467 Atlas Ave., Toronto, Ontario, Canada. For the purpose of the GDPR, Perry Gladstone Consulting is the Data Controller.
Website refers to Perry Gladstone Consulting, accessible from www.perrygladstone.com
Services refers to www.perrygladstone.com, the assessments surveys, and products offered therein, consulting, training, coaching, newsletters and other content we provide, live webinars or editorial events we host, administrative tools, e-commerce processing.
Country refers to: Ontario, Canada
Third-Party Provider means any natural or legal entity who processes the data on behalf of Perry Gladstone Consulting. It refers to third-party companies or individuals employed by Perry Gladstone Consulting to facilitate the Service, to provide the Service on behalf of the Perry Gladstone Consulting, to perform services related to the Service or to assist Perry Gladstone Consulting in analyzing how the Service is used. For the purpose of the GDPR, Third-Party Providers are considered Data Processors.
Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to Perry Gladstone Consulting as the legal entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
Business for the purpose of the CCPA (California Consumer Privacy Act), refers to Perry Gladstone Consulting as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
Consumer for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Sale for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration.
Collecting and Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
First name and last name
Address, State, Province, ZIP/Postal code, City
Information you enter on Perry Gladstone Consulting's Website, Surveys and Assessments
Perry Gladstone Consulting receives and stores information you enter on Perry Gladstone Consulting’s online platforms when you make a purchase, take an assessment, include information in your account, or communicate with us by e-mail, chat, text, phone, or otherwise. As a result of those actions, you might supply Perry Gladstone Consulting with your name, address, and phone number, credit card information, people to whom purchases have been shipped (along with their addresses and delivery information), content of reviews and e-mails to us, and replies you submit during the assessments, which may include your personal beliefs, the opinions and competencies of employees, and information about your company. Of course, you may choose not to provide certain information. However, not providing some information may limit your ability to take advantage of all available features of our assessments, products, and services.
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
perrygladstone.com may include social media and commenting features provided by third parties. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to allow the feature to function properly. Your interactions with any social media features on perrygladstone.com are governed by the respective social media privacy policies, and not that of Perry Gladstone Consulting.
Use of Your Personal Data
Perry Gladstone Consulting may use Personal Data for the following purposes:
To provide and maintain our Services, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
To improvePerry Gladstone Consulting's products and perform leadership research. Assessment responses and general information provided by participants in the 2021 Remote Leadership Assessment are detached from any personally identifiable information, aggregated with other assessment responses, and analyzed in Perry Gladstone Consulting's ongoing research in order to deepen our understanding of trends and and nuances of remote leadership. See Product Terms for additional information.
Perry Gladstone Consulting will never share, sell, rent, communicate or divulge your personal information to third-parties for promotional use. Perry Gladstone Consulting does not, under any circumstances, share Your information with third parties for purposes outside the scope of Services we provide unless:
Required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency);
Perry Gladstone Consulting believes that such action is necessary to:
Comply with a legal obligation
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
Protect and defend the rights or property of Perry Gladstone Consulting
We may share your personal information with Third-Party Providers to perform certain services such as:
creating and updating the functionality of the perrygladstone.com Platform, which delivers products and services;
hosting the website;
billing or processing credit cards, and/or electronic or manual payments;
assisting us in creating and updating Perry Gladstone Consulting's assessment platform;
managing a database of customer and consumer information;
tracking website activities and analytics, including marketing and market research;
enabling us to send you special offers or perform other administrative services, such as customer service, security, tech, operational support, email and legal services; and/or
other services designed to assist us in maximizing our business potential.
These third-parties have access to your personal information only to perform tasks on our behalf and are obligated not to disclose or use your information for any other purpose. These vendors have additional or different privacy policies and/or Terms of Service. You may request additional information regarding specific third-party providers used by Perry Gladstone Consulting from Perry Gladstone Consulting.
Retention of Your Personal Data
Perry Gladstone Consulting will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at Perry Gladstone Consulting's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to—and maintained on—computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Security of Your Personal Data
Perry Gladstone Consulting follows industry best practices to protect information submitted to us, both during transmission and once we receive it. We further require that the third party providers we contract adhere to the same high quality standards.
We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission via public internet.
All payment transactions are processed through a gateway provider and credit card information is not stored or processed on our servers. Your assessment data is held in Amazon Web Services’ data center in Central Canada, fully levering their service security offering. Further details are available here https://aws.amazon.com/security/.
You must also help protect the privacy of your own information as it is transmitted over networks, wireless routers, wireless (WiFi) networks or similar devices by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personal information.
No method of transmission over the Internet, or method of electronic storage, is 100% secure. By using our Services, and sending information to us electronically, you consent to trans-border and international transmission of any data that you may choose to supply us. We cannot ensure or warrant the security of any information you transmit to us or store within the Perry Gladstone Consulting platform, and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards or those of our third party providers.
If you believe your Personal Data has been compromised, please contact Perry Gladstone Consulting.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
Perry Gladstone Consulting does not sell products for purchase by children. Unless permitted by applicable law, children under the age of 18 may not access our Services. We do not intentionally collect, maintain, or use personal information from minors under the age of 18. If a minor submits personal information to Perry Gladstone Consulting, and we learn that the personal information is the information of a child under legal age, we will attempt to delete the information as soon as possible. If you believe that we may have any personal information of a child under the legal age range, please contact Perry Gladstone Consulting.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service providers to monitor and analyze the use of our Service, including Google Analytics.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR
We may process Personal Data under the following conditions:
You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of 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 Perry Gladstone Consulting 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 Perry Gladstone Consulting.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Perry Gladstone Consulting.
In any case, Perry Gladstone Consulting will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
YOUR RIGHTS UNDER THE GDPR
Perry Gladstone Consulting undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data 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 information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
EXERCISING OF YOUR GDPR DATA PROTECTION RIGHTS
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Your Rights Under the CCPA
The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request. The CCPA permits You to request and obtain from Perry Gladstone Consulting information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by Perry Gladstone Consulting or its subsidiaries to a third-party for the third party's direct marketing purposes.
The right to say no to the sale of Personal Data. You also have the right to ask Perry Gladstone Consulting not to sell Your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.
The right to know about Your Personal Data. You have the right to request and obtain from Perry Gladstone Consulting information regarding the disclosure of the following:
The categories of Personal Data collected
The sources from which the Personal Data was collected
The business or commercial purpose for collecting or selling the Personal Data
Categories of third parties with whom We share Personal Data
The specific pieces of Personal Data we collected about You
The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
Denying goods or services to You
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to You
Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
EXERCISING YOUR CCPA DATA PROTECTION RIGHTS
In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us. Perry Gladstone Consulting will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
DO NOT SELL MY PERSONAL INFORMATION
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Services do not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
* Yes, you can send us a text message.