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 information 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 for its own purposes. For this reason, 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.
Advertising and Analytics Services Provided by Others
Transfer of Information to the U.S. and Other Countries
Information for California Consumers; Your California Privacy Rights
Individuals in the European Economic Area (EEA) and the United Kingdom (UK)
Individuals in the Kingdom of Saudi Arabia (KSA)
Individuals in the United Arab Emirates (UAE)
In this Privacy Policy, "personal information" means any information, regardless of its form, that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify, directly or indirectly, a natural person 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.
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 or any other data you provide us with.
When you access or use our Services, we automatically collect information about you, including
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.
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.
We use the information we collect for the following purposes:
We share personal information as described below, for purposes listed under the Use of Information section above:
In certain instances, we may also share aggregated or de-identified information that cannot reasonably be used to identify you. PRIOS processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
We store personal information associated with your account, for purposes listed under the Use of Information section above, for as long as your account remains active. If you close your account with us, we will delete personal information about you within ninety (90) days. To the extent permitted by applicable law, we store other personal 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 (if this legal basis is applicable in your jurisdiction), including to meet our legal, regulatory, or other compliance obligations. 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.
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.
Where required by applicable laws, when we transfer personal information outside of the country in which you reside, we do so in reliance on appropriate safeguards and approved data transfer mechanisms, such as by executing Standard Contractual Clauses. Where relevant, you may contact us as specified below to obtain a copy of the safeguards we use to transfer your personal information. 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/.
We are committed to resolving complaints about our processing of your personal information. You may contact us about any questions or complaints as indicated in the "Contact Us" section below. 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 JAMS, an alternative dispute resolution provider located in the United States, or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. You may also file a complaint with the local data protection authority in your jurisdiction.
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 or under another appropriate safeguard 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 or under another appropriate safeguard, unless we can prove that we are not responsible for the event giving rise to the damage.
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, to the extent permitted by applicable law.
EEA/UK, Turkey, KSA, and UAE users have a choice as to whether to accept non-essential cookies – namely marketing and profiling cookies (including analytics, when used for or in connection with such purposes) – 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.
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/. For individuals in Canada, please visit AdChoices, the Canadian self-regulatory program for online interest-based advertising, administered by the Digital Advertising Alliance of Canada (“DAAC”). 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.
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.
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.
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.
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 as a controller we will only do so in the following situations:
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 applicable, you may also have the right to give general and specific instructions on the fate of your personal information after your death.
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. Please note that there are exceptions and limitations to each of these rights, and that we may not be required to comply with your request.
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: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Pursuant to Article 27 of the 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.”
If you are in Canada, this section applies to you.
Upon your written request, and subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal information and give you access to that information. We may charge a minimal fee for providing such access to you. If you believe that the personal information that we hold about you is not accurate or complete, you may write to us at support@principles.com. If you are able to establish that the information is not accurate or complete, we will take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. In order to facilitate a request to correct or update information, we may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by us.
If you are in Israel, this section applies to you.
You are not legally obligated to provide any personal information to us, and any personal information that you choose to provide to us, is provided at your own free will. However, if you choose not to provide such information, we may not be able to provide our Services to you.
When we process your personal information as a database owner, we will only do so based on your consent or as required under applicable law.
You have certain rights and protections under applicable law regarding the processing of your personal information. If you would like to exercise any of these rights, you may do so by emailing us at support@principles.com.
If you are in Turkey, this section applies to you.
Personal information is transferred in line with the Law on Personal Data Protection numbered 6698. By using our Services, you consent to the transfer of your information to the U.S.
If you are in Turkey, when we process your personal information as a controller, we will only do so in accordance with the Law on Personal Data Protection numbered 6698 based on the following legal basis:
Pursuant to the Law on Personal Data Protection numbered 6698, you have the following rights and protections regarding the processing of your personal information.
If you would like to exercise any of these rights, you may do so by emailing us at support@principles.com.
If you are in the Kingdom of Saudi Arabia, this section applies to you.
Your use of our Services shall constitute an approval of the applicable Privacy Policy at the moment of your use of our Services.
If you are in the Kingdom of Saudi Arabia, when we process your personal information as a controller we will only do so in the following situations:
If you are in the Kingdom of Saudi Arabia, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, completed, or destroyed whenever such personal information is no longer needed. You may also have the right to request obtaining your personal information in a readable and clear format.
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. Please note that there are exceptions and limitations to each of these rights, and that we may not be required to comply with your request.
If you are in the United Arab Emirates, this section applies to you.
If you are in the United Arab Emirates, when we process your personal information as a controller we will only do so in the following situations:
If you are in the United Arab Emirates, you may have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, completed, or destroyed whenever such personal information is no longer needed. You may also have the right to request obtaining your personal information in a readable and clear format.
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. Please note that there are exceptions and limitations to each of these rights, and that we may not be required to comply with your request.
We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you are in the UAE, please contact the UAE Data Office.
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