Privacy

Privacy Policy

Updated November 26, 2024

1. Introduction

CEO Action is committed to protecting your privacy, and this Privacy Policy (“Policy”) will help you understand how we collect and process Personal Information from those who use of any our websites (e.g., www.ceoaction.com), mobile apps or related online and offline services we offer (collectively, the “Services”). This Policy also describes what we will and will not do with the information we collect, and your choices about the collection and use of your information. If you have a business relationship with us, the contractual terms of that relationship will control in the event of any conflict.

Please read this Policy and our posted Terms of Use (together with this Policy, the “Terms”) before you use our Services. By using the Services, you represent and warrant that you are of legal age to form a binding contract with us, and agree to be bound and abide by our Terms. If you do not agree to all of our Terms, or if you violate them in any way, you may not access or use the Services. PLEASE SEE SECTIONS 9-11 OF OUR TERMS REGARDING YOUR LEGAL RIGHTS IN ANY DISPUTE INVOLVING OUR SERVICES, INCLUDING A WAIVER TO A CLASS ACTION.

2. What is Personal Information?

This Policy applies to Personal Information collected or used by CEO Action in connection with its Services. “Personal Information” generally means any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. Personal Information can include “Sensitive Personal Information” (particularly sensitive types of Personal Information) and “Pseudonymised Personal Information” (information that does not identify you directly but can be linked to other information that does). Personal Information does not include anonymous information or information that has had the identity of an individual permanently removed. Note that privacy laws apply different definitions to “Personal Information” in various jurisdictions and contexts, and we may therefore need to apply a particular definition in specific circumstances.

3. How We Collect Personal Information

As described further below, we may receive Personal Information through many aspects of our online and offline Services, and we may collect such information about you by various means, including:

• Directly from you, both online (e.g., our websites, email) and offline (e.g., phone);
• From other third party sources and social media platforms that you may use to engage with us; and
• By combining information from different sources, including online and offline data.

4. What Information Do We Collect?

CEO Action may collect the following types of Personal Information:

• Contact information, including name, e-mail address, phone number;
• Transaction information, such as payment information and transaction history if you conduct any transactions with us;
• Survey information, in response to questions we may send you through the Services, including for collaboration, feedback and research purposes;
• Communications between you and us, such as via e-mail, web form, mail, phone, or other channels; and
• Online User Activity described in the next section.

If you provide us with information regarding another individual (such as a colleague or co-worker), you represent that you have their consent to give us their information and to permit us to use the information in accordance with this Policy.

5. Online User Activity and Cookies

5.1. Site Use Information

CEO Action collects technical information when an individual visits any online CEO Action Services, including IP address, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g., Chrome or Edge on a Windows platform).

We may also collect information about the visit, including pages and content viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse to or away from the page. CEO Action may also receive location information where you choose to provide the Services with access to information about your location.

This technical information can be necessary to provide the Services, and it also helps us determine which portions of Services are most popular and which part of the website people have visited. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area, and measure the effectiveness of advertisements and web searches.

5.2. What Are “Cookies” and How Does CEO Action Use Them?

Cookies are a commonly-used web technology that allows websites to store and retrieve certain information on a user’s system, and track user’s online activities. We, together with the vendors we use, may collect information about your use of our Services by such automated means, including but not limited to cookies, pixels, and other similar technologies. We reserve the right to use this information, in an aggregated and non-personal form only, to monitor the Services’ performance, utilization of features and services, traffic trends, and other analytical and optimization information.

Cookies and similar technologies can help us automatically identify you when you return to our website. Cookies help us review traffic patterns, improve the website, and determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use the Services, the information we may collected by automated means, include, for example:

• Usage details about your interaction with our Services (such as date, time, length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device information including the IP address and other details that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number); and
• Location information where you choose to provide the website with access to information about your device’s location.

We may also ask advertisers or other partners to serve ads or services to you, which may use cookies or similar technologies placed by us or the third party. If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share non-personal information we obtained via cookies with our advertisers and affiliates. Because there is not yet a consensus on how companies should respond to browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

6. How We Use Personal Information We Collect

We use Personal Information to operate, evaluate, and improve our Services, including for the following purposes:

• To provide our Services to you and to provide you with information and services you request from us; 
• To respond to your questions and provide related support;
• To tailor the content that we display to you in our Services and communications;
• For our business purposes, such as data analysis, audits, enhancing our website, improving our services, identifying usage trends, and determining the effectiveness of our promotional activities;
• To administer and protect our organization and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• To inform you about changes to this Privacy Policy and our Terms and other policies;
• To comply with all applicable laws, legal processes and industry standards, our policies and our contractual rights; and
• For any other purpose specified at the point of collection or as described in your express authorization.

We may use and disclose non-personal, non-individual statistics or demographic information in a de-identified or aggregate form without restriction.

6.1. Enhanced Privacy

On some occasions CEO Action collects Personal Information through its Services with the intent or understanding that it will endeavor to maintain a greater degree of privacy for such information than is otherwise set forth in this Privacy Policy. In those relatively rare situations, CEO Action will expressly disclose at the time of collection what enhanced degree of privacy will be afforded to the Personal Information, and CEO Action will reasonably apply the enhanced degree of privacy to such information. For example, if CEO Action conducts a sensitive survey where its intended use of any Personal Information from that survey will be more limited than this general Privacy Policy provides, CEO Action will specifically disclose the stricter privacy terms which will apply to that survey information when it is collected from the survey respondent.

7. How We Share Personal Information

We will not disclose your personal information to third parties without your consent, except in the following circumstances:

• Limited information (e.g., IP address, pageview, etc.) may be collected through third party online tools such as cookies, as described above. As explained above, you can take certain steps to prevent such collection.
• We may share your contact information with select marketing and promotional partners in order to provide you with materials or offers that may be of particular interest to you.
• We may share your personal information with service providers to perform a technology, business, or other professional function (examples include: IT services, maintenance and hosting of our Services, payment processors, marketing partners, shipping and logistics, amongst others). Such information is only provided to such vendors so they can perform their required functions on our behalf.
• We may disclose information about you to our affiliates (such as SHRM), subject to this policy. In addition, we may disclose your information: (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation or suspected or actual fraudulent or illegal activity, including violation of our Terms, or (iv) under exigent circumstances to protect personal safety of our staff, customers, or the public.
• We reserve the right to transfer the information that we maintain in the event we sell or transfer all or a portion of the organization or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.

Where appropriate, we will limit the sharing of your information in accordance with the choices you have provided us and as required under applicable law.

8. Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our Terms or this Privacy Policy, when necessary.
• Cookies: Web browsers may offer users the ability to disable certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.
• Targeted Advertising: We may potentially work with advertising partners who collect information about your online activities and provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising. Popular advertising services you may opt out of targeted advertising from include Google, Facebook, the Network Advertising Initiative, and Digital Advertising Alliance.

9.  State-Specific Notices

Certain privacy laws may provide additional rights with respect to the collection and use of personal information collected by businesses: (i) disclose personal information maintained about the individual; (ii) correct or delete personal information maintained about the individual (subject to certain exceptions); (iii) not sell personal information about the individual to a third party (excluding qualified service providers); and (iv) not engage in third party targeted advertising. We do not engage in impactful profiling activities with respect to user’s personal information, do not use sensitive personal information except for the reasons provided, and do not generally provide a financial incentive in return for the collection or use of personal information (except where disclosed with relevant terms at the time of collection). We do not share personal information to third parties for their own direct marketing purposes. It can be unlawful to discriminate against an individual for exercising such rights. Do to our size and operations, we may not be subject to any particular state’s privacy laws, but you can submit such requests to us via the contact information provided below and we will endeavor to fulfill any obligations that are legally required, otherwise we will respond to such requests in our discretion.

10. Notice for Individuals Outside the United States

The CEO Action Services are provided from the United States and other countries around the world where CEO Action operates, and are not generally intended to subject CEO Action to the laws or jurisdiction of any other country. Any Personal Information that you directly or indirectly provide to CEO Action through use of the Services may be stored and processed, transferred between, and accessed from, the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside. However, to the extent we are subject to the privacy laws of such jurisdictions, CEO Action will endeavor to process Personal Information in accordance with their privacy laws, as applicable.

This section is therefore intended specifically for individuals residing outside of the United States (“US”). This includes residents of the European Economic Area (“EEA”) and European Union (“EU”), the United Kingdom (“UK”), Switzerland, United Arab Emirates (“UAE”), India and other relevant jurisdictions with respect to privacy and data protection laws (collectively, “International Jurisdictions”) to the extent they are applicable to CEO Action.

• Legitimate Bases for Processing: Where required by law, all processing of Personal Information is justified by a legally-recognized basis for processing. In the majority of cases, processing will be justified on one or more of the following bases for processing: (i) The processing is necessary to perform a contract with you; (ii) The processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records; (iii) The processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Our legitimate interests are to use user data and other information we collect to reasonably and responsibly operate and develop our business activities without abusing any privacy interests or rights of such individuals; and (iv) In some instances, we rely on your consent to our processing (at times as a secondary basis for processing in an abundance of caution).
• Transfer of Personal Information: If you reside in one of the International Jurisdictions that imposes legal restrictions on the transfer of Personal Information from that jurisdiction to another country (e.g., the US), to the extent that we engage in such a transfer of your Personal Information (a “Cross-Border Transfer”) we will take steps to ensure that such Cross-Border Transfer satisfies known legal requirements. In particular, if we transfer Personal Information across jurisdictions we will rely on available adequacy decisions, derogations and/or data transfer agreements with standard contractual clauses approved by relevant regulatory authorities to facilitate any transfers with applicable business partners, affiliates and service providers. 
• Exercising Your Privacy Rights: Residents of certain International Jurisdictions are entitled to exercise certain rights under privacy laws applicable to their Personal Information. This includes the right to (a) request access to your Personal Information; (b) request that we correct inaccurate Personal Information we hold about you; (c) request that we delete any Personal Information we hold about you; (d) restrict or object (i.e., withdraw consent) to the processing of Personal Information we hold about you in some circumstances; and/or (e) receive any Personal Information we hold about you in a structured and commonly used format. You also have the right to lodge a complaint with your supervisory authority if the processing of your Personal Information infringes applicable law. Please contact us as provided below if you wish to exercise any of your rights, or if you have any inquiries or complaints regarding the processing of your Personal Information.

11. Links to Other Websites and Third Party Content

Our Services may contain links to other websites or online services, including social media. Please be aware that we are not responsible for the content or privacy practices of such other websites or online services, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or online service that collects personal information.

You may see us promoted by other businesses on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our brand may be displayed or promoted, and if you believe that we are featured in venues that are inappropriate or offensive, please contact us.

12. Security and Retention of Personal Information

We maintain reasonable security safeguards designed to protect information about our website visitors in our possession and control, and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, we cannot ensure the security of any information that you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of Personal Information. To the extent the law allows us to provide such notification via email or conspicuous posting on the Services, you agree to accept notice in that form.

We apply a general rule of keeping Personal Information only for as long as required to fulfill the purposes for which it was collected including (i) to provide you with our Services, such as to maintain account profiles while active and after termination for the purposes described above, and (ii) as reasonably as necessary for legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

13. Information Related to Minors

Our website and other online Services are not intended for minors under 13, and we do not knowingly collect Personal Information online from minors under 13. We will endeavor to promptly delete any information identified as having been provided by such persons as required by applicable law.

14. Changes To This Privacy Policy

We will update this Privacy Policy from time to time, and the update will be effective on the date posted, so please check back periodically. By affirmatively accepting the new policy or continuing to use our Services, you agree to the updated Privacy Policy.

If at any point we decide to use Personal Information in a manner that is materially different from the terms provided to you at the time of collection, we will endeavor to notify you of such changes.

15. Contacting CEO Action

If you have any questions, concerns or comments about this Privacy Policy, our privacy practices, or if you have any requests in regard to your Personal Information, please contact us by email [email protected].