SIY Global, PBC Privacy Policy
Last Updated: June 1, 2026
Introduction
SIY Global, PBC (“SIY Global,” “we,” or “us”) respects your privacy. This Privacy Policy explains who we are, what personal information we collect, how and why we use and share it, how long we keep it, and the rights and choices available to you. If you have questions or a complaint about this Policy or our practices, please contact our Data Protection Officer at DataProtectionOfficer@siyglobal.com.
SIY Global provides digital and instructor-led leadership development programs, assessments, and program evaluation and research services, grounded in emotional intelligence and our Emotional Dynamics model, for leaders and employees of client organizations. This Privacy Policy applies to personal information collected through the websites, platforms, and services where it is linked or referenced (the “Sites” and “Services”).
We use personal information only for the purposes described in this Policy, including delivering training programs and assessments, conducting program evaluation and research for our clients, enabling participant communication through our learning platform (HumanizedWork.com), and communicating with customers and prospects about our services.
Our role. When we deliver programs, assessments, or evaluation studies to employees of a client organization, we process personal information on behalf of, and under the documented instructions of, that client. In that role we act as a “processor” under the EU and UK General Data Protection Regulations (“GDPR”) and as a “service provider” or “processor” under U.S. state privacy laws, and the client’s privacy notice also applies; we refer requests about that information to the client where appropriate. When we operate our own websites, marketing, newsletters, events, and business relationships, we act as a “controller” (or “business”) and this Policy governs.
Compliance with International Laws
We process personal information in accordance with the data protection laws that apply to the processing, which may include the GDPR and U.S. state privacy laws. We maintain procedures to honor individual rights requests and to detect, assess, and report personal data breaches as those laws require.
Purpose and Scope
This policy applies to all personal data processed by SIY Global, including data collected through cookies and ad tracking on its website, responses to assessments, and any other information related to the training experience, measurement of emotional intelligence, focus, concentration, and performance. The data is processed to coordinate and deliver training programs, enhance customer records, and conduct marketing activities, among other purposes, where required by law (for example, for visitors in the EEA and UK), we obtain consent before placing non-essential cookies or advertising trackers.
Commitment to Data Privacy
SIY Global is unwavering in its commitment to safeguarding your information and respecting your rights, requiring every service provider and sub-processor that receives personal information to protect it under written data processing terms. A current list of our sub-processors is available on request. We have a structured incident response plan in place for any security breaches and maintain a Data Protection Officer responsible for ensuring privacy by design in products and compliance with relevant regulatory bodies.
Contact
For any inquiries or complaints related to data privacy, please contact our Data Protection Officer at DataProtectionOfficer@siyglobal.com or use the request form at https://www.siyglobal.com/contact-us.
Categories of Personal Information
Personal Information We May Collect About You As Part of our Services:
Identifiers
Personal Information Collected
- First Name and Last Name
- IP address
- Email address
- Description: These are basic identifiers that are collected to facilitate communication, account creation, and service delivery.
Information that Identifies or Relates to an Individual
Personal Information Collected
- Responses to assessments related to emotional intelligence, focus, concentration, and performance.
- Description: This information is collected as part of the training programs to assess the impact and effectiveness of the training provided by SIY Global.
Commercial Information
Personal Information Collected
- Marketing data
- Data subject request records
- Description: This includes records of interactions with SIY Global’s services, products considered, and other purchasing or consuming histories or tendencies to enhance customer records and conduct marketing activities.
Internet or Other Electronic Network Activity Information
Personal Information Collected
- User activity information obtained from cookies on SIY Global webpages and applications.
- Description: This information is collected to understand user interaction with SIY Global's website and services, enabling continuous improvement and personalized user experience.
Geolocation Data
Personal Information Collected
- Geolocation data obtained via:
- IP address
- Cookies
- Description:This data is used to provide localized services and content, and for troubleshooting and support services.
Audio, Electronic, Visual Information
Personal Information Collected:
- Audio and video recordings and transcripts (for example, recorded interviews, coaching, or program sessions), collected with notice to participants
- Description: This information is collected during interactions with SIY Global’s services and is used to facilitate communication and improve service delivery.
Note on Protected Classifications and Sensitive Information
SIY Global does not intentionally collect characteristics of protected classifications under California or federal law, genetic, or biometric information unless explicitly provided by the user for specific services or programs. Any such information provided unsolicited is not used as part of SIY Global’s standard data processing activities.
Data Security and Compliance
SIY Global is committed to ensuring the security of the collected information through various measures including SOC 2 certified platforms like Absorb LMS, HubSpot, and Google Workspace, and by conducting twice-yearly training on PII handling, implementing single sign-on, 2-factor authentication, and password change policies.
Consent and Rights
Depending on where you live and our role, you may have the right to access, correct, delete, restrict, or object to the processing of your personal information, and to data portability. See “How to Exercise Your Rights” below.
How Your Personal Information Is Collected
SIY Global collects personal information directly from individuals via our website, email, phone, and indirectly from enterprise clients who may provide us with your information in accordance with applicable employment or contractor agreements. SIY Global may also collect information:
- Directly from a third party;
- From your employer or the organization sponsoring your participation in a program or study;
- From cookies on our website; and
- Via our IT systems, including:
- Automated monitoring of our websites and other technical systems.
- Communication systems such as email and instant messaging services.
By posting personal information online that is publicly accessible, you may receive unsolicited messages from other parties in return. We are not responsible for the personally identifiable information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at DataProtectionOfficer@siyglobal.com.
How and Why We Use Your Personal Information
Under applicable data protection laws, SIY Global can only use your personal information if we have a proper reason for doing so, e.g.,
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or your employer or to take steps at your (or your employer’s) request before entering into a contract; or
- Where you have given consent.
- Where necessary for our legitimate interests or those of a third party (such as our client), provided those interests are not overridden by your rights and interests.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
What We Use Your Personal Information For & Our Reasons
- To provide products and/or services to you: For the performance of our contract with you or to take steps at your request before entering a contract.
- To verify identity & ensuring business policies are adhered to: To comply with our legal and regulatory obligations and for our legitimate interests to make sure we are following our own internal procedures so we can deliver the best service to you.
- Operational reasons, such as improving efficiency, training, and quality control: For our legitimate interests to be as efficient as we can so we can deliver the best service for you at the best price.
- Ensuring the confidentiality of commercially sensitive information: To protect trade secrets and other commercially valuable information and to comply with our legal and regulatory obligations.
- Statistical analysis to help us manage our business: For our legitimate interests to be as efficient and relevant as we can so we can deliver the best service for you at the best price.
- Preventing unauthorized access and alteration to systems: To prevent and detect criminal activity that could be damaging for us and for you and to comply with our legal and regulatory obligations.
- Updating and enhancing client records: For the performance of our contract with you and to comply with our legal and regulatory obligations.
- Ensuring safe working practices, staff administration, and assessments: To comply with our legal and regulatory obligations and for our legitimate interests to make sure we are following our own internal procedures and working safely so we can deliver the best service to you.
- Marketing our services to existing and former customers: For our legitimate interests to promote our business to existing and former clients.
- External audits and quality checks: To respond to client security and privacy reviews and audits and to comply with our legal and regulatory obligations.
Use of Collected Information
SIY Global collects information at several points on the Sites and Services, such as program registration, assessments, surveys, interviews, and event sign-ups. SIY Global’s assessments and program data are used for leadership development and program evaluation. They are not designed or offered for hiring, promotion, or other employment decisions about individuals, and we provide assessment, survey, and interview results to client organizations only in aggregate or de-identified form.
Summaries of de-identified or anonymized and aggregated data analyses may be presented to public audiences. Review of SIY Global’s general approaches and accumulated results with professional audiences ensures that SIY Global's assessment methods remain up to date with best practices and professional, technical, and legal standards. While these summaries may be linked to general industries, the identities of client organizations and individuals remain completely confidential.
Summaries of aggregated data may also be used to create normative profiles (or “benchmarks”) for assessments. Normative profiles will not identify individuals or client organizations; however, the source data may link back to some or all the client organizations that are contained within the data set for the purpose of defining the characteristics of the norm sample (such as platform, industry, etc.). We do not include a client’s data in benchmarks where our agreement with that client excludes it.
Research and Program Evaluation Studies
When a client engages SIY Global to evaluate its programs, for example through an impact study or needs assessment, we act as the client’s processor or service provider. We follow the study protocol agreed with the client, including any institutional review board (IRB) determination the client obtains. In these studies:
- We collect only the information the study needs. When we receive a client’s HR or outcome data, we ask for it de-identified or pseudonymized, and the client keeps any key that links records to individuals.
- Participation in surveys and interviews is voluntary. Participants are told how their responses will be used, and interviews are recorded only with notice and consent.
- Results are reported in aggregate or de-identified form, and we do not report results for any group of fewer than five people.
- Study data is used only for that study. We do not use it for benchmarking or any other purpose unless the client agrees in writing.
- Study data is kept separate from other client data, is accessed only by the named study team, and is returned or deleted at the end of the study as set out in our agreement with the client.
- When we co-author publications or presentations with a client, we publish only aggregate or de-identified findings.
Use of Artificial Intelligence
We use AI-enabled tools for activities such as developing program content and analyzing de-identified or aggregated data. We do not enter personal information into AI tools, and the tools we use are configured so that our data is not used to train their models. We do not use AI to make decisions that produce legal or similarly significant effects on individuals. Where a client agreement restricts the use of AI tools for its data, we follow those restrictions.
Third Party Use of Personal Information
Online Surveys:
SIY Global's third-party online survey provider collects and stores user information securely on behalf of SIY Global to manage online surveys. This provider allows SIY Global to create surveys and questionnaires for distribution to potential survey respondents. No information is shared with other third parties.
Newsletter Subscriptions:
SIY Global’s third-party newsletter publishing service provider manages email newsletter subscriptions securely on behalf of SIY Global. This information is owned by SIY Global and is not accessible to any other third parties. Users may opt-out by following the opt-out instructions included in each communication.
Online Customer Service Chat:
SIY Global's third-party online customer service chat service provider collects and stores user information securely on behalf of SIY Global to manage online chat sessions. Users engage in a live question and answer session with an SIY Global employee. Our third-party online customer service chat service provider maintains dialogue transcripts of these chats. No information is shared with other third parties.
Tracking Technologies:
Our third-party business service provider uses cookies to link visits to our site with click-through from pay-per-click sponsored ads. Technologies such as cookies or similar technologies are used by SIY Global and our marketing partners on some of our Sites. This Privacy Policy covers the use of cookies by the Sites and does not cover the use of cookies by any third parties.
Advertising:
We engage a third-party ad network to either display advertising on our Sites or to manage our advertising on other sites. If you do not want to have this information used for serving you interest-based ads, you may opt out through the cookie settings on our Sites or at https://optout.aboutads.info.
Sale and Sharing:
SIY Global does not sell personal information for money. Some advertising cookies or pixels on our Sites may be considered “sharing” of personal information for cross-context behavioral advertising, or “targeted advertising,” under certain U.S. state laws. You can opt out through our cookie settings, and our Sites honor Global Privacy Control (GPC) browser signals as an opt-out request.
Promotional Communications:
- SIY Global may use your personal information to send you updates about our products and services, including exclusive offers, promotions, new products, and/or suggested services. You have the right to opt-out of receiving promotional communications at any time by:
- Using the “unsubscribe” link in emails or “STOP” number in texts; or
- By email at: DataProtectionOfficer@siyglobal.com;
Testimonials:
SIY Global may post customer testimonials on our Sites, which may contain personal information. We do obtain the client's consent via email prior to posting the testimonial. If you wish to have your personal information removed from this section of our site, please contact us at DataProtectionOfficer@siyglobal.com.
Personal Information Disclosed to Vendors
In the preceding 12 months, we have disclosed to vendors the following categories of personal information:
- Identifiers such as first and/or last name, email address, IP address, and other similar identifiers.
- Commercial information such as products or services purchased, obtained, or considered.
- Internet or other electronic network activity information such as browsing history, search history, and information regarding interaction with an Internet Web site, application, or advertisement.
- Geolocation data.
- Assessment, survey, and program evaluation responses, and audio or video recordings, processed by our learning platform, hosting, and productivity providers on our behalf.
SIY Global's Data Management and Security
Data Storage and Processing:
SIY Global stores and processes personal information in the United States, using service providers that maintain SOC 2 Type 2 or ISO/IEC 27001 certified environments. Access is limited to authorized SIY Global personnel who need it to perform their work. Where a contracted facilitator outside the United States must access personal information to deliver services, we use appropriate transfer safeguards. Where a client agreement requires that data remain in the United States, or be accessed only by U.S.-based personnel, we honor that requirement.
Data Retention:
SIY Global retains personal information as long as the account is active or as needed to provide services, and for up to 5 years post user inactivity. Post this period, the data is either deleted or anonymized unless it is required to resolve disputes, enforce agreements, or comply with legal obligations. Where we process personal information on behalf of a client, we retain and delete it as set out in our agreement with that client.
Data Transfer:
Personal information collected in the European Economic Area, United Kingdom, or Switzerland is transferred to the United States. For these transfers we rely on the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, and Swiss equivalents, or on a recipient’s certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, as applicable.
User Rights:
Depending on where you live, you may have rights under the GDPR or U.S. state privacy laws, including the right to know about and access, correct, delete, or port your personal information; to restrict or object to processing; to opt out of targeted advertising, sale, or sharing; and to appeal our decision on your request. We will not discriminate against you for exercising these rights.
Data Security:
SIY Global requires its sub-processors to maintain appropriate security measures, and we select providers with independent SOC 2 Type 2 or ISO/IEC 27001 attestations. Our privacy practices are informed by ISO/IEC 27701. We use commercially reasonable administrative, technical, and organizational safeguards, including encryption in transit and at rest and multi-factor authentication, to protect personal information from unauthorized access, loss, or misuse. Access to personal information is restricted to personnel who need it to perform their job functions, and they are bound by confidentiality obligations.
Responsibility:
Users are responsible for maintaining the confidentiality of their usernames and passwords for sites where they have a user account. In case of any confidentiality breach, users should contact DataProtectionOfficer@siyglobal.com.
Communication:
If we become aware of a security breach affecting personal information that we control, we will notify affected individuals and regulators as required by law. Where we act as a processor or service provider, we will notify the affected client without undue delay, and within any period set in our agreement with that client (typically 48 hours), so the client can meet its own notification obligations.
How to Exercise Your Rights
To exercise any rights described in this Privacy Policy, please contact us in one of the following ways:
- Complete a data subject request form: https://www.siyglobal.com/contact-us
- Email: DataProtectionOfficer@siyglobal.com
- Postal Mail:
Important Notes:
- CCPA or CPRA-related data access or data portability disclosure requests can be made twice within a 12-month period.
- Verification of identity is required, and any information collected for verification will solely be used for verification purposes.
- You may use an authorized agent to submit a request on your behalf, with proof of authorization. If we decline your request, you may appeal by replying to our decision, and we will respond within the time required by applicable law.
Filing a GDPR Complaint:
If unsatisfied with the resolution, you have the right to lodge a complaint with a supervisory authority in the EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred, or, in the United Kingdom, with the Information Commissioner’s Office.
Service Announcements
Service-related announcements are mandatory, and users may not opt-out of these communications as they are not promotional in nature.
Changes to Privacy Notice
SIY Global reserves the right to amend this privacy notice and will notify users by posting a notice on the Sites or emailing prior to the change becoming effective.
Choice/Opt-out
Where we rely on your consent, you may withdraw it at any time by contacting DataProtectionOfficer@siyglobal.com. Withdrawal does not affect processing that occurred before it. You may continue to use our Sites, although some Services may not be available without certain information.
Transfer or Assignment
In events like mergers or acquisitions, user information may be transferred to third parties, subject to this Policy, unless a new privacy policy is adopted by the successor entity.
Consent to Marketing
If you submit a contact form, we will use your information to respond to you. We send marketing emails to business contacts based on our legitimate interests or, where required by law (for example, in the EEA, UK, or Canada), with your opt-in consent. Every marketing email includes an unsubscribe link.
Protection of Children’s Information
Our Sites and Services are intended for adults and are not directed to children under 16. We do not knowingly collect personal information from children under 16; if we learn that we have, we will delete it.
Links
SIY Global is not responsible for the privacy practices of external sites linked to the Sites.