Privacy Policy

Overview: Kaplan DeVries Inc. (KDI) respects individual privacy and values the confidence of its clients, employees, vendors, business partners and others. KDI strives to collect, use, and disclose Personal Information (as defined below) in a manner consistent with the laws of the countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices. KDI abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that KDI follows with respect to transfers of Personal Information anywhere in the world, including transfers from the European Economic Area (EEA) to the United States.

KDI adheres to the privacy principles of the Safe Harbor Program administered by the United States Department of Commerce and as described below. Information regarding the Safe Harbor Program can be found at the program's website: http://export.gov/safeharbor.

Company Background: KDI provides leadership assessment and development consulting services to global companies to improve the effectiveness of executives and other leaders in their professional and personal lives. We collect or receive personal information from clients and their colleagues who are presented with an "informed consent" disclosure prior to submitting personal data. We use personal information in order to provide our consulting services to our clients and to communicate with clients. Providing personal data such as age, gender, and ethnicity is voluntary; however, providing personal data such as the participant's name is required to process the data and to ensure that the participant's results can be distinguished from others. KDI or its contracted agents will handle all personal information collected and received in connection with delivering its services as pledged and outlined in the following Privacy Policy.

Privacy Policy Elements:

• Safe Harbor. We adhere to the U.S. Commerce Department's Safe Harbor principles for personal information collected in connection with the delivery of our consulting services. KDI implements high-level security protocols to ensure the protection of personal information collected.
• Personal Information Collected. The personal data that we collect or receive on participants may include: First and Last Name, Age, Gender, Ethnicity, and E-mail address (not all information we request is required by participants and all required personal information fields are marked). When assessments are administered, we collect responses and then derive summaries and scores and generate a report about participants' personal characteristics. KDI does not require participants to provide sensitive information, as defined by the Safe Harbor, in connection with processing participant data and delivering its customer services, although participants may choose to provide some sensitive information at their option.
• Aggregation of Non-Person-Specific Data. We may statistically aggregate in non-person-specific form test responses and other information collected for KDI internal research purposes. Such aggregated non-person-specific information may be used to enhance, develop or improve our products and services. By initiating the assessment process, you give your consent to this non-person-specific data aggregation and the use and transmission of this aggregated statistical data as outlined herein.
• Transfer of Information. We may disclose personally identifiable information in the following situations: (a) in response to a subpoena, court order or legal process, to the extent permitted and required by law; (b) to protect your security or the security of other persons, consistent with applicable law; (c) in connection with a sale, joint venture, or other transfer of some or all of the assets of KDI; (d) to organizations, including independent testing centers, who are working as our contractors or agents and who are committed or obliged to protect your privacy in a manner consistent with this Privacy Policy. By initiating the assessment process, you give your consent for your personal information to be transmitted in the situations outlined above. All KDI contractors are responsible for complying with national and international protocols covering data use and transfer.
• Independent Testing Centers. Some client projects may involve administration of assessments through independent testing centers. These centers may provide unrelated services and may collect and use personal data for other purposes under different terms and policies. If you have any questions or concerns about an independent testing center's collection or use of any of your personal information, please talk to the independent testing center directly. If you are not able to adequately address concerns about information collected about you through independent testing centers, please contact us at http://www.kaplandevries.com/contact.
• Access to Data. KDI will not provide results to anyone other than the individual being assessed, unless requested by that individual. The dissemination of results is the sole responsibility of the individual participant. Employers and colleagues of individuals taking the assessments are not guaranteed access to participants' results.
• Information Access and Corrections. To access and correct the personal information that we have collected under this policy, please contact our Customer Service Department or send us an E-mail at .(JavaScript must be enabled to view this email address). To protect your privacy and security, we will take reasonable steps to verify your identity before amending any of your personal information in our databases.
• Protection of Personal Information. We use reasonable precautions to protect personal information from unauthorized use, access, disclosure, alteration or destruction. These precautions include appropriate physical, electronic and managerial procedures. For the electronic transmission of identifiable personal data, we provide secured transmission through Secured Socket Layer (SSL) 128 bit encryption (non-identifiable data may be transmitted unencrypted).
• Resolution of Concerns. If you have questions or concerns about this Privacy Policy or how we have handled personal data, please contact us at .(JavaScript must be enabled to view this email address). If we are unable to satisfactorily address your concerns or if a dispute arises, KDI will cooperate with the EU Data Protection Authorities and the Department of Commerce to resolve any complaints and disputes arising in connection with its privacy policy. The EU Data Protection Authorities may be reached through the United States Council of International Business at 212-354-4480.

  Information from Children
  KDI's services are not directed to children or anyone under the age of seventeen (17). KDI will not knowingly collect, maintain, or use any personally identifiable information about anyone under the age of seventeen (17) without the permission of a parent or legal guardian.

  Information Received from Internet Service Providers Through This Web Site
  KDI does not link IP addresses to personally identifiable information; however, we reserve the right to link IP addresses and other information supplied by the ISP to personally identifiable information in order to protect the integrity of our system and for security purposes.

  Cookies
  Cookies are small text files that a Web site transfers to your computer's browser. Cookies are used by KDI to measure traffic patterns, personalize content, and control security. The cookies we use supply non-personally identifiable information, but they may identify your computer, browser, and Internet specifications.

  Transmission of Information
  The Internet is a global environment. By using this site and sending information to us electronically, you consent to transborder and international transmission of any data that you may choose to supply us. Information transmissions to this site and E-mails sent to us may not be secure. Given the inherent operation and nature of the Internet, all Internet transmissions are done at the user's own risk.

  Changes to This Privacy Policy
  We reserve the right to change the terms of this Privacy Policy from time to time by posting an updated Privacy Policy. We encourage you to review this Privacy Policy periodically for any changes or updates.

  How to Contact Us
  If you have any questions or concerns about this Privacy Policy, please contact us at .(JavaScript must be enabled to view this email address). You may also contact us through our corporate office:

  United States +1 (336) 288-8200
  E-mail: .(JavaScript must be enabled to view this email address)

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