Privacy Policy – PrinciplesUs

PRIOS, LLC Privacy Policy

Last Updated May 13, 2024

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 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.

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, directly or indirectly, 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

Log Information such as information related to your access to and use of the Services, including the search strings you enter, media you view or interact with in our Services, the type of browser you use, app version, access dates and times, pages viewed, your IP address, and the page you visited before navigating to our Services;
Device information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information; and
Other information collected by cookies, web beacons and similar tracking technologies. Cookies are small data files stored on your hard drive or in device memory that help us run analytics to improve our Services and your experience, track your preferences, see which areas and features of our Services are popular, and count visits. Where required by applicable law, such as in the European Economic Area (“EEA”) and the UK, we will only set non-essential cookies with your consent. Web beacons (also known as pixel tags or clear GIFs) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the “Your Choices” section below.

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:

Provide and maintain our Services;
Improve our Services, including to provide you with more relevant and personalized content;
Complete the transactions you request, perform our contractual obligations, and as otherwise anticipated within the context of our ongoing business relationship;
Create and manage your online accounts and profiles;
Identify and authenticate users and send technical notices, updates, security alerts, and support and administrative messages;
Respond to your comments, questions, requests and any other communications from you, including to provide customer service;
Communicate with you about products, services, opportunities and events offered by PRIOS and our partners, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
Monitor, audit and analyze trends, usage, and activities in connection with our Services;
Create de-identified, anonymized, or aggregated information;
Conduct internal research and development;
Detect security incidents and protect against illegal or objectionable activities, including the unauthorized use of the Services, and protect the rights and property of PRIOS and others;
Personalize your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, and browsing behavior;
Debug, identify and repair errors that impair existing intended functionality of our Services;
Comply with our legal obligations, including those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions;
Carry out certain short-term activities and other reasonable internal purposes related to the products or services you purchase from us or your ongoing relationship with us;
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; and
Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We share personal information as described below:

With vendors, service providers, and consultants that need access to such information to perform services for us, including storing information, authenticating users, sending transactional and promotional communications, and debugging, securing and improving our Services;
With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
If you use our Services as part of your work, we share certain personal information with your employer or business who has subscribed to our Services;
With other users of the Services if you participate in the interactive areas of our Services;
With law enforcement authorities and individuals involved in legal proceedings, in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements or if we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Principles or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
With our legal, financial, insurance and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of PRIOS’ business or operations;
With third parties, in connection with services you subscribe to, that require importing your personal information; and
With your consent or at your direction.

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

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 one hundred eighty (180) 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, including to meet our legal, regulatory, or other compliance obligations. 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; Data Privacy Framework

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, 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.

PRIOS complies with the EU-U.S. Data Privacy Framework (the “EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (the “Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. We also certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (the “EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. We also certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (the “Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (collectively, the “DPF Principles“), the DPF Principles shall govern. To learn more about the Data Privacy Framework program please visit https://www.dataprivacyframework.gov, and to view our certification, please visit https://www.dataprivacyframework.gov/list.

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/DPF-Dispute-Resolution 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 Data Privacy Framework 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 Data Privacy Framework or another appropriate safeguard, 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, to the extent permitted by applicable law.

Cookies

EEA/UK 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.

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 link in the footer on the homepage. 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.

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:

We share identifiers with email marketing service providers, data analytics providers, advertising networks, development partners, customer service providers, user authentication service providers, payment processors, technical support providers, internet service provider, operating systems and platform, data storage providers and cloud service providers.
We share internet and electronic network activity information with email marketing service providers, data analytics providers, advertising networks, technical support providers, internet service provider, operating systems and platform, data storage providers and cloud service providers.
We share commercial information with payment processors, data storage providers and cloud service providers.
We share visual information with user authentication service providers and data storage providers.
We share professional or employment related information with document parsing and indexing providers and data storage providers.
We share other information that we have derived or inferred about you or that relates to or is capable of being associated with you with development partners, data analytics providers, technical support providers, data storage providers, and cloud service providers.

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. 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.

Legal Basis for Processing

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:

To perform our responsibilities under our contract with you, for example when we provide the products and services you requested.
When we have your consent to do so. When your consent is the legal basis for our processing, you may withdraw such consent at any time.
When we need to use your personal information to perform our responsibilities under our contract with you, for example to provide the services you have requested.
When we have a legitimate interest in processing your personal information to provide you with a good user experience and protect and promote PRIOS. For example, we may process your personal information to respond to your questions or comments, to conduct internal research, to communicate with you about changes to our Services, and to secure and improve our Services.
When we find such processing is necessary to comply with our legal obligations, for example to maintain a record of your consents and those who have opted-out of promotional communications.

Data Subject Rights

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. 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.

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: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

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

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:

Sending an email to privacy@edpo.com
Using EDPO UK’s online request form at https://edpo.com/contact/
Writing to EDPO UK’s office: 8 Northumberland Avenue, London, WC2N 5BY, United Kingdom
Using EDPO EU’s online request form at https://edpo.com/contact/
Writing to EDPO EU’s office: Avenue Huart Hamoir, 71, 1030 Brussels, Belgium

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

Individuals in Canada

If you are in Canada, this section applies to you.

Access and Correction

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.

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