Last Updated August 17, 2023
Information We Collect from You
We collect information directly from you in a variety of ways. For example, we collect information from you when you create an account, participate in any interactive areas of our Services, sign up to receive news, information or special offers from us, make a purchase from us, provide feedback or other submissions to us, fill out a form, participate in a contest or promotion, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.
The types of information we collect directly from you include your name, email address, job title and company name, grade point average or other academic qualifications, photos, ratings and attribute scores you provide, content you create, edit, save or tag, information about meetings or events you create or contribute to, test and assessment responses you provide, and other preferences you express when using the Services.
When you access or use our Services, we automatically collect information about you, including
Information We Collect from Others
We may also obtain information about you from other sources. For example, we may collect information such as ratings, dots and descriptions about you provided by other users of our Services. If you or your social media friends create, log into, or link a PRIOS account with a social media site, or use other features of our Services that integrate with social media sites, we may receive certain information such as your name and profile photo, in accordance with the authorization procedures determined by such social media site. We may also collect information, including demographic information (such as your gender and age range), from analytics providers and other third parties that provide us with information so we can better understand you.
Information We Infer
We may derive information or draw inferences about you based on the other personal information we collect about you. For example, based on the attribute scores or dots you receive through our Services, we may infer your strengths and weaknesses or how you rank with regards to certain attributes as compared to others in your group. We may infer your location from our collection of your IP address. We may also derive various insights from the information submitted by and about you through our Services.
We use the information we collect for various purposes, including to:
We share personal information as described below:
In certain instances, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.
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.
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. 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.
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 or 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 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.
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 email@example.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.
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:
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 firstname.lastname@example.org. 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.
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:
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 email@example.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:
NOTE: please do not forget to mention that your request relates to “PRIOS, LLC.”
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 firstname.lastname@example.org. 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.
1 Nyala Farms Road
Westport, Connecticut 06880