Beecher Reagan Privacy Policy 

This statement sets forth Beecher Reagan’s Privacy Statement for beecherreagan.com and data collected as part of the Verity Leadership AssessmentSM process. This page describes the practices that Beecher Reagan will follow with respect to the privacy of users of this site, and of the Verity Leadership Assessment.

Privacy and Cookies Policy

Beech Reagan is committed to protecting your privacy. This Privacy and Cookies Policy (“Policy”) explains the types of personal data we may collect and how we use, share, store, and secure your personal data.

For purposes of this Policy, “personal data” means the information either on its own or in combination with other information that identifies you or allows you to be identified, such as your name, physical address, email address or other contact details, online identifiers, details of your use of our website navigational information, and any information that becomes personally associated with you.

Data and the Verity Leadership Assessment

Beech Reagan is committed to protecting the privacy of all individuals involved in the Verity Leadership Assessment process. Individual responses on the Hogan assessments produce reports used in the Verity process for the purposes of executive coaching and leader acceleration.

The Hogan assessment data and qualitative insights gathered will be used to summarize strengths and opportunities for leadership acceleration. Insights and assessment data may be shared with the client organization; however, individual Hogan results will be the sole property of the participating individual. Upon client request, individual data may be aggregated into team, practice area, or organizational level reports for the purpose of enhanced group development.

By proceeding with the Verity Leadership Assessment, and Hogan profile series, you are acknowledging your participation in the assessments and agreeing that the data and insights gathered may be shared with the client company.

Beecher Reagan takes utmost care to ensure that all information or data collected is handled professionally and with the purposes of enhancing and accelerating individual, team and organizational performance.

Personal Data Collection

We collect personal data in a number of different ways:

• When you visit use one of our websites and/or use online applications we provide (“Sites” or “Site”);

• When you voluntarily provide your personal data to us (for example, when you opted-in for our electronic mailings, when you registered for an account on a Site, when you completed a web form to access an application or register for an event) or when it is provided to us by the company or organization you work for;

• When you participate in webinars, seminars, trade fairs, or other events;

• From publicly available sources (for example, LinkedIn or corporate websites);

• When you use our services (for example, customer care support, technical support); when it is necessary for us to provide or receive services or otherwise do business with you or the company or organization you belong to; and/or

• We buy services from selected third party vendors that utilize aggregated cookies data to target ads based on common characteristics, such as industry;

• When we have disclosed the collection and intended use to you in advance through this Policy or at the time of collection.

We also combine the personal data that we collect from different sources for the uses further described below (for example, to identify better the areas of your business interests).

You are not required to provide personal data to us; however, if you do not, we may not be able to provide certain services or information you may request.

We collect a number of different types of personal data:

• Relevant business contact information, such as your name, the name of the company or organization you work for, your business address, your location of operation, your title, your email address, your telephone, and other business contact details;

• Information we obtain from your registrations for and attendance of webinars, seminars, trade fairs, and other events. In connection with such events, we may also collect information on your administrative assistant, your dietary requirements, your gender, and your partner;

• We also automatically collect information your browser makes available whenever you visit a Site, through the use of commonly used tracking technologies, such as cookies and web beacons. This information includes your Internet Protocol (IP) address; the source of a Site visit; the domain name of the web site from which you came; number of visits; pages viewed; links, likes, comments, shares clicked; browser type, version, and language; and/or the date and time of your query.

For the avoidance of doubt, there are certain types of personal data we typically do not collect:

• We do not proactively collect any personal data considered as sensitive personal data (for example, health-related data);

• We do not proactively collect private financial information about you, nor information about your private home and family;

• Our Sites are for persons aged 16 years or older;

• We only conduct B2B business and do not engage in B2C business.

Our Use of Your Personal Data

This Policy provides you with information as to how we may use your personal data. For certain specific applications, we may inform you with additional information about how we will use your personal data when you apply for or enter such applications. We hope this will help you make an informed decision about sharing your personal data with us.

We may use personal data that you provide to us for the following business, transactional, and marketing purposes:

• Contact you about a specific request or inquiry;

• Deliver requested services or business transactions we have agreed;

• Administer our Sites and your account(s) (for registered users); analyze trends and improve functionality of our Sites;

• Customize and personalize our Sites and selected third party websites to the preferences you have entered and personalize and improve your online experience, which may include matching and serving targeted advertisements about our products, services and solutions to make the information delivered more relevant to you; we utilize ad networks to display targeted digital advertisements on third party web sites;

• Consider an application for employment from you;

• As deemed necessary to protect our legal rights and our property, to protect other users or any third party, or to prevent personal injury or loss;

• Communicate (via email, regular mail or telephone) with you about products, services, and events of Beech Reagan and its business partners that you may be interested in;

• Generate leads (the identification of particular interest an existing or potential customer may have in our products, solutions and services; for example, based on your level of interest and expressed desire for follow-up information, such as by downloading a document, visiting certain website pages or making a direct inquiry with us) for us and our business partners (for example, authorized distributors) for business promotion purposes, to provide you better support and services and/or to better respond to your requests or inquiries;

• Invite you to provide feedback or participate in customer surveys; understand better the nature and quality of the provision of our services; improve and further develop products, services, and solutions; and/or

• Use such information in the context of our overall customer relationship management (CRM).

For our marketing activities, we process your personal data in our CRM systems. Every promotional communication will include a link allowing you to opt-out of receiving such communications in the future and to manage your preferences to include or exclude certain communications.

The legal basis for using and processing your personal data are, as the case may be, your consent; necessity for responding to inquiries; the performance of requested services; the entering into and performing of contracts and business transactions; and our legitimate business interests.

Information Sharing with Third Parties

Within Beech Reagan, we restrict access to your personal data to employees who need to know the information for the above use purposes. We do not rent or sell your personal data to other companies or individuals. However, we may share your personal data with third parties outside of Beech Reagan for the following purposes:

• With authorized distributors, channel partners and other suppliers selected by us, who are involved in providing our products, services or solutions to you, to communicate with you about Beech Reagan and related products, services, and solutions that you may be interested in, or to respond to your requests or inquiries;

• With selected service providers and subcontractors who provide services to us or on our behalf, such as hosting websites, sending out information, conducting surveys, IT services, analyzing data, organizing events, and other professional services. We only provide these service providers with the personal data they need to deliver their services to us or on our behalf;

• With selected service providers and subcontractors who provide services to us or on our behalf, such as advertising and marketing services, including telemarketing; we provide, for example, information collected about you through our cookies in order to generate and provide advertising about our products, services and solutions that are more relevant or useful to you;

• With governmental and/or regulatory authorities where we are required by applicable law or pursuant to a court, administrative or similar order.

We take commercially reasonable steps to implement contractual safeguards and to promote that the third party companies mentioned above:

• Protect your personal data and keep it secure and confidential;

• Do not collect, use, or disclose your personal data for any purpose other than to perform such functions for us or on our behalf and in accordance with applicable privacy laws and our instructions;

• To not keep this information longer than is needed; and

• To report to us immediately in case of a data breach incident leading to the accidental or unlawful theft, loss, disclosure of or access to personal data.

We also may offer certain services where you can post information on a Site, which will then, be available to other visitors of the Site. Examples are discussion forums and comments on blogs. When you post, basic information identifying you as the poster will be made available to other visitors together with your posted information. This information includes your name or alias, and where relevant, may include other information such as your country or the name of the company or organization for which you work. We are not responsible in any respect for the personal data and other information you may choose to submit thereon. We do not verify the information that is posted and cannot be held liable for any inaccurate, incomplete, unauthorized, illegal and/or inappropriate postings. We may also display statistical, reputational, and other similar information, for example the number of forum posts you have posted or how useful other visitors have rated your posts. For details, please see the help pages for each service.

Aggregating Information

Aggregated or anonymized personal data does not personally identify you or any other user of the Sites. It may be used for statistical analysis and administration, including analysis of trends, tailoring products and services, risk assessment and analysis of costs and charges in relation to our products, services, and solutions.

Our Use of Cookies to Collect Information from You

What are Cookies?

A cookie is a small text file that is downloaded to your computer’s hard drive or stored in your web browser’s memory when you visit our Sites. Cookies help us understand which information and business interests you may have. Cookies help us improve the performance of our Sites and your experience using them. Cookies also allow us to remember your preference settings and to track trends and patterns in how visitors navigate our Sites.

What Cookies or Similar Technologies Do We Use?

Our Sites use several types of cookies: “first party” cookies (used by our website only); “third party” cookies (cookies originating from a third party website); “session” cookies (expire at the end of your browser session); and “persistent” cookies (stored on your device between browser sessions allowing us to remember your preferences or actions).

Our use of cookies generally falls into four categories:

• Strictly Necessary Cookies: these cookies enable you to move around our Site and use its features. These cookies do not gather information about you or remember where you have been when you are browsing our Site;

• Analytical Cookies: these cookies collect information about how you and other visitors use our Site such as how they get to our Site, how often they visit, and which parts of the Site they use. We use this information to improve the capabilities of our Site and ensure that it meets your needs;

• Functionality Cookies: these cookies allow us to store information about the choices you make when you visit our Site and deliver more enhanced personalized content. For example, functionality cookies show when you are logged in to our website and help us remember your user preferences;

• Targeting Cookies: these cookies collect information about you that is used to deliver advertisements that are more relevant to you and your interests.

Our Sites and emails may also contain small, clear graphic images known as web beacons. Web beacons help us identify user behavior such as the number of users that visit specific pages of our Site or whether the email messages we send have been opened or acted upon.

Setting Your Cookies Preferences

The “help” feature on most browsers will tell you how to stop your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on settings or visiting the website of its manufacturer. For more information about cookies, please visit: www.allaboutcookies.org.

You may deactivate cookies in commonly used browsers. See instructions in these links:

• Internet Explorer

• Google Chrome

• Mozilla Firefox

• Safari

For information about making choices with regard to digital advertising, please visit:

• In the USA: Digital Advertising Alliance (DAA)

• In Europe: European Interactive Digital Advertising Alliance (EDAA)

• In Canada: Ad Choices: Digital Advertising Alliance of Canada (DAAC)

We utilize Google Analytics to understand how visitors are using our Site. You may opt out of Google Analytics here: Google Analytics Opt-out Link.

Direct Marketing

As noted above, we may wish to provide you with information about existing and new products, services, solutions, about webinars, seminars, trade fairs, and other events, and about promotions and offers, which may be of interest to you. We may also invite you to take part in market research or request feedback on our products, services, and solutions. This communication may occur by email or telephone (telemarketing).

We will obtain your consent for direct marketing through opt-in, where we are required to do so in accordance with applicable laws, and will keep track of the consent(s) provided by you.

We will ensure that any direct marketing or market research that you receive or are contacted about by e-mail will provide a simple means for you to withdraw from such further e-mail communication. For example, we may provide you with an ‘unsubscribe’ link in emails, or an email address where you can send an opt-out request.

In such cases, we would not necessarily remove all your personal data from our database(s) but would note and respect your changed direct marketing preferences.

Obtaining Your Consent — Communication Preferences

You may gain a lot of information about our services and solutions without having to provide any personal data. However, for certain services, information and events we may require and request certain personal data. This information will enable us to provide you with additional relevant information or service and to use it for the other purposes described in this Policy or described specifically for the requested service, information or event.

We will request, where required by applicable laws, that you grant your explicit consent for our online, electronic direct marketing activities, and for the use of our cookies. Where required, we will request that you grant your explicit consent for us to collect and use your personal data as explained in this Policy.

Such consent will be requested within the web form or hardcopy form used to collect your personal data and/or provided to you to confirm your registrations or preferences (for example, for offline activities, such as trade fairs, seminars, and other events).

In certain cases, we may also request you to confirm your consent through a link in a follow-up email (double opt-in).

Information Security — Cross-border Transfers

We have adopted reasonable, risk-based, technical, and organizational measures, which seek to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

Unfortunately, we cannot guarantee the security of any transmission of personal data over the Internet, via email or other electronic communication. We also cannot guarantee the security of different methods of electronic storage. Electronic communications such as via email are not secure unless they have been appropriately encrypted. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted or exchanged between us. You therefore accept the inherent security implications of dealing online and through email and will not hold us responsible, unless a security breach incident has been caused by the specific gross negligence of Beecher Reagan, its subsidiaries or its agents.

Given the nature of our business, the information you provide to us may be stored in and transferred to countries that offer varied levels of data protection. Often, the personal data we use under this Policy is on cloud applications and servers, which may be located around the globe. We may use and store personal data that we hold about you in any country in which we maintain offices. Transfers of personal data from the European Economic Area (EEA) to our facilities in the USA are covered by intercompany data transfer agreements meeting applicable EU privacy law. In addition, when your personal data is shared by us with or transferred by or to third parties outside of the EEA, where required, with these third parties we generally enter into data processing agreements and/or Standard Contractual Clauses meeting applicable EU privacy laws.

Retention

We retain your personal data in our active systems as long as you have accessed or used our Sites and services or have interacted with us online or offline over the past twelve months, and as long as we may need the information for the purposes described in this Policy. Beyond this period, we archive your personal data in a secure environment or delete it.

If you don’t log on to one of our Sites for at least twelve or more months, you hereby agree that we may permanently delete your accounts and all the data associated with it.

We may retain and use your information for longer periods as necessary to comply with our legal obligations, to resolve disputes and/or to execute and enforce our agreements.

Links to Other Websites

Our Sites may contain links to other websites. We are not responsible for the content, terms of service, security, and privacy practices of these other websites. Your access and use of such links or websites remains solely at your own risk. You should be aware of this when you leave our Sites and we encourage you to read the privacy statements on other websites you visit.

How to Access, Correct, or Delete Your Personal Data

Under applicable privacy laws, you have certain rights in relation to the personal data we hold about you, such as rights of information about and access to your personal data, rights to rectify your personal data, rights to reject or restrict certain processing, rights to delete your personal data and rights to be forgotten.

A number of our Sites (for example, where you have a registered account) allow you to see the personal data we hold about you, to amend and correct this information and to deactivate your registration yourself.

You can also request for the exercise of those rights by contacting us using the below Contact Us information or through the Contact Us form that is accessible at the top of each page within the beecherreagan.com domain.

Contact Us

If you have questions regarding this Policy or our handling of your personal data, please contact our Office at connect@beecherreagan.com.

Changes to this Policy

Please note that we may update or change this Policy from time to time. When we do, we will revise the last updated notice at the bottom of the Policy. If the changes are material, we will also provide a more prominent notice on our corporate website. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

This Policy was last updated on July 25, 2022.