Strategic Decisions Group Privacy Policy

EFFECTIVE DATEAugust 9, 2018

Strategic Decisions Group International LLC (“SDG”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our websites, www.sdg.com, hongkong.sdg.com, germany.sdg.com, www.sdgdecisioneducation.com, rh-odqassessment.sdg.com, www.appliedstrategies.com, and any other SDG websites to which we have posted this Policy (collectively, the “Sites”); the SDG Decision Quest mobile application and other SDG applications to which we have posted this Policy (collectively, the Apps); and the services available through our Sites and Apps (collectively, the Sites, the Apps, and the services available through them are the “Services”).

We adhere to the regulations that govern commercial email communications as they pertain to obtaining consent, responding to opt-out requests in a timely manner, and other restrictions and requirements specific to the individual legislation.

  • CAN-SPAM. The CAN-SPAM Act establishes rules in the United States for commercial email, gives recipients the right to stop receiving email, and spells out tough penalties for violations.
  • CASL. Canada’s Anti-Spam Legislation applies to electronic messages in connection with commercial activity. It seeks to protect Canadians by creating a regulatory framework to combat spam and other electronic threats.
  • GDPR. The General Data Protection Regulation affects all member-states in the European Union. GDPR aims to give control to citizens and residents over their personal data and to unify regulation within the EU.

Any information, including personal information, that we collect from or about you through our Services will be handled as described in this Policy and according ot the respective regulatory framework. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Service including its applicable limitations on damages and the resolution of disputes.

 

The Information We Collect

We collect information about you directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources.

Information We Collect Directly From You. We may collect information about you directly from you. For example, certain areas and features of our Services require registration, and to register you must provide your name, email, company, job title, city, and country. If you purchase classes, services or merchandise from us, we may collect your name, payment card information, and mailing or billing address. If you apply for a job request information, or enroll in a course, we also may collect additional optional information from you, including phone number. We will also collect any other information that you provide to us through our Services, such as a shipping address, the contents of any message you submit to us through our Sites, and responses you provide via surveys on our Services. If you are responding to a job posting or applying for a position, we will collect additional personally identifiable information from your resumé.

Information We Collect About You from Third Parties. We may also collect information about you from third parties. For example, we may collect information available in your public Facebook profile when you “Like” us on Facebook.

Information We Collect Automatically. We automatically collect information about you through your use of our Services, including: domain name; browser type and operating system; web pages you view; links you click; IP address; geolocation; hardware information, such as your device ID; the dates and times you use our Services; and the referring URL that led you to our Site. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

User Content

Some of our Sites invite you to post content on our Services, including your comments, discussions, pictures, and any other information that you would like to be available on our Services (collectively, “User Content”). If you post User Content to our Services, such information, along with other information such as your user name, will be available to all registered users on our Services. Your User Content may become public and SDG cannot prevent such information from being used in a manner that may violate this Policy, the Terms of Service, the law, or your personal privacy.

How We Use Your Information

We use your information, including your personal information and User Content, for the following purposes:

Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features, products, or services; to perform technical operations, such as updating software; and for other customer service and support purposes.

Tailoring Content. To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and otherwise to personalize your experiences while using the Services.

Marketing and Communications. To communicate with you about your account and use of our Services, including to send you notices of course, product and service updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Our communications with you may include communications via email. Please see our section regarding “Your Choices” for more information about how to change your communications preferences.

Recruiting. To communicate with you about job opportunities or openings; to evaluate your qualifications for job openings; to respond to any employment-related inquiries that you submit.

Research and Analytics. To analyze how you interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.

Protecting Rights and Interests. To protect the safety, rights, property, or security of SDG, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which SDG, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Service.

Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request from law enforcement or a governmental authority.

How We Share Your Information

We may share your information, including your personal information and User Content, as follows:

Site Users. Your user name and any information that you post to our Services, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Services.

Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Policy.

Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf, as well as to third parties whom we engage to provide services to you, for example, webinar or online course delivery platforms.

Other Unaffiliated Third Parties.  We will not disclose your information to third parties who are not affiliated with SDG.

Business Transfers. We may disclose your information to another entity in connection with, including during planning for or negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.

Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of SDG, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which SDG, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Service.

Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request from law enforcement or a government official.

Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

How Long We Keep Your Personal Information

SDG conducts management consulting engagements as well as courses and training, webinars, online courses or “MOOCs”, surveys, and other activities for which we may collect or retain your personal information. In addition, you may provide your personally identifiable information voluntarily when you download white papers, view webinars or videos, or participate in online polls.

EU Residents. The European Union requires that we disclose how long we keep the personally identifiable information of its residents. For EU clients, we retain your personally identifiable information in connection with a consulting engagement for 20 years. For EU participants in courses or training, in either public or on-site courses, we retain your personally identifiable information for 10 years. These time frames have been established to accommodate former clients and course participants who return many years later to request additional consulting engagements or course delivery. For EU residents who provide their personally identifiable information in connection with free content or services from our Sites such as webinars, downloadable assets, or other resources, we keep information for two years from your last interaction. For recruiting inquiries from EU residents, we keep resumes and information of EU residents for one year.

Outside of the European Union. We keep the personally identifiable information of consulting clients and course attendees indefinitely. We retain the personal information of those who access resources from our website or other online services such as webinars or surveys for two years from the last interaction. Information and resumes obtained in the course of recruiting or job interviews is retained for one year.

Exception for Legal Requirements. We may retain your personal information for longer than these time frames if they may be the subject of a legal claim, or may otherwise be relevant for future litigation.

Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services.  Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Services who disable cookies will be able to browse certain areas of the Services, but some features may not function (e.g., you may not be able to stay logged into your account).

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Do Not Track Disclosure

For more information about Do Not Track signals, please click here. You may disable certain tracking as discussed in the “Cookies and Other Tracking Mechanisms” section above (e.g., by disabling cookies).

Third-Party Analytics

We use automated devices and applications, such as Google Analytics and Marketo, to evaluate usage of our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services.

Third-Party Ad Networks

We use third parties such as network advertisers to display advertisements on our Services, to assist us in displaying advertisements on third-party websites, and to evaluate the success of our advertising campaigns. Network advertisers are third parties that display advertisements based on your visits to our Sites as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested.

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).

Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Services or other services. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextual advertising). Also, if your browsers are configured to reject cookies when you visit an opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt out may no longer be effective.

Third-Party Links

Our Services may contain links to third-party websites  or Services. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of the third-party operators of websites or services. We are not responsible for the information practices of such third parties. For example, if you fill out a survey on SurveyMonkey, your survey responses and other information you may provide are governed by the SurveyMonkey Privacy Policy.

Security

We have implemented generally accepted standards of technology and operational security in order to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Your information is contained on secure networks and is only accessible by authorized employees who have special access right to such systems and are required to keep the information confidential. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Transborder Hosting and Transfer of Information

We are a global firm with offices in multiple countries. Strategic Decisions Group International LLC may share some of the information it gathers with its affiliates for purposes described in this Privacy Policy. We adhere to the frameworks and regulations that govern your personally identifiable information, including CAN-SPAM, GDPR, and CASL.

Your Choices

Accessing, Modifying, or Deleting Your Personal Information. You may access, modify, or delete the personal information that you have provided to us by logging into your account settings or emailing us at preferences@sdg.com with your request. Please note that we may retain certain information about you as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information but we believe that you have violated our Terms of Service we may retain information about you in order to attempt to resolve the issue before deleting it.

Opting out of Marketing Emails. We may send periodic promotional or informational emails to you. You may opt out of such communications by following the unsubscribe link contained in every marketing email. You may visit our unsubscribe webpage to enter the email address you would like unsubscribed. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Children Under 13

Our Services are not targeted to children under 13 years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact our Data Privacy Officer:

Barbara Metzler
bmetzler [at] sdg.com
Strategic Decisions Group International LLC
951 Mariners Island Blvd., Suite 400
San Mateo CA 94404


To unsubscribe from our marketing emails, please visit our unsubscribe webpage or contact us at preferences@sdg.com with the word “unsubscribe” in the subject line.

Consent and Changes to this Policy

This Policy is current as of the Effective Date set forth above. By using the Site, you consent to the collection, use, and storage of your information by us in the manner described in this Privacy Policy and governed by the respective regulations such as CAN-SPAM, CASL, and GDPR. We reserve the right to make changes to this Privacy Policy from time to time. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites.  This Privacy Policy was last updated on August 9, 2018.