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Developing Whole Leaders for the whole World

International Transfer of Personal Information and

EEA Data Subject Rights

Personal information provided to us by users outside of the United States may be transferred to other countries such as the United States, where data protection laws may differ from those of your home country. By providing us with your information you acknowledge that your information will be transferred to the U.S. and processed on servers in the U.S. However, all reasonable steps will be taken to protect your privacy in accordance with the applicable data protection laws.

If you are an individual located in the European Union or the countries forming the European Economic Area (Iceland, Liechtenstein, and Norway), you will have the following rights with regard to your Personal Data:

1. Right of access: You may request details of your personal information that we hold. We will confirm whether we are processing your personal information and we will disclose supplementary information including the categories of personal information, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding personal information transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations and other laws.

2. Right of correction: We will comply with your request to edit and update incorrect personal information promptly.

3. Right to be forgotten: At your request, we will delete your personal information promptly if:

  • it is no longer necessary to retain your personal information; 
  • you withdraw the consent which formed the basis of your personal information processing; 
  • you object to the processing of your personal information and there are no overriding legitimate grounds for such processing; 
  • the personal information was processed illegally; or 
  • the personal information must be deleted for us to comply with our legal obligations.

We will inform any third parties we might have shared your personal information with of your deletion request.
We will decline your request for deletion if processing of your personal information is necessary:

  • to comply with our legal obligations;
  • in pursuit of a legal action;
  • to detect and monitor fraud; or
  • for the performance of a task in the public interest.

4. Right to restrict processing of your personal information: At your request, we will limit the processing of your personal information if:

  • you dispute the accuracy of your personal information; 
  • your Personal Information was processed unlawfully and you request a limitation on processing, rather than the deletion of your personal information; 
  • we no longer need to process your personal information, but you require your personal information in connection with a legal claim; or 
  • you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.

5. Right to notice related to correction, deletion, and limitation on processing: In so far as it is practicable, we will notify you of any correction, deletion, and/or limitation on processing of your personal information.

6. Right to data portability: At your request, we will provide you free of charge with your personal information in a structured, commonly used and machine readable format, if: (i) you provided us with personal information; (ii) the processing of your personal information is based on your consent or required for the performance of a contract; or (iii) the processing is carried out by automated means.

7. Right to object: Where we process your personal information based upon our legitimate interest then you have the right to object to this processing.

8. Right not to be subject to decisions based solely on automated processing: You will not be subject to decisions with a legal or similarly significant effect (including profiling) that are based solely on the automated processing of your personal information, unless you have given us your explicit consent or where they are necessary for a contract with us.

9. Right to withdraw consent: You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your personal information up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you.

10. Right to complain to a supervisory authority: If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction.

If you wish to contact us in connection with the exercise of your rights listed above, please email us at the address provided. We will respond to your written request without unreasonable delay and in accordance with any deadlines imposed by law. Unless we notify you at the time of your request, we will not charge you any fee in connection with the exercise of your rights.

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