Privacy Policy

Last revised on October 1, 2020

This Privacy Policy (“Policy”) describes True Synthesis LLC’s (“Synthesis”) practices for collecting, using, sharing, and protecting personal information. Synthesis conducts assessments for our employer clients to use with their leadership, senior management, employees, and job candidates. When you complete an assessment questionnaire, you direct us to share the resulting assessment report with (a) your potential or current employer or (b) our affiliates that provide services to the employer. To comply with privacy requirements in Europe and California, we have provided additional details about our privacy practices to users in the European Union, European Economic Area, United Kingdom (collectively “Europe” or “European”) here and California here.

Collection and Processing of Your Personal Information

Personal Information means information that identifies you as an individual or from which you may be identified. Non-personal information means information that does not directly identify you. We collect both types of information about you. The following provides some examples of the type of information that we collect and what we use that information for:

Types of Information, Purpose for Collection, and Use of Information

Assessment Questionnaire

If you complete an assessment questionnaire, we collect information such as your name, contact information, job title, and questionnaire responses. We use this information to create an assessment report about you for your potential or current employer. We may use such reports to generate aggregated profiles, industry reports or other analytics.

Client Information

We collect business contact information and billing information from our clients and our potential clients. We use that information to market our assessments and to provide our clients with products or services.

Email interconnectivity

If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners within it. We use that information to identify whether messages have been received and read by a message recipient. We may also take the information in your emails and add it to our contacts and log it with our customer relationship management (CRM) system.

Employment

If you apply for a Synthesis job posting, or become an employee at Synthesis, we collect information necessary to process your application or to further the employment relationship. This may include your Social Security Number, National Security Number, among other things.

Feedback/Support

If you provide us feedback or contact us we will collect your name and email address, as well as any other content you send to us, in order to reply.

Mailing List

When you sign up for one of our mailing lists we collect your email address.

Mobile Devices

We and our third-party partners, like Google Analytics, collect information from mobile devices such as unique identifying information broadcast from devices when visiting our website.

Surveys

If you participate in a survey (other than an assessment questionnaire), we collect information provided through the survey to improve our services.

Web logs

We collect your browser type, operating system, internet protocol (IP) address (a number that is automatically assigned to a computer when using the internet), domain name, click-activity, referring website, viewed websites, and/or a date/time stamp for visits.

Cookies and first party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. We use both session cookies (which expire once a web browser is closed) and persistent cookies (which stay on a device until deleted). Among other things, cookies allow us to provide a more personal and interactive experience and to improve our marketing efforts. Persistent cookies may be removed by following instructions provided by the browser. If cookies are disabled some areas or features of our websites may not work properly.

We collect personal information about you from a variety of sources, including when you visit our website, when you voluntarily provide information to us, when information is publicly posted (e.g. Google, Facebook, Twitter, etc.), or when we receive it from third parties such as our clients.

Use of information

We only use the information collected via assessment questionnaires to provide our products or services, to conduct analytics, and to comply with legal obligations.

In addition to the purposes and uses described above, we may use other forms of personal information in the following ways:

To identify you when you visit our websites.
To respond to your inquiries related to support, employment opportunities, or other requests.
To provide our products or services.
To conduct analytics.
To send marketing and promotional materials, including information relating to our products, services, sales or promotions.
For internal administrative purposes, as well as to manage our relationship with you.

As discussed in the sections above, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

Affiliates. We may share assessment reports with our affiliates that provide services to your current or potential employer, at the employer’s direction. We may also share your business contact information with one of our affiliated companies so that they can communicate with you about the products or services that they provide.
Clients. When we conduct assessments at the request of a client, we will share the resulting assessment reports with that client. However, we will not share the raw assessment questionnaire responses with our clients without your express consent.
Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties that are not described elsewhere in this policy.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request.
Service Providers. Synthesis may provide personal information to third parties that act as agents, consultants or contractors to perform tasks on behalf of and under Synthesis’s instruction. Such recipients must agree to abide by confidentiality obligations and are not permitted to use your personal information except for the limited purpose that we request.
Third-Party Tracking Companies. When you interact with us online – including via websites or email – third-party companies, including analytics partners, may collect tracking information by automated means over time and across different websites. The privacy policies of these third-party companies apply to their collection, use and disclosure of your information.
Corporate transactions. We may also share your information if another company acquires our company, business, or our assets, or in the event of a bankruptcy or reorganization.

Retention of Information

We retain personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual requests that we delete information about them. If you would like additional information concerning how long we keep a specific type of information, you can contact us using the contact information provided below.

Protecting Information

Synthesis uses reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain.. Unfortunately, data transmission over the internet cannot be guaranteed as completely secure. Therefore, while Synthesis strives to protect your personal information, Synthesis cannot guarantee the security of personal information. In the event that Synthesis is required to notify you about a situation involving your data, Synthesis may do so by email, telephone or mail to the extent permitted by law.

Your Choices

You can make the following choices regarding your personal information:

Access, Correction, and/or Deletion of Your Personal Information. You may request to access, correct or delete the personal information that Synthesis has collected about you on its own behalf by writing to the contact listed below under the section titled “Contact Information.” When we delete personal information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it.
Ability to Restrict or Object to Processing. You may request to restrict our continued processing of your personal information or object to our reliance on legitimate interests as the basis of our processing of your personal information. If we receive an objection, we will evaluate whether we are required by law to discontinue such processing.
Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions. You can take steps to opt out of online tracking as described here.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive or contacting us using the information below. If you decide not to receive promotional emails, we may still send you service-related communications.
Opt-Out / Revocation of Consent. If we rely on your consent to process personal information you may revoke that consent by writing to the contact listed below under the section titled “Contact Information.” Note that in some situations we may no longer be able to provide you services if you revoke your consent; we may also limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
Different Purposes. If we use your information for a materially different purpose than the purpose for which it was collected, we will offer you the ability to either opt-in or opt-out of such a use, as required by law.

Contact Information

If you have any questions or concerns related to this Privacy Policy, please contact Synthesis at:

True Synthesis LLC

56 N. Haddon Ave. 1st Floor

Haddonfield, NJ 08033 USA

ATTN: Privacy Officer

privacy@yoursynthesis.com

800-218-0340

If you are not satisfied with our response, and are in Europe, you may have a right to lodge a complaint with your local supervisory authority.

Miscellaneous

Modifications to Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, we will notify you of the change.
Affiliated Companies. Some Synthesis affiliates and/or sites may have their own, possibly different, privacy policies. Synthesis encourages you to read the privacy policies of any of Synthesis’ affiliate websites that you may visit.Additional Information for European Users

Additional Information for European Users

Controller

Synthesis is the controller of your personal information covered by this Privacy Policy. See the Contact Information section above to contact our Data Protection Officer. When a client engages Synthesis to conduct an assessment, the client is also a controller of the information collected in connection with the assessment.

Legal bases for processing

The legal bases for our processing of your personal information are described below.

To provide our products and services. Where we have an agreement governing this purpose, processing is necessary to perform the contract governing our provision of services or to take steps that you request prior to signing up for our services.
When we collect sensitive information, such as through an assessment questionnaire / survey, we process such information as necessary to carry out obligations related to leadership assessment or rely on the individual’s consent.
In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

The following processing activities constitute our legitimate interests:

To identify you when you visit our websites.
To respond to your inquiries.
To send marketing and promotional materials.
To conduct analytics.
For internal administrative purposes.
To, in an aggregated or anonymized form, generate industry reports about trends.
For compliance, fraud prevention and safety.
To comply with law. Processing is necessary to comply with our legal obligations.
Other uses. Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested the consent or by contacting us.

Cross-border data transfer

Your personal information may be processed in a country where you do not reside that has privacy laws that may be less stringent than the laws in your country.

Synthesis is based in and maintains its infrastructure in the US, and it is necessary for us to transfer personal information to the US to provide our services to you and our employer clients.

Notice to California Users

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information.

This notice and the privacy rights it describes do not apply to information related to our business contacts, job applicants, or employees.

Personal Information that We Collect, Use and Share

The information below describes how we currently collect, use and share personal information, and how we have collected used and shared personal information over the past 12 months. The below information may not cover information you volunteer to us, such as in correspondence.

This Notice to California Users does not apply to personal information of individuals who interact with us in their business capacity, including to employees and other representatives of our current or potential clients. We may use cookies and other tracking technologies when you interact with us online and share information at your direction, but we do not sell personal information. Specifically, when you complete an assessment questionnaire, you direct us to share the resulting assessment report with (a) your potential or current employer or (b) our affiliates that provide services to the employer. We use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to learn how you may opt out of our (and third-party tracking companies’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.

We may collect, use and share personal information in the following ways:

Assessment Questionnaire
- Sources of personal information: Assessed individuals
- CCPA categories of personal information collected: Identifiers, commercial information, professional or employment-related information, education information, and protected classification characteristics
- Business/commercial purposes for which we may collect and use personal information:
  - To provide our products and services.
  - For internal administrative purposes.
  - To conduct analytics, such as to create aggregated profiles and industry reports.
  - To send marketing and promotional materials.
- Data sharing: When you complete an assessment questionnaire, you direct us to share the resulting assessment report with (a) your potential or current employer or (b) our affiliates that provide services to the employer.

Email Interconnectivity, Mobile Devices, Web Logs, and Online Activity
- Sources of personal information: Automatically collected
- CCPA categories of personal information collected: Online identifiers, internet or network information, and geolocation data
- Business/commercial purposes for which we may collect and use personal information:
  - To identify you when you visit our websites.
  - To conduct analytics.
  - For internal administrative purposes.
- Data sharing: This information is collected directly by third-party tracking companies.

Surveys and Feedback/Support
- Sources of personal information: Clients and assessed individuals
- CCPA categories of personal information collected: Identifiers, commercial information, and professional information
- Business/commercial purposes for which we may collect and use personal information:
  - To provide our products and services.
  - To respond to your inquiries.
  - To conduct analytics.
  - For internal administrative purposes.
- Data sharing: We may publicly share data gathered in an anonymized form or with your consent.

Please note that we may also disclose personal information with service providers, and in connection with corporate transactions or compliance.

California Residents’ Privacy Rights

The CCPA grants California residents the following rights:

Information. You can request information about how we have collected, used and shared your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in the above chart.
Access. You can request a copy of the personal information that we have collected about you.
List of Third-Party Marketers. Under California’s Shine the Light law, Synthesis users who are California residents may request a notice identifying the categories of personal information that we share with third parties for their own direct marketing purposes, and such third parties’ contact information.
Deletion. You can ask us to delete the personal information that we maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain information we maintain for compliance in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination, as prohibited by the CCPA.

How to Submit a Request

To request access to or deletion of personal information:

call 800-218-0340
email privacy@yoursynthesis.com
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

Online Tracking Opt-Out Guide

Like many companies online, Synthesis uses services provided by third parties that use tracking technology. These services rely on tracking technologies – such as cookies – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers.
Platform opt-outs. Google offers opt-out features that lets you opt out of use of your information for interest-based advertising. Google also offers a browser extension to opt out of Google Analytics.
Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Note that because many of these opt-out mechanisms are specific to the device or browser on which you exercise them, you will need to opt out on every browser and device that you use.