Services privacy

At The Predictive Index, LLC (“PI”) we are committed to protecting your personal data.  This services privacy policy (“Services Policy”) outlines PI’s privacy practices with respect to any information you provide to or is collected by PI in connection with your use of our products and services.  If you only visit our public website, this Services Policy does not apply to you. The Website Privacy Policy can be reviewed here.

When we use the term “Personal Data” in this Services Policy, we are referring to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. 

If you are responding to a PI assessment, you are called a “Respondent” for the purposes of this Services Policy.  Clients of PI are referred to as “Customers” and authorized users of the PI software at each Customer company are referred to as “Users.”

We do not collect information from children. PI assessments are not designed to be administered to anyone under the age of 18, therefore we do not solicit or collect any type of information from a person known to be under that age.

Respondents to PI Assessments 

We collect the name and email address for all Respondents.  You will also be asked to provide responses to the PI Behavioral Assessment (which consists of adjectives chosen by the Respondent) and/or the PI Cognitive Assessment (which consists of multiple-choice responses chosen by the Respondent).

We use the Personal Data we collect to provide the PI assessment results to the Customer that requested you complete the assessment (your potential or current employer).  Your Personal Data is anonymized 120 days following the end of our agreement with the Customer unless the Customer requests such anonymization earlier.  If you are a freemium Software Client that is not required to pay any subscription fee, your Personal Data is anonymized 120 days following the termination of your agreement with PI unless you request such anonymization earlier.

In addition to the Personal Data collected when you complete a PI assessment, we may also collect additional information from you if you voluntarily agree to answer optional research questions.  In this case, the information requested may include the following: Customer-provided group designation, age, years of experience, ethnicity, gender, country of origin, education level, position level, company name, relationship to PI, title, occupation, and personal contact details to be included in further PI research.  Such additional information is only collected, used, and stored with your consent. This additional information is not provided to a Customer and is used only for PI’s internal research purposes.

Customers and Users of PI Software

We collect the following categories of Personal Data from Customers and Users:

Categories of Sources

When you use our products and services, we collect Personal Data directly from you when you provide it to us or as it is automatically generated and collected.  We also sometimes receive the following types of Personal Data from our PI Certified Partner network and other affiliate organizations, as well as third party service providers that provide Personal Data and non-personal data to us: identifiers, Personal Data categories (California Consumer Records Act information), and inference information.

Our Business Purposes for Collecting Personal Information

• To provide the services to you
• To provide customer support for the services to you
• To respond to requests and communications from you
• To improve our website and our services
• To send you updates about our company
• For targeting marketing campaigns
• To inform you about our products and services and to gather feedback from you on our website and services
• To understand how our services are accessed, used, and whether there are any potential security issues arising from such use

We use your Personal Data only in connection with performing the contract that we have entered into with you, your employer, or a third party, and in providing, managing and administering our Services.

PI may collect, store and use aggregated anonymous information from the administration of PI assessments and our other products and services in order to improve our business operations and our products. This information does not identify any individual. PI also uses log files and other generally available web tracking technologies in operating, maintaining, and improving our PI software platform and our website. This information does not contain any Personal Data and is not linked to any Personal Data that PI holds except when a Respondent voluntarily agrees to answer optional research questions.

Customer Collected Information

If you are a Customer, you may request and store other information from your Users and Respondents including without limitation job code, department code, occupation, status, language preference, or other freeform company-specific information configured by the Customer, if applicable. The Service is intended for business purposes only, and is not intended to collect or store any special categories of personal data or sensitive health or financial information.  Please do not enter this type of information.  PI solely makes use of such information in accordance with this Services Policy. If you voluntarily provide this company-specific information, you are consenting to our collection and use of this information as described in this Services Policy.

Customers receive PI Assessments and associated reports processed by the PI software platform and then may integrate these reports into their own Human Resources and personnel systems.  PI does not own or control information contained in the PI Assessments or stored on the PI software platform by Customers. If you wish to access, amend, or delete any personal data connected with a PI Assessment that you may have taken, please contact the company who requested that you take the PI Assessment directly.

PI Certified Partners

PI and its distribution partners (“PI Certified Partners”) collect additional Personal Data from Users and employees of Customers who attend workshops or training. This information may include address, email address, telephone and fax numbers. PI Certified Partners share this information with us and we use this information to contact you to provide you with additional information regarding your use of the Service.  PI does not control Personal Data collected by PI Certified Partners.  If you wish to access, amend, or delete any Personal Data given to a PI Certified Partner, or to understand how that Partner collects, uses, and discloses your Personal Data, you should contact that Partner directly. A directory of our PI Certified Partners is here.

Third Parties We May Disclose Personal Data To

PI maintains contracts with our Customers, distributors, and subcontractors requiring them to comply with the requirements of this Services Policy. These third parties must provide at least the same level of privacy protection as required under applicable law, including without limitation under European Union data protection laws.  A complete list of technical service providers may be found here.

PI does not sell or share your Personal Data to any third party, under the definitions of “sell” and “share” in applicable law. We do not disclose any Personal Data to any other party except to fulfill the purposes for which the information was disclosed and as described in this Services Policy. To fulfill those purposes, PI may disclose the following Personal Data to:

In addition, as explained in the Respondents to PI Assessments section (located higher in this document), we provide PI assessment results to the Customer that requested the assessment be completed, who may be the potential or current employer of the person taking the assessment and whom the assessment is about.  

Additional Disclosures

We may need to disclose your Personal Data for law enforcement or other legal purposes. This type of disclosure may be necessary in connection with, but not limited to, a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter. 

In the event of an acquisition, merger, sale, corporate restructuring, bankruptcy, or other similar event that involves PI, we may disclose Personal Data about you, including personal contact information. If such an event occurs, we will take reasonable steps to require that your Personal Data be handled in accordance with this Services Policy.

Free Trials and Services Demonstrations

If you are utilizing a free trial or participating in a demonstration of the Services, in addition to the uses outlined above, your Personal Data may be used by PI and/or its PI Certified Partners in connection with offering the Services to you and/or your organization for purchase. For additional information about Personal Data obtained during free trials and demonstrations of the Services, please refer to Sections  28 and 29 of our Client Software Agreement located at https://www.predictiveindex.com/terms.

Google API Services User Data Policy

PI’s use of information received from Google’s APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Additional Information for California Residents

The California Consumer Privacy Act (“CCPA”) provides California residents enhanced rights with respect to their personal data that is collected by businesses. 

We do not use or disclose sensitive personal data, and we do not “sell” or “share” personal data as those terms are defined by the CCPA, and we have not in the prior 12 months. The CCPA requires us to state that we do not have actual knowledge that we sell or share the personal data of California residents under 16 years of age.

First, California residents may opt-out of having their personal data sold to, or shared with, other persons or parties.  As stated, PI does not sell or share your information.

Second, California residents have a right to know:

What specific pieces of information a business has about the resident;

Categories of personal data it has collected about the resident;

Categories of sources from which the personal data is collected;

Categories of personal data that the business sold, shared, or disclosed for a business purpose about the resident;

Categories of third parties to whom the personal data was sold, shared, or disclosed for a business purpose; and

The business or commercial purpose for collecting, selling, or sharing personal data.

Third, California residents can request that the personal data a business has collected from them be deleted from the business’s systems and records, subject to certain exceptions.

Fourth, California residents can request that inaccurate personal data a business maintains about them be corrected. 

Fifth, California residents can request to limit the use or disclosure of their sensitive personal data.  As stated above, PI does not collect sensitive personal information under the CCPA.

To make a “request to know,” “request to delete,” or “request to correct” your Personal Data or the Personal Data of an individual for whom you are an authorized agent, please go to the “Contact Us” section in our “Privacy and DPA FAQ” page or email us at privacy@predictiveindex.com or submit your request by phone by calling us at (800) 832-8884. (If you email us, please put “California Request to Know,” “California Request to Delete,” or “California Request to Correct” in the subject heading of your email.)  

We will confirm receipt of your request to know, delete, or correct within 10 days along with a description of what steps we will take to verify and respond.  We must provide the requested information or delete your Personal Data within 45 days of receipt of your request but can use an additional 45 days, but we will let you know if additional time is needed.

When contacting us, we may ask you to provide certain, limited Personal Data, such as your name, e-mail address and/or username to verify your request and to match with our records and systems.  We will not retain this Personal Data or use it for any other purpose.  

Additional Information for Colorado Residents

We may be subject to the Colorado Privacy Act based on our interactions with Colorado residents and our use of their personal data.  The Colorado Privacy Act provides Colorado residents enhanced rights with respect to their personal data when acting in an individual or household context.  If you are using products and services in the context of your employment or application for employment, this law may not apply to you.  It does not apply to Colorado residents who are acting in commercial or employment contexts, as job applicants, or as beneficiaries of someone acting in an employment context.

In this section, “CPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Colorado resident.  CPA personal data does not include de-identified or publicly available information, as defined in the Colorado Privacy Act, or data maintained for employment purposes. 

First, a Colorado resident may opt out of processing their CPA personal data for purposes of targeted advertising, the sale of their CPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Colorado resident.  

Second, a Colorado resident has the right to confirm whether we are processing CPA personal data concerning them and to access their CPA personal data. As part of a request for access, the Colorado resident may also request to receive their CPA personal data in a portable and, if technically feasible, readily usable format.

Third, a Colorado resident may have the right to correct inaccuracies in their CPA personal data we hold.

Fourth, a Colorado resident may have the right to request we delete CPA personal data concerning them.

To exercise your rights, please go to the “Contact Us” section in our “Privacy and DPA FAQ” page or email us at privacy@predictiveindex.com or submit your request by phone by calling us at (800) 832-8884.  If you email us, please put in the subject line of your email the right you are seeking to invoke: “Colorado Right to Opt Out,” “Colorado Right to Access,” “Colorado Right to Correct,” or “Colorado Right to Delete.”  

You may submit multiple requests at once through our webform or in an email.  Subject to certain exceptions, ordinarily there is no cost for submitting your first request; if you submit multiple requests in a twelve-month period, we may charge you a fee for answering your request. We are permitted to use commercially reasonable efforts to authenticate you are who you say you are, and if you are submitting the requesting on behalf of another, that you have the authority to do so.  So we may need to ask you for more information, in light of the rights exercised, the type, sensitivity, value, or volume of personal data, the level of possible harm if we improperly grant the request, and the cost to us. If we cannot authenticate you or your authority, we will deny the request. 

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your CPA personal data) without undue delay and within 45 days after we receive your request.  We may extend that deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why. 

The Colorado Privacy Act includes exceptions for Personal Data regulated under other laws or maintained for certain reasons or in certain contexts.  For example, the Colorado Privacy Act does not apply to publicly available information, including information that we reasonably believe Colorado residents have lawfully made available to the general public.  As another example, we will not delete CPA personal data when it is necessary to maintain it to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not.  You may appeal our decision by emailing us at privacy@predictiveindex.com with the subject line “Appeal of Request” and including our response to your request.  We will also include this information in our response to your request.  If you appeal our decision, we have 45 days to respond.  We may also extend our deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why.  If you have concerns about the results of your appeal, you may contact the Colorado Attorney General.

Additional Information for Connecticut Residents

We may be subject to the Connecticut Data Privacy Act based on our interactions with Connecticut residents and our use of their personal data.  This law provides Connecticut residents enhanced rights with respect to their personal data when they are not acting solely in a commercial or employment context (such as a B2B communication) when interacting with us.  If you are using our products and services in connection with employment or an application for employment, these disclosures are unlikely to apply to you.

In this section, “CTDPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Connecticut resident.  CTDPA personal data does not include de-identified or publicly available information, as defined in the Connecticut Data Privacy Act, or to information processed or maintained in the course of applying to, employed by or acting as an agent or independent contractor of us or another company (such as our Customer), to the extent that the data is collected and used within the context of that role.  

First, a Connecticut resident may have the right to confirm whether we are processing CTDPA personal data concerning them and to access their CTDPA personal data. 

Second, a Connecticut resident may have the right to correct inaccuracies in their CTDPA personal data we hold.

Third, a Connecticut resident may have the right to request we delete CTDPA personal data concerning them.

Fourth, a Connecticut resident may also request to receive their CTDPA personal data in a portable and, if technically feasible, readily usable format.

Fifth, a Connecticut resident may opt out of processing their CTDPA personal data for purposes of targeted advertising, the sale of their CTDPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Connecticut resident.  

To exercise your rights, please go to the “Contact Us” section in our “Privacy and DPA FAQ” page or email us at privacy@predictiveindex.com or submit your request by phone by calling us at (800) 832-8884.  If you email us, please put in the subject line of your email the right you are seeking to invoke: “Connecticut Right to Access,” “Connecticut Right to Correct,” “Connecticut Right to Delete,” “Connecticut Right to Portability,” and “Connecticut Right to Opt Out.”

You may submit multiple requests at once through our webform or in an email.  Subject to certain exceptions, ordinarily there is no cost for submitting your first request; if you submit multiple requests in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests.  For requests other than a Right to Opt Out, we are permitted to use commercially reasonable efforts to authenticate you are who you say you are and if you are making a request on behalf of another, that you have the authority to do so.  If we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you.  If we cannot authenticate you or your authority, we will deny the request.  If you submit a Right to Opt Out request, we are permitted to deny the request if we have a good faith, reasonable and documented belief that the request is fraudulent, and we will tell you that and why.

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your CTDPA personal data) without undue delay and within 45 days after we receive your request.  We may extend that deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why. 

Connecticut’s law includes exceptions for Personal Data regulated under other laws or maintained for certain reasons or in certain contexts.  For example, it does not apply to publicly available information, including information that we reasonably believe Connecticut residents have lawfully made available to the general public.  As another example, we will not delete CTDPA personal data when it is necessary to maintain it to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not.  You may appeal our decision by emailing us at privacy@predictiveindex.com with the subject line “Appeal of Request” and including our response to your request.  We will also include this information in our response to your request.  If you appeal our decision, we have 60 days to respond.  If you have concerns about the results of your appeal, you may contact the Connecticut Attorney General.

Additional Information for Virginia Residents

We may be subject to the Virginia Consumer Data Protection Act based on our interactions with Virginia residents and our use of their personal data.  The Virginia Consumer Data Protection Act provides Virginia residents enhanced rights with respect to their personal data when acting in an individual or household context, but not when they are acting in a commercial or employment context.  If you are using our products and services in connection with employment or an application for employment, these disclosures are unlikely to apply to you.

In this section, “CDPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Virginia resident.  CDPA personal data does not include de-identified or publicly available information, as defined in the Virginia Consumer Data Protection Act, or to information processed or maintained in the course of applying to, employed by, or acting as an agent or independent contract of us or another company (such as our Customers), to the extent that the data is collected and used within the context of that role.

First, a Virginia resident may opt out of processing their CDPA personal data for purposes of targeted advertising, the sale of their CDPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Virginia resident.  

Second, a Virginia resident has the right to confirm whether we are processing CDPA personal data concerning them and to access their CDPA personal data. 

Third, a Virginia resident may also request to receive their CDPA personal data in a portable and, if technically feasible, readily usable format.

Fourth, a Virginia resident may have the right to correct inaccuracies in their CDPA personal data we hold.

Fifth, a Virginia resident may have the right to request we delete CDPA personal data concerning them.

To exercise your rights, please go to the “Contact Us” section in our “Privacy and DPA FAQ” page or email us at privacy@predictiveindex.com or submit your request by phone by calling us at (800) 832-8884.  If you email us, please put in the subject line of your email the right you are seeking to invoke: “Virginia Right to Opt Out,” “Virginia Right to Access,” “Virginia Right to Portability,” “Virginia Right to Correct,” or “Virginia Right to Delete.”  

You may submit multiple requests at once in an email.  Subject to certain exceptions, ordinarily there is no cost for submitting your first two requests; if you submit more than two requests in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests.  We are permitted to use commercially reasonable efforts to authenticate you are who you say you are, and if we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you.  If we cannot authenticate you or your authority, we will deny the request. 

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your CDPA personal data) without undue delay and within 45 days after we receive your request.  We may extend that deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why. 

The Virginia Consumer Data Protection Act includes exceptions for Personal Data regulated under other laws or maintained for certain reasons or in certain contexts.  For example, the Virginia Consumer Data Protection Act does not apply to publicly available information, including information that we reasonably believe Virginia residents have lawfully made available to the general public.  As another example, we will not delete CDPA personal data when it is necessary to maintain it to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not.  You may appeal our decision by emailing us at privacy@predictiveindex.com with the subject line “Appeal of Request” and including our response to your request.  We will also include this information in our response to your request.  If you appeal our decision, we have 60 days to respond.

Additional Information for Utah Residents

We may be subject to the Utah Consumer Privacy Act based on our interactions with Utah residents and our use of their personal data.  The Utah Consumer Privacy Act provides Utah residents enhanced rights with respect to their personal data when acting in an individual or household context, but not when acting in a commercial or employment context.  If you are using our products and services in connection with employment or an application for employment, these disclosures are unlikely to apply to you.

In this section, “UCPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Utah resident.  UCPA personal data does not include de-identified or publicly available information, as defined in the Utah Consumer Privacy Act, or information processed or maintained in the course of applying to, employed by, or acting as an agent or independent contract of us or another company (such as our Customer), to the extent that the data is collected and used within the context of that role.

First, a Utah resident has the right to confirm whether we are processing UCPA personal data concerning them and to access their UCPA personal data. 

Second, a Utah resident may have the right to request we delete UCPA personal data concerning them.

Third, a Utah resident may also request to receive their UCPA personal data that they provided to us  in a portable and, if technically feasible, readily usable format.

Fourth, a Utah resident may opt out of processing their UCPA personal data for purposes of targeted advertising or the sale of their UCPA personal data.  

To exercise your rights, please go to the “Contact Us” section in our “Privacy and DPA FAQ” page or email us at privacy@predictiveindex.com or submit your request by phone by calling us at (800) 832-8884.  If you email us, please put in the subject line of your email the right you are seeking to invoke: “Utah Right to Access,” “Utah Right to Delete,” “Utah Right to Portability,” or “Utah Right to Opt Out.”

You may submit multiple requests at once in an email.  Subject to certain exceptions, ordinarily there is no cost for submitting your first request; if you submit more than one request in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests.  We are permitted to use commercially reasonable efforts to authenticate you are who you say you are, and if we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you.  If we cannot authenticate you or your authority, we will deny the request. 

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your UCPA personal data) without undue delay and within 45 days after we receive your request.  We may extend that deadline by 45 days, to 90 days in total, in some cases.  If we extend the deadline, we will tell you that and why. 

The Utah Consumer Privacy Act includes exceptions for Personal Data regulated under other laws or maintained for certain reasons or in certain contexts.  For example, the Utah Consumer Privacy Act does not apply to publicly available information, including information that we reasonably believe Utah residents have lawfully made available to the general public.  As another example, we will not delete UCPA personal data when it is necessary to maintain it to comply with a legal obligation.

Contact

To submit a request to exercise any of your rights provided in this notice, please go to the “Contact Us” section in our “Privacy and DPA FAQ” page or email us at privacy@predictiveindex.com or submit your request by phone by calling us at (800) 832-8884. We will evaluate the request and take action where required to do so.

Last modified February 15, 2024