This Privacy Policy explains how PRIOS, LLC ("PRIOS", "we" or "us"), located at 25 Ford Road, Westport, Connecticut 06880, collect, use, disclose, retain and otherwise process information about you when you access or use our websites, mobile applications and other online products and services that link to this Privacy Policy (collectively, the "Services"), or otherwise interact with us.

Notwithstanding the foregoing, some of our Services are intended for use by organizations. If you are using our Services at the invitation of or through an account provided to you by your organization, our processing of your personal data in connection with that Service is governed by a contract between us and your organization. Your data will be accessible to and will be processed by your organization subject to their own policies, and you should direct your privacy inquiries, including any requests to exercise your data protection rights to your organization. We are not responsible for the privacy or security practices of your organization, which may differ from those set forth in this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review our Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Data Retention

Advertising and Analytics Services Provided by Others

Transfer of Information to the U.S. and Other Countries

Your Choices

Information for California Consumers; Your California Privacy Rights

Individuals in the European Economic Area (EEA) and the United Kingdom (UK)

Contact Us

COLLECTION OF INFORMATION

In this Privacy Policy, "personal information" means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal information. The types of personal information we collect about you depend on your interactions with us and are described in more detail below.

Information We Collect from You

We collect information directly from you in a variety of ways. For example, we collect information from you when you create an account, participate in any interactive areas of our Services, sign up to receive news, information or special offers from us, make a purchase from us, provide feedback or other submissions to us, fill out a form, participate in a contest or promotion, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.

The types of information we collect directly from you include your name, email address, job title and company name, grade point average or other academic qualifications, photos, ratings and attribute scores you provide, content you create, edit, save or tag, information about meetings or events you create or contribute to, test and assessment responses you provide, and other preferences you express when using the Services.

When you access or use our Services, we automatically collect information about you, including

Information We Collect from Others

We may also obtain information about you from other sources. For example, we may collect information such as ratings, dots and descriptions about you provided by other users of our Services. If you or your social media friends create, log into, or link a PRIOS account with a social media site, or use other features of our Services that integrate with social media sites, we may receive certain information such as your name and profile photo, in accordance with the authorization procedures determined by such social media site. We may also collect information, including demographic information (such as your gender and age range), from analytics providers and other third parties that provide us with information so we can better understand you.

Information We Infer

We may derive information or draw inferences about you based on the other personal information we collect about you. For example, based on the attribute scores or dots you receive through our Services, we may infer your strengths and weaknesses or how you rank with regards to certain attributes as compared to others in your group. We may infer your location from our collection of your IP address. We may also derive various insights from the information submitted by and about you through our Services.

USE OF INFORMATION

We use the information we collect for various purposes, including to:

SHARING OF INFORMATION

We share personal information as described below:

In certain instances, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

DATA RETENTION

To the extent permitted by applicable law, we store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. If you close your account with us, we will delete personal information about you within ninety (90) days. We also automatically delete accounts if a user has not interacted with our Services after two (2) years. Please refer to Your Choices below for information about how to delete your account and other choices available to you.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

PRIOS is based in the United States and we process and store information in the U.S. and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. When we transfer personal information from the EEA or the UK, we do so in reliance on an approved data transfer mechanism. We have also certified to the U.S. Department of Commerce that we adhere to its EU-U.S. Privacy Shield Framework in connection with our transfer to the United States of personal information that relates to individuals in the EEA and the UK. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield, we are committed to resolving complaints about our processing of your personal information. You may contact us about any questions or complaints regarding our compliance with the Privacy Shield program as indicated in the "Contact Us" section below. We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. PRIOS is subject to the investigatory and enforcement powers of the Federal Trade Commission. If we share personal information transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party's processing in violation of the Privacy Shield PRIOS, unless we can prove that we are not responsible for the event giving rise to the damage.

YOUR CHOICES

Account Information

You may update certain account information you provide to us at any time by logging into your account and adjusting your settings. If you no longer want us to process information about you, you can request that we delete your account through the customer support functions of our Services, but note that we may retain certain information as required by law or for legitimate business purposes, where permitted by applicable law. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies

EEA/UK users have a choice as to whether to accept non-essential cookies when you access our Services. We will only set non-essential cookies if you give us your consent.

You can manage cookies through the Cookie Settings accessible in the banner presented at the bottom or via the Cookie Settings link in the footer on the homepage. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy and the "Advertising and Analytics Services Provided by Others" section below.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, such as your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is used by PRIOS and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and mobile applications, and better understand your activity. For more information, please see our Cookie Policy. You can manage or block cookies based on your preferences by clicking on our Cookie Settings. In addition, to learn more about how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit http://www.aboutads.info/choices. For individuals in the EEA and the UK, please visit http://www.youronlinechoices.eu/. Your device may also include a feature ("Limit Ad Tracking" on iOS or "Opt Out of Interest-Based Ads" or "Opt Out of Ads Personalization" on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Promotional Communications

If you receive promotional emails from PRIOS, you may opt out at any time by following the instructions in those emails, or by contacting us at legal@principles.com. If you opt out, we may still send you non-promotional emails, such as those about your account or updates to our user terms or policies.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

INFORMATION FOR CALIFORNIA CONSUMERS; YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to disclose the following information with respect to our collection, use, and disclosure of personal information.

In the preceding twelve (12) months, we have collected the following categories of personal information: identifiers; internet or other electronic network activity information; demographic information (note that some demographic information may be considered characteristics of protected classifications under state or federal law); professional or employment related information; education information; audio, electronic, visual, thermal, olfactory, or similar information; inferences; and other information that relates to or is reasonably capable of being associated with you. For examples of the precise data points we collect and the sources of such collection, please see Collection of Information above. We collect personal information for the business and commercial purposes listed in Use of Information above.

We may share your personal information with third parties as described in Sharing of Information above. In the preceding twelve (12) months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:

PRIOS does not, and will not, sell your personal information. As described in this Privacy Policy, we do permit our advertising partners to use cookies and other technologies to receive information about you in order to show you ads that are targeted to your interests. In order to opt out of this targeted advertising please see Advertising and Analytics Services Provided by Others above.

Subject to certain limitations, you have the right to (1) request to know more about the categories and the specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) opt out of any "sales" of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. Please note that we may retain certain information as required or permitted by applicable law. You may make these requests by emailing us at support@principles.com or visiting this page. If you would like to use an authorized agent registered with the California Secretary of State to exercise these rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA. We will verify your request by asking you to provide information about you that matches the information we already maintain. If you request to delete your personal information, some of our Services may no longer be available to you.

INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA) AND THE UNITED KINGDOM (UK)

If you are in the EEA/UK, you have certain rights and protections under the law regarding the processing of your personal information.

If you are in the EEA/UK, when we process your personal information we will only do so in the following situations:

Data Subject Requests

If you are in the EEA/UK, you have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or shared with another provider. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may do so by emailing us at support@principles.com or visiting this page. If you have created an account to access and use our Services, you may also update certain personal information by logging into your account.

Questions or Complaints

If you are in the EEA/UK and have a concern about how we process personal information, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

General Data Protection Regulation (GDPR) - European & UK Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as our GDPR representative in the EU and the UK. You can contact EDPO regarding matters pertaining to the GDPR by:

NOTE: please do not forget to mention that your request relates to “PRIOS, LLC.”

CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact us at: legal@principles.com or, where available, through "Contact Support" from within our mobile applications. You can also write to us at:

PRIOS, LLC
Attn: Legal
25 Ford Road
Westport, Connecticut 06880