Privacy Policy – updated

This Privacy Policy Statement (“Statement”) explains how Partners in Leadership,
LLC d/b/a Culture Partners (“Partners,” “we,” “us,” “our,” or the “Company”) collect,
handle, store and protect personal information about you in the context of our
services and various product offerings.

1. What We Do:

Partners provides Accountability Training and Culture Change consulting services to
corporate customers. Our corporate customers in turn, share access to Partners’
proprietary materials with their employees or other approved representatives. The
corporate customer decides on how best to utilize Partners’ proprietary materials
within the terms of its agreement with us. If you are granted access to our services
by one of our corporate customers and would like to know about the data use
practices of the company or other organization that provides access to Partners’
proprietary materials to you, please contact such organization.

2. To Whom This Statement Applies and What It Covers:

This Statement applies to any individual who uses any Partners’ website(s),
application, including mobile application (“app”), product, software, and/or service
of ours that hyperlinks to this Statement (these are our “Services”). This Statement
also applies to live interactions with individuals such as via customer service, live
seminars, or physical mail.

3. Sources of Personal Information Collected:

We collect personal information about you from your interactions with us and from
certain third parties and other sources (such as your employer or the subscriber
providing access to our Services or from publicly available sources where

When you register for a course, webinar, seminar or online tool, you provide us
information about the organization you are affiliated with (our corporate customer),
your name and business contact information and certain other profile information
that we ask of you. We process your information for authentication purposes, to
verify your eligibility to access Partners’ proprietary materials, to deliver Partners’
proprietary materials to you and to send you information about our terms, our
Services and other Partners’ proprietary materials that we believe may be
interesting to you. If you contact us with questions or respond to our emails, you
may be disclosing additional information to us.

When you access Partners’ proprietary materials online, we also receive information
about your device, software, usage times and locations. Our browser-based app
version also places cookies as necessary to provide functionality to you. When you
attend ‘live’ seminars, at our locations, our registration personnel collect
information about your attendance and you may be recorded by security cameras.
We process usage information to deliver, improve and optimize our Partners’
proprietary materials, to protect you, us and other users from fraud and misuse,
and to determine what information, features, promotional information, and other
services you need or may be interested in.

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If you submit any personal information relating to anyone other than yourself, you
represent that you have obtained any necessary consent from that individual for
use and disclosure of that individual’s personal information as described in this

4. Your Personal Online Company ID:

To sign up for and to log on to Partners’ various web services, you will be requested
to create a unique identification password and username. This convenient service
saves you time and allows for easier use of our web services. You will need to
create a personal profile by providing your name, phone number, email address,
and in some cases your mailing address. Our system saves this information in your
personal profile and assigns you your own unique personal login which you can use
when performing various activities.

If applicable, subscribers may be asked for a billing address and/or a credit card
number. This information is passed on to our payment processor, Stripe, and is not
saved by our system. You may review Stripe’s privacy practices here.

5. Why We Collect Personal Information:

We collect your personal information to provide our Services or materials you have
requested. When you access Partners’ proprietary materials online, we receive
information about your device, software, usage times, and usage locations. When
you attend ‘live’ seminars, at our locations, our registration personnel collect
information about your attendance. You may be recorded by security cameras,
owned and operated by some venues and subject to the privacy practices of such
venues. We do not have access to such images. We process usage information to
deliver, improve, and optimize our Partners’ materials; to protect you, us and other
users from fraud and misuse; and to determine what information, features,
promotional information, or other services you need or may be interested in. We
may use contact information provided by you to communicate about information,
features, promotional information, or other services you have requested to may be
interested in. You may submit an opt-out request to suppress such communications
by contacting us via one of the methods below.

Information you provide may be used to help us respond to your customer service
requests or support needs more efficiently.

We may use your contact information to respond to inquiries, questions, and/or
other requests. The email address may also be used to send notifications of
changes to our Services or these terms or data collected.

Our Services may use “cookies” to enhance your experience. Your web browser
places cookies on your hard drive for record-keeping purposes and sometimes to
track information about you. You may choose to set your web browser to refuse
cookies, or to alert you when cookies are being sent. If you do so, note that some of
our Services may not function properly.

6. How We Protect Your Personal Information:

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The Company takes precautions—including administrative, technical, and physical
measures—to safeguard your personal information against loss, theft, and misuse,
as well as unauthorized access, disclosure, alteration, and destruction.

Our online services use Secure Sockets Layer (SSL) encryption for communications
and to make online purchases you must use an SSL-enabled browser in order to
protect the confidentiality of your personal and credit card information while it is
transmitted over the internet. You can help us by also taking precautions to protect
your personal data when you are on the internet. Do not share your account or login
information. Change your passwords often using a combination of letters and
numbers, and make sure you use a secure web browser.

While we make efforts to ensure the integrity and security of our network and
systems, we cannot guarantee that our security measures will prevent third-party
“hackers” from illegally obtaining your personal information.

7. When We Would Disclose Your Information:

We do not disclose your individual registration or usage data to third parties, except
as follows:

  •  With the company, organization, or subscriber that provides you with access to
    Partners materials or other content or services requested.
  • With your consent. If we have relied on your consent, you may have the right
    to revoke your consent for the use of your personal information and you
    can request that we no longer use your personal information by sending
    an e-mail to
  • With service providers all over the world that help us deliver our Services or
    materials requested by you subject to confidentiality agreements.
  • We share aggregated usage statistics.
  • As required by law or to protect you, other users, us or third parties from harm,
    including fraud, data security breaches or where someone’s physical safety may be at risk.
  • In a reorganization or sale of our Company or assets, your data may be
    transferred, subject to the acquirer accepting the commitments made in this
    Statement and compliance with applicable law.

Without such information being made available, it would be difficult for you to
purchase products, have services provided to you, receive customer service,
provide feedback, or access certain services, offers, and content on our web site.

8. Links to Sites and Services of Other Companies:

Within our Services, there may be links to third-party websites or applications. We
are not responsible for the content or privacy compliance of third-party websites or
applications. You should check those websites or applications for their privacy
statements and terms that apply to them.

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We use third party companies and individuals to facilitate our Services. Such third
parties may have limited access to your personal information in order to perform
tasks (e.g., security detection, communication, storage, or web analytics) on our

9. Storing and Managing Collected Information:

We will retain information collected for the longer of as necessary to perform the
subscription or service agreement for the subscriber or organization providing your
account and to comply with our legal obligations, resolve disputes, and enforce our
agreements. If you would like to review the personal identification information we
have collected from you via our Services or if you would like us to delete personal
identification information that you have provided via our Services, please contact us
in writing using the contact information below and we will respond to verifiable
requests within a reasonable time or as required under applicable law(s). Data
subject rights vary under applicable law and rights do not apply to individuals in all

10. Privacy Information for California Residents:

For privacy rights and practices applicable to California residents, please click here.

11. Privacy and Visitors Outside the United States:

If you reside outside the United States, please be aware that by interacting with the
site you are transferring information collected and/or provided via the site from your
country to the United States. You consent to have your information transferred,
processed, and stored in the United States and under United States privacy
standards. The information may be transmitted onwards to a representative
authorized to represent Partners in your country. The representative may be outside
the United States but obligated to treat any information received consistent with
this Statement.

If your organization or subscriber is outside the United States, transfers of personal
information may be governed by specific agreements to provide adequate
protections for your data in such jurisdictions. Please inquire with your organization
or subscriber to determine whether and which terms apply to your account.

If you are in the European Economic Area, the United Kingdom, or Switzerland, see
EEA+ disclosures here.

12. Further Questions:

You can opt out of marketing messages, set your communication and privacy
preferences, or submit other requests at any time by contacting us using the
contact information below. Under the laws in your country, you may have a right to
access personal information about you, to correct such information and to request
the deletion of your personal data in accordance with applicable law. You may also
be entitled to object to certain data processing activities or to revoke consent
previously granted, to the extent permitted by local law. Such requests may be

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submitted for review, verification, and appropriate action using the contact
information below.

13. Effective Date; Updates to Privacy Policy:

The terms and conditions in this Statement and related links are valid as of your
visit today. We reserve the right to revise, amend, or modify this Statement at any
time and in any manner. When we change the policy in a material way, we will
provide a prominent notice such as by posting a notification on the main page of
our web site or sending a message to the email address associated with your
profile. Your use of our Services after any such changes are implemented
constitutes your acknowledgement and acceptance of these changes. Please
consult this Statement prior to every use for any changes.

14. Contacting Us:

If you have any questions about this Statement, our privacy practices, or your
interactions with our Services, please contact us:

  1. By mail to: Privacy Agent, c/o Culture Partners, 2555 Ynez Rd., Ste. 200,
    Temecula, CA 92591
  2. By email to
  3. By internet at
  4. By telephone at (800)-504-6070

Culture Partners