Privacy Policy

Effective Date: 5/01/22

SIY Global, PBC and its affiliated entities (“SIY Global,” “we,” or “us”) are committed to respecting your privacy and protecting your personal information, whether you are a client, customer, potential customer, or other user of our web services (collectively, “you”). This Privacy Policy explains the types of personal information we may collect from visitors to our websites, including [] and all related websites, mobile apps, and web-based services (our “Sites”). This Policy also describes how we use personal information, the purpose for sharing and recipients of personal information, and your available rights and choices associated with that information.

This Privacy Policy does not apply to third-party websites, products or services, even if they may link to our Sites or our Sites may link to them. We recommend you review the privacy practices of those third parties before connecting or accessing third party websites and sharing any personal information.

We also encourage you to review our Terms of Use to understand how your personal information will be treated as you make full use of our Sites. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

This Privacy Policy is provided in a layered format. You can jump to a specific section by clicking on the section below:

1. Collection of personal information - We collect certain personal information about you when you engage us for services over our websites or otherwise use our websites. We may also automatically collect information regarding your use of our sites as you use them.

2. Use of personal information - We use your personal information for various purposes connected with your interest in our websites and services, and to allow us to maintain and improve them.

3. Sharing of personal information - We may share your personal information with certain third parties, such as with our service providers and to provide you with opportunities that we believe may be of interest to you.

4. Your rights and choices - You may have certain rights and choices regarding our collection, use, and disclosure of your personal information.

5. Data security - The security of your personal information is of utmost importance to us and we maintain appropriate safeguards to protect it.

6. Cookie policy - When you visit our websites, we may collect certain information from you automatically through cookies and other tracking technologies.

7. Children’s privacy - You must be at least 18 years old or older to use our sites.

8. International data transfers - Our websites are operated exclusively in the United States.

9. European Privacy Notice - We provide additional disclosures and rights to individuals located in Europe.

10. Links to other websites - Our websites may contain links to other websites that are not operated by us and that are subject to third party privacy policies and other terms.

11. Changes to this Privacy Policy - We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws.

12. Contact us - You may contact us for comments or questions in various ways.

1. Collection of Personal Information

For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through our Sites will be apparent by the context of the page, and may include but is not limited to the types of information described below.

a. Personal information you provide to us

We may collect the following personal information about you that you choose to provide us when you use our Sites:

  • Program registration information: When you register for one of our programs, you may be asked to provide your first and last name, email address, home address, job title, company name, demographic information, program-related assessment data, and other information about you.

  • Email newsletter and contact information: When you sign up for our email newsletter, you may be asked to provide your first and last name, email address, and country of residence. If you wish to contact us via one of our web contact forms, including to contact a Client Advisor, you may be asked to provide your first and last name, email address, company name, job title/function, and country of residence.

  • The Learning Hub If you sign up for a Learning Hub account, you may be asked to provide your email address, phone number, and create a password.

  • Payments: If you register for a program, you may be required to provide your payment card or bank account information and your billing address, or your account information for one of our third party payment platforms such as PayPal.

  • Promotions: Certain promotions for SIY Global products and services may require you to provide us with your email address, telephone number, and other information about you.

b. Information that we automatically collect

Our Sites use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (“Cookies”), which collect information from you automatically as your use our Sites, including:

  • Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and

  • Usage data, such as geolocation data, browsing history, time spent on the Sites, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Site.

We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. For example, some of our community websites may use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.

Please review our Cookie Policy below for more information about our use of these technologies.

c. Aggregated, anonymized, and deidentified information

We may create aggregated, anonymous or de-identified data from personal information by removing data components that make the data personally identifiable to you or through obfuscation or other means. Our use of aggregated, anonymized and de-identified data is not subject to this Privacy Policy.

2. Use of Personal Information

We may use the personal information that we collect about you in the following ways:

a. Our products and services

We use the personal information we collect to provide the products and services that SIY Global offers to its clients and customers, as well as to provide, maintain, and improve our Sites and the products and services that SIY Global offers through them (together, our “Services”). This includes:

  • Providing you with requested Services, including our online programs;

  • Providing you with customer service and support, and facilitating other communications that you request or that are required to provide Services to you;

  • Processing payments and refunds;

  • Facilitating and supporting our community features;

  • Providing you with information about new Services and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;

  • Performing analytics for new and existing Sites, such as our user accounts and related features;

  • Maintaining and improving the quality of our Sites;

  • Growing our business, including to perform research and development, understanding our customer trends, and understand the effectiveness of our marketing;

  • Protecting ourselves, you, and others; prevent fraud and other unlawful or unauthorized activity; and create and maintain a trusted, secure, and reliable online environment; and

  • Complying with our legal obligations; respond to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defense against legal claims.

b. Digital marketing communications

We may send you promotional email communications about SIY Global, invite you to participate in events or promotions, or otherwise communicate with you for marketing purposes, consistent with your preferences and applicable law. For example, when you provide your email address to join our email newsletter, or when we otherwise collect your contact information through your interaction with our Sites, we may use that information to follow up with you regarding an event or send you information that you have requested about SIY Global or our third party partners. You may opt out of receiving any, or all, of these marketing communications from us via the unsubscribe link provided in such emails or by following further instructions provided in Your Rights and Choices.

3. Sharing of Personal Information

We may share your personal information with the following categories of third parties:

a. Among our affiliates.

We may share personal information among our various affiliates, which may include Search Inside Yourself Leadership Institute (the “Institute”), to provide our Sites, provide the Services, and for internal business and administrative purposes. Specifically, if you have an existing relationship with, or have previously requested services from, the Institute, we may continue sharing your personal information with the Institute consistent with your engagement with them.

b. Our service providers.

We share personal information with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use the information for any other purpose.

c. Other business partners.

We may share personal information with third-party business partners in connection with our Site and Services. For example, we may share personal information with partners about whom you have requested more information from.

d. Third-party platform advertising.

We may share your information with third-party platform providers who assist us in serving advertising regarding the Sites and Services to others who may be interested. We also partner with third parties (such as Twitter) who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.

e. Affiliate and business transfer.

If SIY Global, including any of its affiliates, is involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity. If such transfer results in a material change to the use of your personal information, we will provide notice before your personal information is transferred and/or becomes subject to a different privacy policy.

f. Compliance and harm prevention.

We may share personal information as we believe necessary (i) to comply with applicable law, rules and regulations; (ii) to enforce our contractual rights; (iii) to investigate possible wrongdoing in connection with the Sites and Services; (iv) to protect and defend the rights, privacy, safety and property of SIY Global, you, and others; and (v) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.

4. Your Rights and Choices

You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact Us section at the end of this Policy.

a. Opting out of receiving electronic communications from us.

If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or by submitting a request using the information in the Contact Us section. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Services or for other reasons disclosed in this Policy.

b. Your California privacy rights.

We do not disclose personal information to third parties for their own direct marketing purposes. However, because California residents have the right to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information Contact Us section. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond. “Personal information” under this California law means any information that identified, described, or was able to be associated with an individual at the time of disclosure.

c. Your Nevada privacy rights.

Nevada residents have the right to request to opt out of any “sale” of their personal information. SIY Global does not sell your personal information. However, you may nonetheless request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please contact us using the information in the Contact Us section at the end of this Policy, and provide “Nevada Privacy Rights” in the subject line. You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.

d. Your European privacy rights.

Individuals located in the European Economic Area, United Kingdom, and Switzerland have certain rights with respect to our collection, use, and sharing of their personal information. Please review our European Privacy Notice for more information about those rights.

5. Data Security

The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we use reasonable practices and procedures to protect your personal information, we cannot guarantee its absolute security. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.

6. Cookie Policy

Cookies are text files placed on your computer to collect standard Internet log information and visitor information. When you visit our Sites, we may collect information from you automatically through Cookies. We also rely on partners to provide many features of our Sites using data about your use of the Sites. We use Cookies for the following purposes:

  • Necessity: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. Learn more about necessary cookies.

  • Preference: To allow us to remember your preferences and identify you when you return to our Sites.

  • Analytics: These cookies help us to understand how visitors engage with the website. We may use a set of cookies to collect information and report site usage statistics. In addition to reporting site usage statistics, data collected may also be used, together with some of the advertising cookies described, to help show more relevant ads across the web and to measure interactions with the ads we show. Learn more about analytics cookies.

  • Advertising: We use cookies to make our ads more engaging and valuable to site visitors. Some common applications of cookies are to select advertising based on what’s relevant to a user; to improve reporting on ad campaign performance; and to avoid showing ads the user has already seen. Learn more about advertisement cookies..

  • Social Media: To enable the sharing of content from our Sites through social networking and other sites.

  • Functionality: We use a set of cookies that are optional for the website to function. They are usually only set in response to information provided to the website to personalize and optimize your experience as well as remember your chat history. Learn more about functionality cookies.

You can modify your browser settings to decline or accept Cookies. However, in a few cases, some of our Sites’ features may not function as designed.

If you wish to opt out of our sharing of the data that is gathered when you visit our Site for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements. You may also visit these websites for more information on how you can opt back into the sharing of data.

Opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Sites or on other websites.

We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

7. Children’s Privacy

You must be at least 18 years old or older to register for or use our Sites and the Services offered through them. The Sites are intended for a general audience and we do not knowingly collect personal information from children under age 18 through the Sites.

If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us using the information in the Contact Us section. If we become aware that we have collected personal information from children under age 13 without verification of parental consent, we will take steps to remove that information from our servers.

8. International Data Transfers

Our Sites are operated in the United States with support provided by teams in certain other third countries including India. We may transfer, store and use information we collect and maintain about you, including personal information outside of your state, province, country or other governmental jurisdiction. The data protection laws in the jurisdiction in which we process personal information may differ from those of your jurisdiction, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions. By using the Sites or providing us with any information, you consent to the transfer and processing of your information, including personal information, in the United States as set forth in this Privacy Policy.

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we comply with any applicable laws to provide an adequate level of data protection to the U.S., as described further in European Privacy Notice. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use EU Standard Contractual Clauses set out in the annex to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (“Model Clauses”) with data recipients located outside the EEA, the UK, or Switzerland as well as other appropriate measures and safeguards.

9. European Privacy Notice

This European Privacy Notice applies to any individuals located within the EEA, UK, or Switzerland from whom we may have collected personal data from any source, including through your use of our Sites, Products, and Services. We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, access, rectification, erasure, restrict processing, data portability and to object with respect to collected personal data. For the purposes of this European Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.

a. Basis for processing your personal data

SIY Global relies on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our terms of use; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.

Legitimate business interests. We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.

While our legitimate interests are most extensively detailed in Section 2 of our Privacy Policy, they generally include:

  • Provide, improve, and develop our Sites and Services, including to deliver your requested Services including our programs, communicate with you and provide user support, customize the Sites to better fit your needs as a user, develop new Services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.

  • Protect you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable Sites and Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various Sites, content you submit to the Sites, and information obtained from third parties.

  • Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

b. Your privacy rights

In certain circumstances, individuals located within the EEA, UK, and Switzerland are entitled to the following data protection rights regarding their personal data:

  • Right to access. You have the right to request confirmation of whether SIY Global processes personal data relating to you, and if so, to request a copy of that personal data.

  • Right to rectification. You have the right to request that SIY Global correct or update your personal data that is inaccurate, incomplete or outdated.

  • Right to erasure. You have the right to request that SIY Global erase your personal data in certain circumstances provided by law.

  • Right to restrict processing. You have the right to request that SIY Global restrict the use of your personal data in certain circumstances.

  • Right to object to processing. You have the right to object to SIY Global’s processing of your personal data, under certain conditions.

  • Right to data portability. You have the right to request that SIY Global export the data that we have collected to you or another company, under certain conditions.

Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time. If you would like to exercise any of these rights, please submit a written request using the information in the Contact Us section below. We will respond to these requests in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

You may also have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority. You can view the contact information for your data protection authority here.

10. Links to Other Websites

Our Sites may contain links to other websites that are not operated by SIY Global. We strongly suggest you review their privacy policies. If any linked website is not owned or controlled by us, we are not responsible for its content or privacy policies, or the practices of the operator of the website or services.

11. Changes to This Privacy Policy

We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Sites. If we make any material changes to this Privacy Policy, we will take reasonable measures to notify you via email and/or a prominent notice on our Sites prior to the change becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

12. Contact Us

If you have any questions about this Privacy Policy or wish to exercise one of your privacy rights, please contact us using the following information: