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:
4. What Information Do We Collect?
CEO Action may collect the following types of Personal Information:
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:
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:
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:
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.
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.
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].