Mobius Executive Leadership LLC – Privacy Policy

Last Updated: May 14th, 2024

INTRODUCTION

Mobius Executive Leadership, LLC, along with its subsidiaries and affiliates (collectively, “Mobius,” “we,” “us,” or “our”) is a premier professional services firm dedicated to providing transformational leadership development programs, skills training, immersive retreats, executive coaching and other related programs and services (collectively, the “Services”).

This Privacy Notice describes the information collection, use, retention and sharing practices we use when you interact with us online through our website, www.mobiusleadership.com (the “Website”) or in-person, by phone or videoconference, such as when you participate in the Services.

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

PERSONAL INFORMATION WE COLLECT, FOR WHAT PURPOSES, HOW WE USE IT AND HOW LONG WE RETAIN IT

We collect your personal information either in connection with the Services, if you register for one of our events or related to your interaction with our Website or social media pages. As described below, we collect this information either from you, from third parties (such as your employer) or by automated means.

Personal Information Collected in Connection with Events or the Services

If you register yourself or your organization for one of our programs or events, we collect from you or your employer: (i) personal identifiers, such as your name and email address; (ii) professional/employment related information, including job title, and company name; and (iii) sensitive financial information if you provide a credit or debit card to register for such event.We use this information to communicate with you regarding the event, finalize your registration and process your payment, if applicable.We retain this information so long as it is needed to process your registration and note that we only retain the cardholder name and the last 4 digits of the card.

If you receive or participate in our Services, we collect from you, your employer, our alliance partners, as well as through our research of publicly available sources (including organizational or corporate websites, LinkedIn profiles and other social media): (i) personal identifiers, such as your name, and email address; (ii) professional/job related information, including job title, company name, details of your personal and professional background and education (including that found in your professional bio), career aspirations, and development goals; (iii) demographic and biological data; (iv) visual information, such as your headshot; (v) sensitive personal information, which may include health or mental health conditions, contained in responses to interview questions, questionnaires or pre-work conducted by you in advance of the Services; and (vi) any other information you share with us, or our subcontracted practitioners, during your receipt of the Services. We use this information to provide the Services according to contractual requirements, communicate with you prior to and following the Services and to tailor the Services to fit your needs, if applicable.We retain this information only for so long as it is necessary to provide the Services and conduct any follow-up communications.

When you participate in our events or receive the Services, to the extent the General Data Protection Regulation (“GDPR”), Regulation (EU) 2016/679, and the UK Data Protection Act 2018 (“DPA”) apply to you or your employer, our role in connection with the data that we process is that of an independent controller.

Personal Information Collected When You Interact With Our Website or Social Media Pages

If you contact us via our Website or subscribe to our mailing list to receive newsletters, publications, alerts, announcements and other communications, we collect from you personal identifiers, such as your name, email address, phone number, and professional/employment related information such as your company name and any other personal information contained in your correspondence, if any.We use this information to respond to your questions or inquiries, to troubleshoot where necessary and to send you updates and editorial content. You may unsubscribe at any time by clicking the “unsubscribe” link included with each newsletter we send you. Our emails include a tracking pixel that tracks whether you open the email and whether you click banners in the email and your subsequent clicks and usage of our Website. We use this information to send you additional email communications which may be of interest to you, as based on your interaction with our emails and/or Website. You can avoid downloading the pixel by rejecting the download of images in the email. We retain this information indefinitely until you notify us of your desire to opt out of receiving such communications.

If you interact with our social media pages on social networking websites, such as Facebook, X, and LinkedIn, (each a “Social Media Page” and collectively, “Social Media Pages”), we collect your name, profile picture, basic engagement metrics and other information you provide such as comments, likes, sharing or rating. To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in advertising our Services via our Social Media Pages and communicating with users, customers, and interested parties. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Facebook, X, and LinkedIn use your personal information, please see Facebook’s Privacy Notice, X’s Privacy Notice, and LinkedIn’s Privacy Notice.When using direct message capabilities on the Social Media Pages (such as Facebook messenger), the applicable Social Media Page collects, automatically, your IP address, date and time of the server request, time zone, specific browser or app function, access status, amount of data transferred, browser or app from which the request comes, device type, operating system used, and its interface (e.g. Android or IOS), language, version of the operating system, and device identifiers. We do not use this information; its use is governed by the applicable Social Media Page’s Privacy Notice. Additionally, Facebook, X, and LinkedIn process personal information in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal information.

In addition to the personal information you provide directly to us, we also collect information by automated means as you interact with our Website, including your Internet Protocol (“IP”) address, unique device identifier, geolocation data, country, browser, device operating system, application version, language settings and information about your use of the Website.When you access our Website via a mobile device, we collect information regarding the type of device, unique device identifier, IP address, operating system, the type of mobile browser used and other diagnostic data.Our Website uses small text files and data files including cookies and other tracking technologies such as pixels, server logs, and web beacons (the “Tracking Technologies”) to gather information about your usage patterns when you navigate the Website to personalize and enhance your experience; understand how visitors generally use our Website; improve the Website; prevent fraudulent use of the Website; diagnose and repair Website errors, and, in cases of abuse, track and mitigate the abuse.We also allow certain trusted partners to place cookies on our Website to collect information about how you interact with the Website and other websites you visit.

We use HubSpot Analytics to recognize and count the number of people who visit the Website and collect information on how users engage and interact with the Website.To collect this information, HubSpot Analytics installs cookies on your browser or reads cookies that are already there.We do not combine the information collected through the use of HubSpot Analytics with personal information.For more information on HubSpot Analytics, please see HubSpot’s Privacy Policy.You can disable cookies through your individual browser settings.Please note that if you disable cookies, some of our Website features may not function properly or at all.If you are a California resident and wish to opt out, please visit Manage My Cookie Preferences.

We only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described below.

DATA RETENTION

Unless otherwise stated in this Privacy Notice, we retain your personal information until we no longer need your information to fulfill the purposes for which we collected it or until we receive a valid request to delete the information, subject to certain exceptions.However, we may need to use and retain your personal information for longer than the periods indicated above for purposes of:

Compliance with our legal and contractual obligations. For example, retaining your records for the purpose of accounting, dispute resolution, and compliance with labor, tax, and financial regulations.
Meeting our safety and security commitments. Such as preventing fraud.
Exercising or defending legal claims. We also may need to retain personal information for longer than the periods indicated above in order to respond to legal process or enforceable governmental requests, or to enforce our contracts, including investigation of potential violations.

HOW WE SHARE YOUR PERSONAL INFORMATION

Mobius shares personal information as described above, and generally, as follows:

Within Mobius. We share your personal information with our personnel across our global organization, on a need-to-know basis, for the legitimate business purposes of efficiently and effectively providing the Services.
With third parties.We also share your personal information, on a need-to-know basis, with third parties, including our agents, contractors, subcontractors, service providers who process, store and track information on our behalf, such as information technology providers,and business affiliates and partners, with whom we engage or collaborate to perform the Services or other functions on our behalf. Only the information necessary to perform a specified business function will be disclosed, said third parties are subject to confidentiality requirements and are prohibited from using the personal information for any purposes other than providing the services to us.
In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
Where legally required. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of use or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.
Protection.We share personal information to protect the rights, property, life, health, security or safety of Mobius, the Services, the Website or its users, our business partners or any third party or if we believe your actions are inconsistent with our applicable policies.
With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time by emailing us at HubSpot’s Privacy Policy.

Cross Border Transfers

Because Mobius is a global organization, we may need to transfer, store or process your personal information in countries that do not provide the same level of protection as the data protection laws of your home country.Personal information we collect may be transferred to and processed in the United States and be subject to United States law.We take appropriate steps, where required, to provide appropriate safeguards for such personal information, including, without limitation, standard data protection clauses adopted or approved by the European Commission.

Sharing in the Last Twelve (12) Months

For a business purpose. In the preceding twelve (12) months, Mobius has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

We have disclosed your identifiers to service providers that assist us in providing the Services. These service providers assist us with the following: information technology (“IT”) support; data hosting; data analysis; customer relationship management; mailing; email delivery; professional services (lawyers, bankers, insurers, auditors, accountants); purchase and payment; research and reporting; video/phone system; web analytics; and coaching and instruction providers.
We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Website and platform errors.
We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to update, improve, and maintain the Website and platform.

Sale of Personal Information

In the preceding twelve (12) months, Mobius has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics/advertising providers as described in PERSONAL INFORMATION WE COLLECT, FOR WHAT PURPOSES, HOW WE USE IT AND HOW LONG WE RETAIN IT. If you are a California resident and wish to opt out, please visit Manage My Cookie Preferences.

DO NOT TRACK

We do not respond to Do Not Track requests.Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

SECURITY PROTOCOLS

Mobius has in place generally accepted and appropriate technical and organizational security processes designed to protect personal information from unauthorized access, loss, misuse, alteration, or destruction.Only authorized employees and contractors are permitted to access personal information, on a need to know basis.Each individual having access to any personal information is obligated to treat it as confidential. To the extent that we disclose personal information to third party providers, we require that such providers also maintain appropriate security and confidentiality measures and use the personal information in accordance with applicable law.However, although we take steps that are generally accepted as industry standard, no security measure or modality of data transmission is 100% secure, and we cannot guarantee the absolute security of the personal information we have collected from you.If we learn of a security system breach, we will attempt to notify you so that you can take appropriate protective steps.

LINKS TO THIRD-PARTY WEBSITES

The Website may contain links to other third-party websites or services that are not operated or controlled by Mobius.We are not responsible for the content of or privacy and data collection practices of any non-Mobius websites to which we link from the Website and cannot control the content or security of such websites.We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites.No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.We encourage you to review the privacy practices or notices posted on those third-party websites for further information.

YOUR INFORMATION CHOICES AND RIGHTS

You have the following choices with respect to your personal information:

Unsubscribe from newsletters and marketing communications. You may opt out of receiving newsletters or marketing emails from us by clicking the “unsubscribe” link included with each newsletter or provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to perform the Services.
Opt out of email tracking. You can disable this tracking by blocking automatic loading of images in your email.
Correct or view your personal information. You may send an email to security@mobiusleadership.com to correct or view certain personal information of yours in our possession.
Opt out of analytics and interest-based advertising. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our Website may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all interest-based advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

- Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
- European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
- In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent.

RIGHTS OF DATA SUBJECTS IN THE EUROPEAN UNION AND UNITED KINGDOM

Individuals in the European Union and United Kingdom are entitled to certain rights under General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”), respectively. To the extent these laws apply to our processing of your personal data, you are entitled to the following rights:

Right to access. For any of the processing described above, you have the right to ask us for copies of your personal data. However, this right has some exemptions, which means you may not always receive all the personal data we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), or certain instances of ongoing or prior negotiations with the requestor, among others.
Right to rectification. For any of the processing described above, you have the right to ask us to rectify personal data you think is inaccurate or incomplete.
Right to erasure. When we use cookies and other trackers, send you marketing emails, or process your personal data collected from an event that you attended, you have the right to request erasure of your personal data that we are not obligated to keep in some cases (also known as the right to be forgotten). For example, you can request us to delete your personal data if: (i) we no longer need the data for the purpose it was collected for, or (ii) we process the data based on your consent and you revoke your consent.
Right to restrict processing. For any of the processing described above, if you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need your personal information for a specific purpose, you have the right to request that we restrict the processing of this personal information. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of your personal data while we make our assessment.
Right to object to processing. You have the right to object to our processing of your personal data when the legal basis for the processing is pursuant to our legitimate interests by referencing your personal circumstances. This may apply, for example to processing in connection with our Social Media Pages.
Right to data portability. You have the right to ask that we transfer the personal data you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal information to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means. You can invoke this right for the processing of the information we automatically collect from you as you interact with the Website via cookies, pixels, and similar tracking technologies. This may also apply in connection with your account information.
Right to lodge a complaint. You have the right to lodge a complaint with the relevant Supervisory Authority.

These rights may be exercised by contacting us as security@mobiusleadership.com.We may request certain information from you to help us confirm your identity prior to processing your request.Upon receipt of your request to exercise your rights, we will acknowledge receipt within the time period required by applicable law and provide you with information about the next steps in the process.

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

Residents of California may be entitled to additional rights and protections which are set forth below.

RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, “CCPA”) entitles California residents to certain rights. To the extent the CCPA applies to our processing of your personal information, you have the following rights:

Right to access/know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort.
Right to deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
Right to correct. You have the right to correct inaccurate personal information that we collect or maintain.
Right to opt out of sale/sharing. You have the right to opt out of the sale or sharing of your personal information to third parties. Mobius does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years.
Right to non-discrimination. You have the right to not receive discriminatory treatment if and when you exercise your privacy rights under the CCPA.
Right to limit use of sensitive personal information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. However, Mobius does not process sensitive personal information in a manner which gives rise to this right.
Right to data portability. You have the right to ask that we transfer the personal information you gave us, to you, or in certain cases, directly to another organization, in a format that is easily understandable and to the extent technically feasible, in a structured, commonly used, machine-readable format. However, you may exercise this right no more than two times per calendar year.

If you are a California resident and wish to exercise your privacy rights, you may submit a request via email to security@mobiusleadership.com, via webform, or by calling toll-free 888-492-1423. Please indicate your state of residence upon submission of your request. To opt out of the sale/share of your information through cookies, please visit Manage My Cookie Preferences.

We may request certain information from you to help us confirm your identity prior to processing your request.Upon receipt of your request to exercise your rights, we will acknowledge receipt within the time period required by applicable law and provide you with information about the next steps in the process.

NOTICE FOR NEVADA RESIDENTS

Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as defined under Nevada law) to a person who in turn licenses or sells such information to another person. We don’t currently sell or provide your personal information in this manner. To opt out of the sale of your personal information in the future, you may submit a request to us via email to security@mobiusleadership.com. Proof of identification may be required before such a request is granted.

CHILDREN

Mobius understands the importance of protecting the privacy of children, particularly in their online interactions.This Website is not designed for and does not intentionally target or solicit to children aged 18 or younger.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US

If you have any questions or concerns regarding this Privacy Notice, please contact us by email at security@mobiusleadership.com, or send a letter to:

Mobius Executive Leadership LLC
Attention: Legal Department
35 Highland Circle, 2^nd Floor
Needham, Massachusetts 02494