This Privacy Statement is designed to tell you about the practices regarding the collection, use, and disclosure of information about you throughout your participation in Evolve Leadership (“Evolve”, “We”, “Us”) programs. The Privacy Statement also addresses your use of EvolveLeadership.com or other websites that link to this statement, our portions of survey websites hosted by third party service providers, our e-mail communications to you, and our related online marketing services such as electronic newsletters, invitations, announcements, and other events and communications (collectively the “Websites”). Please be sure to read this entire Privacy Statement before participating in the Programs or using or submitting information to the Websites.

The Programs and the Websites are provided to you by Evolve and if applicable in coordination with your sponsor (e.g., your employer). Your participation in the Programs and use of the Websites are voluntary and based on your eligibility as determined by your sponsor.

This Privacy Statement was last updated January 30, 2021 and became effective at that time. As We update this Privacy Statement from time to time, we will post the revised statement on our Websites as appropriate. Please check back periodically. By using the Websites or otherwise participating in the Programs, you agree to the terms of this Privacy Statement, as updated from time to time.

Specifically, you consent to the collection, processing, retention, and disclosure of information about you by Evolve and its affiliates, business partners, and service providers for the purposes described in this Privacy Statement. You may revoke this authorization by cancelling your registration through your sponsor (if applicable) or by contacting us. If you cancel your registration, we may store and process information about you that is required for recordkeeping purposes, as otherwise allowed for according to this Privacy Statement, and as allowed under applicable law and regulations.

Other portions of the third-party websites that are not used by Evolve are not governed by this Privacy Statement.

Information about You: Information about you is collected through a variety of sources, including directly from you, through your participation in certain Program-related events and activities, from other persons who you select (e.g., so that they may complete surveys about you), through your interactivity with the Websites, and if applicable from your employer or other sponsor. Some areas of the Websites may require you to submit information in order for you to benefit from the specified features or to participate in a particular activity. We will inform you when information is required.

Our websites and other public comment functions are by design open to the public and are not private. Please think carefully before posting personal information in your comments and in any public forum. Your posts and comments may be viewed, disclosed to, or shared by others and may be used by others in ways you and We cannot control, including to contact you for other purposes.

Our use of Information about you, along with our affiliates, business partners, and service providers, is used to provide products and services to you, to fulfill your information requests, as input to various Programs, and to contact you as you have requested. If you provide information to us, We may combine such information with other information We have about you through your participation in any of our Programs that are arranged by your sponsor (if applicable), unless We specify otherwise at the point of collection. Except as otherwise stated, We may use information about you to improve our Programs or the content of our Websites, and for our analysis. In cases where We remove the elements of your information that could identify you, We may use and disclose the resulting “de-identified” information without restrictions. For example, Evolve Leadership may create de-identified, statistical, and aggregate data results for research purposes and for reporting to other organizations, including your sponsor (e.g., your employer). This data reported will not contain personal identifiers and will not identify individual participants. We may share information with the following parties for the purposes described below:

• To your sponsor, if applicable:
  –   We may provide aggregate and statistical information and reporting (i.e., information that does not identify you).
  –   We may also provide information about you and your participation in the Programs if you specifically authorize Us to do so.

• To third party coaches who may assist you with your participation in the Programs.
• To our affiliate companies, third party service providers, business partners, and contractors who assist Us in managing, administering or delivering the Programs, We may provide information about you and your participation in the Programs. We will require such parties to protect and govern the use of the information about you according to this Privacy Statement and other requirements that We place upon them.
• In connection with the sale, assignment, or other transfer of the business of our Programs or the Websites, We may transfer the information about you, in which case We will require any such buyer or acquiring party to agree to treat the information in accordance with this Privacy Statement and use it for similar purposes.
• To respond to law enforcement requests or where required by applicable laws, court orders, or government regulations, We may transfer information about you to other parties for legal purposes.

We will not sell or otherwise give information about you to other parties for their marketing purposes. Information about you will be processed by Us, our affiliates, business partners, and service providers in the United States and in other locations where data protection rules may differ from those of the country in which you reside.

We may use your contact information to send you material about our or your sponsor’s other Programs and products. We may also send you invitations to participate in research studies, such as to develop, evaluate, and update our Programs.

Website Techniques

As you use the Websites, your browser and other devices communicate with the servers involved to coordinate the interactivity and content that you request. Those servers (which include those operated by Us and also those of our affiliates, business partners, and services providers) keep records of your interactivity and requests for services and content to assist Us in managing and improving the utility of the Websites, and to conduct research and analysis on the use of our Programs and tools.

The types of such interactive information include your Internet protocol (IP) addresses, browser types, URLs of referring hyperlinks (i.e., if you clicked through to a page in our Websites), and related web usage information.

The information is stored in web server logs and also in web cookies kept on your computer or mobile device, which are then transmitted back to our Websites of our affiliates, business partners, or service providers by your computer or other device. These servers may be operated, and the cookies managed by Us, our affiliates, business partners, and/or service providers.

We may use cookies* to store your user id and to then authenticate you to the protected portions of the Websites, to analyze how the Websites are accessed and used, and to help Us tailor our services to our participants. Our affiliates, business partners, and service providers may also use cookies for these purposes. Acceptance of cookies by your browser is required for the correct functioning of the Websites. We and our affiliates, business partners, and service providers use cookies and other technical means to record other interactivity information about the use of the Websites and to analyze those records for those purposes.

*A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Websites. Some cookies contain serial numbers that allow Us to connect your website activity with other information We store about you or as it relates to your use of the Websites.

Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons in the Websites, such as to unlock the Websites to you once you have been authenticated and to identify you as you use the various features. Your browser usually erases session cookies once you exit your browser.

“Persistent” cookies are more permanent cookies that are stored on your computer or mobile device even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences (e.g., email subscriptions, how you like to display the Website).

Managing Information about You: Opt-out Procedure: To keep personally identifiable information that you provide Us accurate, current, and complete, please contact Us as specified below and We will take appropriate steps to update or correct such information in our possession, or to delete your information from our contact list.

You may cancel your registration and participation in our Programs by contacting Us or your sponsor.

Security: We take reasonable steps to protect information about you in our possession and control, such as for information associated with the Websites, and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever completely secure or error-free. In particular, email sent between you and Us may not be secure.

Cross-Border Transfer: Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country.

Information about Children: Our programs are open to people of all ages. Our Websites are not intended for use by children under the age of 13 without approval by a parent. For example, parents are allowed to invite their children to provide input to our surveys.

Links to Other Websites: Our Websites may contain links and references to other websites. Our Privacy Statement does not apply to such websites. We encourage you to become familiar with the privacy practices of the other websites that you use.

Contacting Us: If you have a comment or question about the use of the website, please contact us online or as follows:

Email: concierge@evolveleadership.com

Phone: 617-595-8590