This statement was last updated on May 23, 2018

Our commitments to protecting your privacy

This Marketing Privacy Statement describes how the Center for Creative Leadership® (“CCL”) collects, uses, and discloses information CCL collects through www.ccl.org, solutions.ccl.org (eCommerce), the myCCL web portal service, and other affiliated sites that link to this Marketing Privacy Statement (collectively, “the Websites”). Currently, these other affiliated sites are:

  • www.toxicbosses.org
  • www.kicksomeglass.com (coming)
  • www.experiencedrivendevelopment.com/
  • www.ccl-explorer.org

CCL is committed to respecting and protecting the privacy of our constituents. CCL subscribes to the American Psychological Association’s code of ethics regarding the use of an individual’s personal data for research; this code is particularly concerned with protecting the rights of the person. CCL is also a strong supporter of the privacy rights of data subjects as spelled out in the European Union’s General Data Protection Regulation and is committed to working with data subjects, controllers, processors, and Supervisory Authorities to implement all of the provisions of the Regulation.

Who is “responsible for processing”? Who is the Data Privacy Officer (“DPO”) and preferred contact person?

Center for Creative Leadership, 1 Leadership Pl, Greensboro, NC 27410, USA and its European representation — Center for Creative Leadership, rue Neerveld 101-103, 1200 Brussels, Belgium — are responsible for processing your personal data available to them. This means that we, CCL, determine the purposes and means of processing of this data, and that we are your interlocutor and that of the supervisory authorities (the Belgian Data Protection Authority and the other European supervisory authorities) for any questions relating to its use.

If you have a question about our processing or would like to exercise one of your rights set out below, please contact our Data Protection Officer by e-mail (privacy@ccl.org) or by mail (DPO, Legal Department, rue Neerveld 101-103, 1200 Brussels, Belgium).

Scope

CCL is based in the United States and maintains its servers in the United States; consequently, the data of those using our services from regions outside the United States will be transferred to the United States for processing.

By using our websites and providing personal information to us through our websites, email, or other marketing communications:

  1. You acknowledge you have read and agree to this Marketing Privacy Statement.
  2. To the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by CCL and any third-party recipients in accordance with this Marketing Privacy Statement; and
  3. You are also agreeing to comply with our CCL Community Rules, which are incorporated herein by reference.

If you become a participant in any of CCL services, some sites that you access within the Websites, including within your myCCL account, may be governed by a Privacy Statement for participants that differs from this one and/or contain additional information as required under applicable law. Please refer to the applicable Privacy Statements on the sites you visit in order to understand how they collect and process your data.

In this Marketing Privacy Statement, your information is sometimes called “personal data” or “personal information”. We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information.

Third-party links

Our Websites may link to third-party sites that are not controlled by CCL and thus do not operate under CCL’s privacy practices (i.e. attending/promoting external events, event partnerships, social media). When you visit third-party sites, CCL’s privacy practices no longer apply. Please review each third-party site’s privacy policy before disclosing any personally data.

Collection of personal information

When you use our Websites, we may collect information about you and your use of the relevant site, including through cookies and analytics tools.  We may collect personal data about you — such as your name, job title, company name, address, email address, and telephone number — either directly from you or by combining information we collect via the Websites with personal information we collect and maintain through other means (such as e-commerce system, client relationship management systems, or identification and access management systems, including IP addresses), or as we may receive from social media or other third-party sites.

Below are some examples of how you may provide personal information to CCL:

  • searching and browsing for leadership content;
  • subscribing to or ordering newsletters and/or publications;
  • registering for online services such as myCCL;
  • participating in “sign up for newsletters”;
  • participating in discussion or message forums through linked websites;
  • entering a Leading Insights panel survey;
  • registering for leadership events and conferences;
  • contacting us for further information;
  • visiting our Websites while logged into a social media platform;
  • participating in blog discussions and making comments;
  • Searching or buying publications or other products, or communicating with customer service, and in doing so, you might supply us with such information as your name, address, and phone numbers; credit card information; people to whom purchases have been shipped, including addresses and phone number; content of reviews and e-mails to us; and other financial or identification information such Social Security and driver’s license numbers.

We do not request to collect sensitive information through the Websites unless we are legally required to do so. Due to some open-field questions, we ask that you do not provide sensitive information of this nature when using the Websites. If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this Marketing Privacy Statement or as described at the point where you choose to disclose this information.

We also do not actively seek demographic information from visitors to the Websites. However, you may choose to provide such information (including, for example, when becoming a Registered myCCL Member, visiting our site from a social media site, or submitting a resume though LinkedIn or CCL’s job portal). If you choose to provide demographic information to us, the act of doing so constitutes your explicit consent, where such consent is necessary and valid applicable law, for us to collect and use that information in the ways described in this Marketing Privacy Statement or as described at the point where you choose to disclose this information.

We will collect only the minimum information required to complete your request and we will not use it further for any other purpose.

Registered myCCL Member

If you choose to become a Registered myCCL Member, as part of the registration process you will be asked to provide us with personal information through a registration form. Information we collect may include your name, email address, password, country, organization, job title, and leadership interest preferences. Some of the information is required, and if you do not provide it, you will not be able to register and receive the benefits of being a Registered Member. We have marked with an asterisk (*) those registration fields seeking information that you must provide in order to become a Registered Member. We will do the utmost to limit such required.

As a Registered myCCL Member, you shall be responsible for providing us with accurate information about you and for keeping that information up to date. You may update your information at any time by editing your user profile in your myCCL account.

Once you are a Registered myCCL Member, we may combine the information you give us as part of the registration process with information initially provided through your profile. As a Registered myCCL Member, all of the data you provide as part of registration may be tied back to the information we collect or have previously collected about you through your use of the Websites.

Why do we collect your personal data?

When you provide personal information to us, or when we collect it, we may use it for any of the purposes described in this Marketing Privacy Statement including:

  • to administer and manage the Websites, including to confirm and authenticate your identity and prevent unauthorized access to restricted areas of the site, premium content, or other services limited to Registered myCCL Members;
  • to sort and analyze user data (such as defining user browsing behavior criteria);
  • to determine the company, organization, institution, or agency that you work for;
  • to conduct benchmarking and data analysis including, for example, usage of the Websites and demographics analyses of their users;
  • to understand how you use the features and functions of our Websites in order to improve the user experience;
  • to review, analyze, publish blog discussion groups and comments;
  • to fulfill your orders for any publications or other products, respond to your requests, customize future shopping for you, improve our stores, and communicate with you;
  • any other purposes for which you provided the information to CCL, including any of the purposes given in the “What data do we collect ” section above.

Our Websites do not collect or compile personal data for sale to non-CCL parties for consumer marketing purposes.

Note that when you participate in a blog discussion or make comments, and/or share a picture or story about leadership development (e.g. photo of an inspirational scene or an anecdote about a toxic boss or teamwork), this content is called “User Provided Content.”  By submitting User Provided Content through any of our websites or otherwise communicating with us, you grant CCL a sub-licensable, worldwide, royalty-free license to host, store, copy, publish, distribute, provide access to, create derivative works of, and otherwise use such User Provided Content to the extent and in the form or context we deem appropriate on or through any media or medium and with any technology or devices now known or hereafter developed or discovered. This includes the right for CCL to copy, display, and index your User Provided Content. CCL will own the indexes it creates. We will also have the right to continue to use your User Provided Content, even if you stop using the CCL websites.

If you would like to find out more about the different categories of information we collect on the Websites, please review the “Collection of personal information” section.

Personalized Communication for Registered myCCL Members

If you choose to become a Registered myCCL Member, we may also use your information for the following purposes:

  • to provide you with information about us and our services including via personalized marketing messages and/or communications unique to your organization about our products and services;
  • to invite you to attend events, participate in forums, etc.;
  • any other specific purposes for which you provided the information to CCL.

Which legal grounds do we use to process your personal data?

We process your data for various purposes. For each type of processing, only the data relevant to achieving the purpose in question is processed.

We rely on one or more of the following processing conditions:

  • your explicit consent via an opt-in form to receive communications from CCL. With your consent, CCL will electronically send you newsletters containing commercial information about new services and products, promotions, and benefits;
  • our legitimate interest in the effective delivery of information and services to you, in which case we seek to preserve a proportionate balance between our legitimate interest and respect for your privacy. For instance, we way use legitimate interest to continuously improve our website and our products/services (in particular by conducting satisfaction surveys and analyzing data collected via cookies), answer information request forms, or prevent abuse and fraud;
  • to satisfy any legal and regulatory obligations to which we are subject;
  • to perform our obligations to provide and track the products or services purchased.

How do we protect your data?

CCL is committed to maintaining the confidentiality and security of your data and to implementing appropriate security measures to prevent the loss, destruction, misuse, unintentional modification, or disclosure of your data:

  • by updating security measures as the technology evolves, as needed;
  • by ensuring that your data are not accessible to unauthorized persons;
  • by requesting a proof of identity before being able to provide you with any personal information about you as part of the security procedures; and
  • by performing periodic back-ups and storing this data on secure servers.

Our websites have security measures in place to protect the loss, misuse and alteration of the information under our control. CCL’s secure server encrypts all payment information, including name, address, credit card number, and expiration date. The encryption process takes all personal information and converts it into code that is securely transmitted over the internet using secure socket layer (SSL) technology.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by email) is never completely secure. We do the utmost to protect personal data, but we cannot guarantee the security of data transmitted to or by us.

Cookies

Learn more about cookies and how CCL uses them. https://www.ccl.org/cookies

Social media widgets

CCL’s Web sites include social media features, such as the Facebook “like” button, and widgets, such as the “share this” button or interactive mini-programs that run on CCL’s site. These features may collect IP addresses and record which pages are being visited on our site, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Interactions with these features are governed by the privacy policy of the company providing it.

Transfers of personal information

International transfers

Because CCL is a global American non-profit organization with branches and entities around the world, your personal information may be transferred to and stored outside the country where you are located. This includes countries outside the European Economic Area (EEA) and countries that do not have laws that provide specific protection for personal information. When we collect your personal information within the EEA, transfer outside the EEA will be only:

  • to a recipient located in a country which provides an adequate level of protection for your personal information; and/or
  • under a contract with the recipient of the data, which means the recipient must protect the data to the same standards as required within the EEA, such as standard contractual clauses approved by the European Commission.

The Center for Creative Leadership is organized in the United States of America as a 501 (c)(3) nonprofit academic and research institution. Because of this non-profit standing, CCL may not participate in the EU US Privacy Shield Framework as set forth by the U.S. Department of Commerce.

Third-party providers

We may transfer or disclose the personal data we collect to our CCL entities and to their vetted third- party contractors and subcontractors. When we transfer personal data, we do so for the purposes for which the information has been initially collected, for the administration and maintenance of the Websites and associated systems, and/or for other internal or administrative purposes. We also may transfer personal data to third-party service providers of identity management, website hosting and management, data analysis, data backup, security, and storage services.

The third-party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by CCL, and to flow those same obligations down to their sub-processors.

Other disclosures

We may also disclose personal information to third parties under the following circumstances:

  • when explicitly requested by you;
  • when required to deliver publications or reference materials as requested by you;
  • when required to facilitate conferences or events hosted by a third party;
  • for regulatory compliance purposes; and/or
  • as otherwise set out in this Marketing Privacy Statement.

CCL may also disclose personal information:

  • in response to lawful requests by public authorities, including to meet national security or law enforcement requirements or to comply with a subpoena, or similar legal process;
  • when it is believed in good faith that disclosure is necessary to protect our rights, protect others’ safety, investigate fraud, or respond to a government request;
  • if CCL is involved in a merger, acquisition, or sale of all or a portion of its assets, in which case users will be notified via email and/or a prominent notice on our Websites of any change in ownership or uses of personal information, as well as any choices users may have regarding their personal information; and/or
  • to any other third party for whom users or clients have given prior consent.

Retention of personal information

We will retain your personal information on our systems only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information.
If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honor your request.

Marketing

We will only provide you with marketing materials after you have consented to it explicitly.

If you have previously opted- in to receiving emails from us, use the Preference Center to tell us specifically what you are interested in hearing about, or to opt out of receiving marketing emails from us at all. You can update your preferences at any time.

If you opt in to any subscriptions, you will receive automated emails when content is updated. If you opt in to any newsletters, you will periodically receive curated emails related to those newsletters.

If you become a Registered myCCL Member, we may also contact you with email and marketing communications about subjects that we believe may be of interest to you.

Unsubscribe

If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we have provided within the appropriate area(s) of the Websites or in the relevant communications to you.

If you do not wish to receive emails or marketing communications from us, you can at any time contact us to request that such communications cease. If you wish to unsubscribe or no longer receive only certain communications, please identify such communications in your request or visit our preference center.

Please note that when you exercise your right to object to the sending of direct marketing, this only applies to the given email address. If you receive emails at several email addresses, the unsubscribe procedure must be repeated for each email address used. If you unsubscribe by post, you will need to specify the email addresses you want to disable.

If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honor your request.

Account deactivation

If you are a Registered myCCL Member, you may deactivate your account at any time by contacting TechnicalTeam@ccl.org.

If you deactivate your account on the Websites, you will no longer receive the benefits of being a Registered myCCL Member. If you choose to deactivate your account, we may retain information sufficient to identify you so that we can honor your request.

If you have other accounts with CCL or have provided your information to CCL through other means (such as subscribing to newsletter or being a participant in a CCL service), those accounts will be maintained unless you take specific action to inform us to cease contacting you.

Any user-generated content that you may have created before then will not be anonymized following deactivation, nor will it be immediately removed from our systems or records.

Access to data

We are committed to providing reasonable and practical access that allows visitors to the Websites to identify and correct any inaccuracies in the information we collect about them.

When we keep your personal data, we are responsible for keeping an accurate record of the information that you have submitted to us and verified. We do not assume responsibility for verifying the ongoing accuracy of your personal information. If you are a Registered User, you may update your personal information; to do so, log in using your account credentials and update your information.

If you have questions about the accuracy of your personal data you previously submitted to CCL, or want to have information removed, please contact us. When requested, we will delete personal data from current operational systems, provided that it is practical and commercially feasible to comply with the request and there is no legal or regulatory need for us to keep the information.

Rights in relation to your personal data

You may have certain rights under your local law in relation to the personal information we hold about you. In particular, you may have a right to:

  • request a copy of personal information we hold about you;
  • ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
  • ask that we delete personal information that we hold about you, or restrict the way in which we process such personal information;
  • object to our processing of your personal information; and/or
  • withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights or understand if these rights apply to you, please contact us.

Children

We understand the importance of protecting children’s privacy, especially in an online environment. While CCL does work with children in school and educational contexts through its Societal Advancement Division, the Websites covered by this Marketing Privacy Statement are not intentionally designed for or directed at children. We adhere to laws regarding marketing to children. We never knowingly collect or maintain personal information about individuals under the age of 18 for the purpose of direct marketing.

Contact us

If you have a question about our processing or would like to exercise one of your rights set out above do not hesitate to contact our Data Protection Officer by email (privacy@ccl.org) or by mail (DPO, Legal Department, rue Neerveld 101-103, 1200 Brussels, Belgium).

When you send us an application relating to your rights, please provide us with your full contact details (name, surname, email address(es), full postal address).

Modifications

This Marketing Privacy Statement was last modified in May 23, 2018. We may update this Marketing Privacy Statement at any time by publishing an updated version here. Therefore, we encourage you to review this Marketing Privacy Statement periodically to be informed about how we are protecting your information.

European Union Data Protection Authorities