Thank you for visiting performance to Potential. We respect your privacy and are committed to protecting your personal information. The following policy applies to all information collected by us in the process of conducting our business.

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1. Information Collected

• Personally-Identifiable Information (“Personal Information”): information that identifies you, such as your name, phone number, email address, mailing address, job title, or organizational affiliation. Performance to Potential and our service providers only collect Personal Information when you or someone in your team submits such information for the purposes of your participation in one of our programs. We may collect Personal Information over the phone, in email, through a face-to-face conversation, or through online and offline forms that you populate. 

• Confidential information: information that you provide regarding your opinions and feedback on own or team’s attitudes and behaviors, or your opinions and feedback on other individual’s attitudes and behaviors. Additionally we may request strategy documents and other contextual information necessary to do our work, protected by non disclosure agreements with our clients.

 

2. Purposes of Collection

We use your personal information and confidential information as follows:

• We use your personal information to coordinate meetings or send information.

• We use confidential information to prepare diagnostic reports that participants use as part of a personal, team or organizational development process and for no other purposes. These reports are also confidential. Unless they are individual diagnostic reports, they do not contain personal data. The data collected is anonymized and aggregated for analytical purposes and shared with the individual or team undergoing the process. Individual feedback reports are provided to the individual, the internal program coordinator for printing and handling purposes and/or the participant's assigned coach (internal or external). Group-level reports are provided to the internal program coordinator, the consultant (internal or external), and/or to the individual team members.

 

Sharing

We may share your Personal Information as follows:

• We may share information with those who need it to do work for us, like third-party vendors who conduct specialized quantitative behavioral assessments.

• We may share personal information for legal, protection, and safety purposes.

• We may share information to comply with laws.

• We may share information to respond to lawful requests and legal processes.

• We may share information to protect the rights and property of Performance to Potential, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.

• We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

 

Some of the ways we use your Personal information require us to share information with third parties, so we can provide an effective service and comply with laws that apply to us:

• Service Providers. Third party companies that we engage to process information on our behalf based on our instructions and in compliance with this Privacy Policy.  Some information we acquire may be collected by third party providers on our behalf.  For example, when you complete a self or other assessment. These data are compiled in another trusted third-party database and customer relationship management tool.

• Law enforcement agencies or government agencies. We only share information if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Connor; or to detect, prevent, or otherwise address fraud, security or technical issues.

 

Retention

We keep your Personal Information only so long as we need it to fulfill the purposes described in this policy or as per our service agreement with our client companies. When we no longer need to use your Personal Information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that you cannot be identified.

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3. Your Choices

Notice & Choice

Performance to Potential collects Personal Data for the purposes stated above and utilizes it in the manners specified above. Where we collect personal information directly from individuals we inform them of the purposes for which we collect and use it.

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The individual providing data will have the choice, in writing, to opt out if we propose (A) to disclose personal data to a 3rd party or (B) to allow the personal data to be used for a purpose that is materially different from the purpose for which the data were originally collected.

 

Data Integrity and Purpose Limitation

We will only use Personal Data in ways that are consistent with the purposes for which it was collected or subsequently authorized by the individual. To the extent necessary for those purposes, we will take reasonable steps to ensure that Personal Data is accurate, complete, current, and relevant for its intended use.

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Accountability for Disclosure to Third Parties

Performance to Potential does not disclose, sell, share, trade or give away an individual’s Personal Data to third parties, except under one or more of the following circumstances:

• The disclosure is to another affiliated entity or to persons or entities providing services on our or the individual’s behalf consistent with the purpose for which the information was obtained. These affiliated entities, persons or entities providing services on our or the individual’s behalf include individual, team or organizational automated assessment providers, as well as other third party vendors that support us in handling information (like printing stores). In these cases of onward transfer, we review the third-party’s privacy policy and make sure it shares the same level of security as the present policy.  We may request to have a non-disclosure agreement signed. We also obtain our client’s consent to use these vendors depending on each case.   

• We have the individual’s written authorization to make the disclosure.

• The disclosure is required by law or professional standards.

• The information is publicly available.

• The disclosure is reasonably necessary for the establishment or defense of legal claim.

• The disclosure is reasonably related to the sale or disposition of all or part of our business.

• Performance to Potential is liable for appropriate onward transfers of personal data to third parties.

 

International Transfers

Permitted transfers of information include the transfer of data from one jurisdiction to another. Because privacy laws vary from one jurisdiction to another, Personal Data may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated. By providing personal or confidential information to us or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, which may provide for different data protection rules than in your country. Where required, we implement appropriate cross-border transfer solutions to provide adequate protection for transfers of personal information.

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Right to Access and Correct or Delete Personal Data

Individuals have the right to access their personal data to review, correct or delete it. If an individual wishes to gain access to their personal data they may contact Maria Ferrante at maria@performncetopotential.com.

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Before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and to provide other details, including Personal Data, to help us to respond to your request. The completion of the request will take a reasonable amount of time, not to exceed five business days and will be responded in writing. No individual will be allowed to review or modify another individual’s information.

 

4. Security

We use appropriate and reasonable administrative, physical, and technical measures to safeguard Personal Information controlled by us. Only employees who need the information to perform a specific job are granted access to personally identifiable information.

 

5. Linked websites

Our Site may contain links to other websites. We are not responsible for the privacy practices or the content of such websites.

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As part of the Site or Services, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us the Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Site or via our Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

Performance to Potential, with its partnership and commitment to Security and Privacy with Microsoft, also provides a link to their Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement 

 

6. Changes to this Privacy Policy

We reserve the right to modify or supplement this policy at any time. Any changes to the policy will be posted on this page. 

 

7. Enforcement and Dispute Resolution

We utilize the self-assessment approach to assure compliance with our privacy statement. We periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles.

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We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.

 

8. Questions

Inquiries or complaints regarding this privacy policy should be directed to:

Maria Ferrante, DPO, maria@performancetopotential.com

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