This website is owned and operated by Smarter Collaboration International, Inc (the "Company," "we," or "us"). We work diligently to protect the privacy, confidentiality, and security of the Personal Information (defined below) that we receive. This Privacy Policy describes our practices for Personal Information that we collect from individuals online or offline ("you"), such as individuals who browse our Sites (defined below), register for an account, use the Products or Services offered through the Sites, participate in interviews, surveys, promotions, or training, receive newsletters, communicate with us, or apply for employment.

 

This Policy is intended to satisfy applicable notice and transparency obligations, including under the EU/UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and other applicable privacy and data protection laws. Where local law requires additional disclosures, those disclosures are provided in the sections below.

 

Privacy Principles

We design our privacy program around core principles of transparency, purpose limitation, data minimization, security, and accountability. In particular:

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Access — Where we act as the controller of your Personal Information, we provide you with the opportunity to confirm whether we process your Personal Information, obtain a copy of it, request correction or deletion, and (where applicable) restrict or object to certain processing, within a reasonable time.

 

Accountability for Onward Transfer — We disclose Personal Information to third parties only as described in this Policy or our agreements, and we require appropriate contractual protections for Personal Information shared with service providers.

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Accuracy — We take reasonable steps to keep Personal Information accurate and up to date and to correct it when appropriate.

 

Choice — We provide mechanisms to manage marketing preferences and, where required, to consent to or opt out of certain processing.

 

Integrity, Confidentiality, and Security — We maintain administrative, technical, and physical safeguards designed to protect Personal Information.

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Storage Limitation — We retain Personal Information only as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.

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Definitions

For purposes of this Privacy Policy:

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• "Assessment" means an instrument, questionnaire, or series of tests completed by one or more End Users to generate one or more Reports.

• "End User" means an individual who takes, will take, or has taken an Assessment.

• "Report" means an analysis based on Assessment responses and related scoring.

• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This may include identifiers (such as name and email), commercial information (such as billing details), internet or other electronic network activity information (such as IP address and device identifiers), and other information described in this Policy.

• "Sensitive Personal Information" (as defined by certain laws such as the CPRA) may include information such as precise geolocation, certain government identifiers, and certain demographic attributes. We collect Sensitive Personal Information only when needed for the Services and/or where permitted by law, and in some cases only with your explicit consent.

• "Session Data" means technical and usage information about how you access and use the Sites, such as IP address, device identifiers, browser type, operating system, referring URLs, pages viewed, timestamps, and similar information.

• "Service Provider" means a vendor that processes Personal Information on our behalf under a written contract that limits the vendor’s use of Personal Information to providing services to us.

• "Sites" means our websites and applications, including any sites or apps we operate from time to time (for example, gardnerandco.co and smartercollaboration.com).

 

Your Agreement to this Privacy Policy

By creating an account, using the Sites, and/or submitting Personal Information to us, you agree to the practices described in this Privacy Policy and agree that we may collect, use, disclose, store, transmit, and process Personal Information as described here or as required by law.

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If you reside in a country or territory that restricts the transfer of Personal Information outside that country or territory, you understand that we may transfer, store, and process your Personal Information in countries that may have different data protection laws. Where required, we implement appropriate safeguards for such transfers (see International Transfers below).

 

Children are not permitted to use the Sites. If we learn that we have collected Personal Information directly from a Child (as defined below) without appropriate authorization, we will take steps to delete that information.

 

Confidentiality; Intellectual Property; Prohibited AI Use

Our Assessments, Reports, scoring models, methodologies, and related materials are proprietary and constitute valuable intellectual property and trade secrets. Except as expressly authorized in writing by the Company or under an applicable license agreement, you must not: (i) copy, reproduce, publish, distribute, or make Reports or other proprietary materials available outside your organization; (ii) create derivative works based on our Assessments, Reports, or methodologies; (iii) remove, obscure, or alter copyright, trademark, or proprietary notices; or (iv) use the Sites or any Company materials to develop, train, or improve competing products.

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In addition, you shall not upload, input, or otherwise provide any Company content (including Reports, assessment items, questions, scoring outputs, or other proprietary information) into any artificial intelligence (AI) platform, machine learning system, or similar technology, whether for analysis, content generation, model training, or any other purpose, except where the Company has provided prior written permission.

 

Links to External Sites

The Sites may link to third-party websites that are not operated by the Company. This Privacy Policy does not apply to third-party websites. We encourage you to review the privacy statements of any third-party site you visit.

 

What Personal Information We Collect and How

We collect Personal Information as necessary to: (i) provide our Products or Services; (ii) communicate with you (including marketing where permitted); (iii) continue research and development in our field; and (iv) improve our Sites, Products, or Services.

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Where required by law, we will obtain your consent for certain processing (for example, certain optional demographic questions or non-essential cookies). Otherwise, depending on context, our legal bases may include performance of a contract, legitimate interests, and compliance with legal obligations.

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We do not sell Personal Information for monetary consideration. Some privacy laws define "sale" or "sharing" broadly to include certain disclosures (for example, disclosures for cross-context behavioral advertising). To the extent such laws apply to our activities, we provide applicable choices and rights as described in the Your Rights section.

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If you visit the Sites—If you visit the Sites, we automatically collect Session Data through server logs, cookies, and similar technologies. We also use analytics services such as Google Analytics to help us understand how visitors use the Sites, measure performance, and improve content. Google Analytics may use cookies and collect information such as your IP address and device and browser information; the information collected through these tools is subject to configuration and may be processed by Google on our behalf as a Service Provider.

 

If you register or create an account—If you register or create an account, we require that you provide certain Personal Information during account registration. We typically collect your name, email address, contact information, and account credentials, and may ask for other optional information that helps us serve you better.

 

If you complete an Assessment—If an End User completes an Assessment, we collect the End User’s name, email address (where applicable), contact information, Assessment responses, and Session Data in order to score the Assessment and generate Reports. In some cases, we offer optional demographic questions; where those questions involve Sensitive Personal Information, we collect and use that information only with your explicit consent or as otherwise permitted by law.

 

If you participate in a survey, interview, or promotion—If you choose to participate in one of our surveys, interviews, promotions, or feedback initiatives, we may collect Personal Information such as your name, email address, and any other information that you choose to provide. Participation is optional, and we provide mechanisms to opt out of such contacts where appropriate.

 

If you sign up to receive marketing communications—If you sign up to receive marketing communications, we may use contact information to send product updates, newsletters, and other communications. These communications may include measurement tools (such as pixels) to understand engagement and improve communications. You can opt out of marketing communications at any time using the instructions included in the communications or by contacting us.

 

If you are a Customer or other business contact—If you are a Customer or other business contact, or an employee or agent of a Customer or business contact, we may collect business contact information in the regular course of our interaction with you.

 

If we receive information from third parties—We may receive Personal Information about you from third parties, such as Customers, business partners, and service providers, for example to administer an Assessment, provide services you requested, or validate accreditation status.

 

If you apply for employment—If you apply for employment, we may collect Personal Information such as your name, email address, work history, and other information you provide in conjunction with your application. We use this information to evaluate your candidacy and to contact you regarding the application.

 

If you use a mobile application—If you use a mobile application we provide, we may collect certain additional Personal Information depending on the app’s features, including device identifiers and, where you enable such features, location information. You can control certain permissions through your device settings.

 

If you participate in virtual training programs—We may use Session Data to administer and secure virtual training programs, including to monitor attendance, manage registrations, and prevent misuse.

 

How We Use Personal Information

To facilitate use of the Sites—We use Session Data to operate the Sites, enhance navigation, understand usage, maintain security, and improve content.

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In connection with Assessments—We use Assessment responses to score Assessments and to generate Reports and other outputs. Where a Customer sponsors an Assessment, we may provide that Customer with named, individual Reports and related outputs for the End Users participating in that engagement so that the Customer (or its authorized professional) may provide feedback or services to those End Users. We may also generate aggregated team or group reports that are designed to present results in a way intended not to identify individuals.

 

To validate certification status—If you are or become an Certified Partner or similar credentialed user, we may use and disclose limited information regarding accreditation (such as name, credential(s), date(s), and status) to individuals who inquire for verification purposes.

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For research purposes—We may use aggregated and/or de-identified data (including aggregated Assessment responses, demographic information where collected with appropriate permissions, and usage analytics) for research, statistical analysis, product development, and quality improvement. We take reasonable measures to reduce the likelihood that such data identifies an individual.

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For maintenance and security—We may use technical data to diagnose problems with our systems, administer the Sites, prevent fraud, protect accounts, and maintain the integrity of our Services.

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For marketing purposes—Where permitted by law, we may use contact information to send marketing communications. You may opt out at any time.

 

Automated Processing and Profiling

Some Services involve automated scoring of Assessments to generate Reports. We do not intend to use automated processing to make decisions that produce legal or similarly significant effects about you without meaningful human involvement, except where you have provided explicit consent or such processing is otherwise permitted by law. You may contact us to request additional information about our use of automated processing.

 

To Whom We Disclose Personal Information

From time to time, we may disclose Personal Information to someone other than the individual who provided the Personal Information, as described below:

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Customers—If you take an Assessment at the direction of or sponsored by one of our Customers, that Customer will receive from the Company one or more Reports based on the Assessment and the responses you provided. These Reports may be named individual reports. In some engagements, we may also provide aggregated team or group outputs that are designed to be de-identified.

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Service Providers—We may engage third parties to perform functions and provide services to us, such as hosting, assessment administration, customer relationship management, analytics (including Google Analytics), email delivery, payment processing, and support. Pursuant to written agreements, these Service Providers are required to protect Personal Information and are restricted from using Personal Information for any purpose other than providing services to us.

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To defend or enforce our rights—We may use or disclose Personal Information to protect the Company, protect the Sites, respond to breaches of our terms, prevent fraud, or pursue available remedies. If a Customer neglects to pay amounts due and owing to the Company, we may provide limited information to a third-party service provider for collection of overdue payments.

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Co-Marketing Partners—From time to time, we may collaborate with other companies to offer additional Products or Services. Where you request such Products or Services, we may share the Personal Information reasonably necessary for those companies to provide them. This Policy does not govern those companies’ practices, and we encourage you to review their privacy policies.

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Mergers & Acquisitions; Bankruptcy—If any or all of the Company’s assets are acquired by or merged with those of another entity, or in the event of a bankruptcy or similar event, Personal Information may be disclosed as part of due diligence and transferred as part of the transaction, subject to appropriate protections.

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Law Enforcement; Litigation—We may disclose Personal Information where required by law or in response to valid legal process, and where necessary to protect the rights, property, or safety of the Company, our users, or others.

 

Aggregated/De-identified data—Other than as stated above, if we provide third parties with information, it may be in the form of aggregated and/or de-identified data used for research, product development, or statistical analysis.

 

Cookies and Other Technologies

A cookie is a small text file that a website sends to a visitor’s browser and that is returned each time the visitor makes a request from the website. We also may use pixel tags, SDKs, and similar technologies to understand site usage and improve Services.

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We use cookies and similar technologies for purposes that may include: (i) operating and securing the Sites (including authentication and fraud prevention); (ii) remembering preferences; (iii) analytics and performance measurement (including through Google Analytics); and (iv) marketing measurement where permitted.

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Depending on your location, you may be able to control certain cookies through a cookie banner or preference tool when you visit the Sites. You can also control cookies through your browser settings. If you decide not to accept certain cookies, some functionality may not work as intended. The Sites do not currently respond to “Do Not Track” signals or similar mechanisms.

 

How We Retain Personal Information

As a general principle, we keep Personal Information in identifiable form only for as long as necessary to achieve the purposes for which it is processed, subject to our reasonable archive, backup, and research practices and as required or permitted by law.

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In practice, we generally retain Personal Information: (i) for as long as your account remains active; (ii) for as long as we continue to do business with you or the applicable Customer; and/or (iii) for as long as required or permitted by applicable law. When an account becomes inactive or a relationship ends, we may retain Personal Information for a reasonable period for backup, security, audit, and recordkeeping purposes.

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We may retain Assessment responses and related data longer in aggregated and/or de-identified form for research, statistical analysis, product development, or other commercial purposes, and we take reasonable measures intended to reduce identifiability in such datasets.

 

How We Protect Personal Information

We follow generally accepted industry standards and maintain administrative, technical, and physical measures designed to protect Personal Information during transmission and once received. Measures may include access controls, encryption in transit, logging and monitoring, and security training.

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No method of transmission over the Internet, or method of electronic storage, is fully secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee absolute security.

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Security Incidents and Breach Notification—We maintain incident response processes and will provide notifications to individuals and/or regulators when required by applicable breach notification laws.

 

International Transfers

We may process and store Personal Information in the United States and other countries where we or our Service Providers operate. Where the GDPR/UK GDPR or similar laws apply, and Personal Information is transferred internationally, we rely on appropriate safeguards such as Standard Contractual Clauses, the UK International Data Transfer Addendum/IDTA, adequacy decisions, or other lawful transfer mechanisms, as applicable.

 

Your Rights

We respect your rights as a data subject. Depending on your location and our role (controller or processor), you may have rights to access, correct, delete, or obtain a copy of your Personal Information; restrict or object to certain processing; and withdraw consent where processing is based on consent. You may also have the right to data portability where technically feasible.

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Marketing Opt-Out—You may opt out of marketing communications at any time using the unsubscribe link in our communications or by contacting us. We may continue to send non-marketing communications such as service notices.

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California and Other U.S. State Rights—If you are a resident of certain U.S. states (including California), you may have additional rights, which can include the right to know categories of Personal Information collected and disclosed, the right to delete, the right to correct, and the right to opt out of certain disclosures that may be considered “sale” or “sharing” under applicable law. Where applicable, you also may have the right to limit the use and disclosure of Sensitive Personal Information.

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To exercise your rights, please contact us as described in the Contact Us section. We may need to verify your identity before fulfilling requests. Where we act as a processor on behalf of a Customer, we will direct you to the applicable Customer and/or reasonably assist that Customer in responding to your request.

 

Non-Discrimination—We will not discriminate against you for exercising your privacy rights. In some cases, the nature of the product or service may differ depending on whether (or to what extent) you provide Personal Information; however, where this occurs, there is generally a direct relationship between the product/service and the Personal Information required to provide it.

 

Children’s Privacy

Children are not permitted to use the Sites. “Child” means individuals (i) in the United States under age 13; (ii) in the European Union under age 16; or (iii) in other jurisdictions under the applicable minimum age. We do not knowingly collect Personal Information from Children without appropriate authorization.

 

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make material changes, we will place a prominent notice on the affected Site(s) or send a notice to the email address associated with your account, as appropriate. The “Last Updated” date at the top of this Policy indicates when it was last revised.

 

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us:

By email: info@smartercollaboration.com
By mail: Smarter Collaboration International, Inc
61 Park Ave
Newton, MA 02458
USA

If you are located in the EEA/UK, you may also have the right to lodge a complaint with your local data protection authority.