Privacy Policy

Bates understands that your privacy is important to you and it is important to us, too.

Bates is strongly committed to protecting your privacy and the personal information that you may provide to Bates as you access and use the materials on our website. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used.

When you supply any personal information to Bates, we have legal obligations towards you in the way we deal with that data. We must explain how we will use the information and tell you if we want to pass the information on to anyone else. In addition to the personal information that you may provide to Bates as you access and use the materials on the site, information that you submit to Bates in response to an email request for information or other outreach from Bates, or through Bates’ employment application processes, will also be treated in accordance with this Privacy Policy.

In this Privacy Policy, Bates describes the scope and breadth of our commitment to privacy. Bates may, in its sole discretion, amend this Privacy Policy from time to time. Any material changes to our policy will be reflected on this page, so that you remain informed about the information we collect and how we use it. By exploring and using this site, and by submitting information to Bates, you consent and agree to Bates’ use of such information as described in this Policy.

Any information you provide to Bates on this site will only be used by us or, at our direction, our website vendor. We use the information to supply you with our newsletter, event announcements, and occasional surveys or news.

Unless we are obliged or permitted by law to disclose it, your data will never be supplied to anyone outside the company except, in the case of our assessments (see below), to our data collection platform vendors. We will never sell or share our members' e-mail addresses.

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate procedures to safeguard and secure the information we collect online.

Information That We Collect, and How We Use It

Bates collects information from our users when they create their account for this site, when they request copies of publications, seek additional information regarding our services or employment opportunities, or register for conferences and other Bates -sponsored events. Some of Bates’ registration, enrollment, account setup and other forms may ask users to give us contact information, unique personal identifiers, payment information, subject areas of interest and/or demographic information. We may use this data to tailor the visitor's experience at our site or, if applicable, to assess candidacy and qualifications for employment with Bates. We sometimes aggregate demographic information, and the types of systems and browsers of users for internal purposes, so that we may better understand the user population of our site, identify subject areas of interest, and determine whether the site is designed to work with the computer settings of a majority of our visitors. Any payment information you may provide to us will be destroyed or erased after the transaction is completed.

Any personal information that you provide, such as your name, address, e-mail address, phone number, subject areas of interest, etc., allows Bates to inform you about updates to the service and to notify you about other products and services offered by Bates that may be of interest to you.

We will not sell, share, rent, or otherwise make available any of that information to other parties, except that we may disclose the information to third parties who perform services on our behalf and have a need to access the information in connection with those services. However, in such circumstances, we make those parties aware of our privacy policies and require them to honor those policies.

Individuals that subscribe to e-mail newsletters are given the opportunity to opt-out of promotions, news, and information at the time of sign up. Bates also provides users the opportunity to opt-out of receiving communications from us at the points where we request information. You may also feel free to contact us as indicated below.

Information collected about or from an individual is considered by us to be confidential and, therefore, is protected as such. Individuals receive feedback on assessments only from qualified and certified Bates coaches.

Although Bates has never been required to release information without an individual’s permission, it must be acknowledged that in extremely rare cases we may receive a court order requiring us to do so.

Data collected from surveys published by Bates are stored in our databases. Periodically, we may publish data on groups of people, though individuals are never identified in these reports. Organizations are identified only if prior written approval has been received from the organization. We may also provide organization summary profiles on groups of individuals within that organization if the number of individuals is large enough to be potentially meaningful.

If desired, response data can be removed from our databases. To do so, please write to info@bates-communications.com. To ensure that all assessment materials for individuals are received and scored, data are not typically deleted until 60-90 days after receipt of the “remove data” request.

E-Mail Addresses

We may collect the e-mail addresses at the point of subscription, of users who wish to receive e-mail notification of publications and press releases in identified subject areas of interest, and of those who send us e-mail messages or express interest regarding our services or employment opportunities or register for conferences and other Bates-sponsored events. However, we will not share any e-mail addresses with any third party or send unsolicited e-mail to any of the addresses we collect, except in the very limited circumstances set forth in this policy.

We use Salesforce and/or Hubspot as our Customer Relationship Management platforms. By submitting this form, you acknowledge that the information you provide will be transferred to Salesforce and/or Hubspot for processing in accordance with their Privacy Policy.

Cookies

When you use our sites, Bates will assign cookie files (“cookies”) to you, which are a small amount of information we send to your web browser. Cookies enable the computers operating our websites to differentiate between visitors and to track the patterns of activities engaged in by different visitors. By tracking such activities, the computers operating our websites can recognize a visitor and customize certain features for that visitor. We may also use aggregated, non-identifiable information regarding persons who visit our site in order to learn more about the use of the site and how we can improve it.

You may be able to modify your browser preferences to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose not to accept cookies, you may not be able to use those functions of the websites that require registration.

We may also receive IP addresses in the normal course of the operation of our website. An IP address is a number assigned to you by your Internet Service Provider so that you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others.

This Site may also use Google Analytics, a web analytics service provided by Google, Inc. and/or a web analytics service provided by HubSpot, Inc. Both tools use cookies to help the web team analyze how users use the site. The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google and HubSpot under their privacy policies:

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of your information by Google and HubSpot in the manner and for the purposes set out above.

Choice

Bates acts as a data collector on behalf of its clients. Bates does not disclose any personal data, whether collected through its websites or transferred directly to it from clients, to any third party except as required by law, as authorized by clients or to those working on behalf of Bates. Bates does not collect sensitive personal data (e.g. information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, or the commission or alleged commission of any offense).

Security

Bates has in place technological and operational security processes designed to protect personally identifiable information from loss, misuse, alteration, or destruction. Only authorized employees and contractors will have access to any data provided by you, and that access is limited by need. Each employee or contractor having access to any personally-identifiable information is obligated to maintain its confidentiality.

Data Integrity

Bates takes reasonable steps to insure: (a) that its use of personal data is consistent/compatible with the purpose for which it was intended and (b) that data is reliable for its intended use, accurate, complete, and current. Bates is not responsible for verifying the integrity of transferred, client-provided personal data. Instead, Bates relies on its clients for the accuracy of the data provided.

Data Retention

Bates will keep personal data, including data we process on your behalf, only so long as it is needed to provide services to you. We may retain and use this personal information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

Data Sharing

The use of information collected through Bates systems will be limited to the purpose of providing the service for which you have engaged with Bates. We are committed to respecting and protecting your privacy. Bates subscribes to the American Psychological Association’s code of ethics regarding the use of an individual’s personal data for research. This code is particularly concerned with protecting the rights of a person.

Bates is based in the United States and maintains its servers in the United States. If you are visiting from outside the United States with laws governing data collection and use, please note that by using this site and our services, your personal information will be transferred to the United States for processing.

Bates will also comply with government laws and regulations related to data collected by us for the purpose of providing the service for which you have engaged with us. This could require local data storage or duplication of data storage across geographic regions.

Bates will share your personal information with third parties only in the ways that are described in this privacy policy. We also limit the information we collect to the minimum necessary to provide outstanding customer service or to send you marketing emails, which you may opt out of.

All payment information you might provide to Bates is kept secure or destroyed after any transaction is complete.

Access

Upon request, Bates will provide you with information about whether we hold any of your personal information. You may correct, update, amend, delete or remove your personal information from any account, directory or testimonial on our site by making the change on your account or by emailing us at info@bates-communications.com.

Access to Data Controlled by Our Clients

Bates sometimes collects information under the direction of a client and, in such a case, may have no direct relationship with the individuals whose personal data we process. Bates acknowledges that you have the right to access your personal information. If you seek access or seek to amend, correct or delete inaccurate data, you should contact the client directly. If Bates has such information in its databases, you may contact us to remove it.

Log Files

As is true with most websites, Bates gathers certain information automatically and stores it in log files. This information may include IP addresses, browser types, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This automatically collected log information may combine with other information collected by Bates. This is done to improve services we provide, marketing efforts, analytics and site functionality.

Links

Our website contains links to other sites. Bates is not responsible for the privacy practices or the content of those websites. If you submit personal information to any of those sites, your information is guided by their privacy policies. You are encouraged to read carefully the privacy policies of any website you visit.

Social Media

The Bates website includes social media features such as the Facebook “like” button and other similar widgets. These features may collect IP addresses, which pages are being visited on our site, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Interactions with these features are governed by the privacy policy of the company providing it.

Information Request Forms

The information request form on the Bates website asks users to provide contact information such as name and email address. This contact information is used to send the visitor information about Bates. Our emails provide a method for individuals to opt-out of any future emails.

Registration Request Forms

Bates collects information from people wishing to register for any of our programs. This includes the person’s name, email address and, in some instances, their mailing address. This contact information on the registration form is used for all necessary contact related to the program.

Online Surveys

From time to time, Bates may post online surveys asking visitors for their opinions on a variety of subjects involving business, work, leadership and the like. Any demographic or profile data collected would be used for educational or research purposes only. Visitors are not required to provide any personal information in connection with these surveys.

Testimonials

With their consent only, Bates may display personal testimonials from clients on the site. Any client wishing to update or delete a testimonial should contact Bates at info@bates-communications.com.

Privacy and Assessment Data

As part of its offerings, Bates implements assessment projects/service offerings on behalf of its clients. Bates’ clients, their employees, and others participating in assessment projects are directed to Bates-controlled, third-party websites, through methods including email or print invitations. All of these third-party websites are GDPR compliant. Bates would be happy to provide you with the names of those sites so that you can learn more about their privacy policies.

Organizational assessment data is typically summarized in aggregate form by group(s). Bates and its clients have agreed to certain reporting metrics. Bates reserves the rights to use organizational demographic data to report results for varied groups/subgroups to better understand results and gain insight.

Individual multi-rater assessment data is typically summarized e.g., by each category of respondents.

As part of our mission to improve the quality of leadership in organizations, Bates gathers research data on organizations themselves, their leadership teams, and individual leaders. The data is then analyzed and the results are often published in summary reports or articles designed for wide circulation. By providing personal data to us, you agree that we may use that data to deliver the requested service and communicate information regarding our programs, products and services in which you may be interested.

Since the organizations and individuals who participate in our programs and other activities represent valuable resources for our research, the information we collect is stored in our databases and may become part of a research project. We have a strong commitment to protect the rights, privacy, and dignity of everyone who participates in these activities. As such, we would never disclose your identity in any research without your permission.

Assessment data collected about or from an individual as part of a leadership development program is shared with and explained to that person. It will never be disclosed to someone else without the individual’s expressed permission.

Compliance with Law

Bates complies with all applicable privacy laws and regulations. Bates may be compelled to surrender personal user or customer information to legal authorities without express user consent if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction. Also, in the event of a violation of the terms and conditions of use of this site or a violation of any restrictions on use of materials provided in or through this site, we may disclose personal user information to our affected business partners or legal authorities.

International Transfer of Information

Because Bates is a global organization, information collected on this Site or through other means may be transferred from time to time among the Bates offices or personnel, or to third parties located throughout the world, including offices located outside the European Economic Area, and this site may be viewed and hosted anywhere in the world, including countries that may not have laws regulating the use and transfer of personally-identifiable data. Bates complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries. Bates has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Bates’ certification, please visit http://www.export.gov/safeharbor/. By using the site, submitting information through the site, or submitting information to Bates through other means, you voluntarily consent to such international transfer and hosting of such information.

GDPR

We are continuously evolving our privacy policy to address the privacy laws around the world, including compliance with the General Data Protection Regulation (GDPR) which takes effect on May 25, 2018. The GDPR provides new rules for companies processing data about EU individuals with enhanced privacy rights.

In preparation for the GDPR, we are actively reviewing and updating our policies and procedures to help ensure that all data is handled appropriately. We are also reviewing and updating our relationships with our third-party service providers to help ensure that data is protected by third parties that may process or store your data in compliance with GDPR requirements. As we continue to take additional steps in this area, we will be reflecting those updates in this policy.

Change and/or Delete Information

You may access, correct, update, and/or delete any personally-identifiable information that you submit to Bates through this site or through other means. To do so, please either follow instructions on the page of the site on which you have provided such information or subscribed or registered or contact us at info@bates-communications.com.

Children

Bates understands the importance of protecting children's privacy, particularly in their online interactions. This website is not designed for and does not intentionally target or solicit to children 18 years of age and younger.

Contact Us

If you have any questions about this privacy policy, or Bates’ collection and use of information, please contact us at:

Bates Communications Inc.
40 Walnut Street, Suite 302
Wellesley, MA 02481

Tel: 800-908-8239 |info@bates-communications.com

Our Website Vendor

For information about the privacy policy of our third-party website vendor, please visit this link.

(Last updated May 2018)

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