Privacy Policy

Last Updated: July 28 2025

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Introduction

Behavioral Essentials (“Behavioral Essentials,” “we,” “our,” or “us”) respects your privacy and is committed to protecting it through this Privacy Policy and Notice (“Policy”). This Policy applies to the processing of Personal Data subject to the applicable privacy and data collection laws of the United States in compliance with various individual state laws (collectively, the “U.S.”) and the data collection laws of the United Kingdom, the European Union, and European Economic Area (collectively, “Europe”). This Policy is intended to inform Clients, Participants, coaching recipients, consumers, and users of our Services, websites: behavioralessentials.com and blindspotting.com (the “Websites”), and applications (“you” or “your”) about the types of Personal Data we may collect from you or you may provide to us and how we may use, disclose, maintain, and protect Personal Data, and the choices and rights you have regarding your Personal Data. “Personal Data” means any Data that is reasonably linkable to a particular individual or household, such as name, email address, mailing address, telephone number, and other data as more specifically detailed below.  This Policy applies to data collected through our Websites, mobile applications, account creation, assessments, communications with us in person, by telephone, or online, or through other means when providing our Services.

The following categories of data are not Personal Data:

  • Publicly available data;
  • Deidentified or aggregated data; or
  • Data otherwise excluded from the scope of U.S. or GDPR Privacy Laws.

By using or accessing the Services, or providing us with Personal Data in any way, you agree to this Policy and the practices described herein. If you do not agree with our policies and practices, do not use our Websites, mobile applications, or Services, and do not provide us with your Personal Data. This policy may change from time to time, and any updates will be posted on our Websites: behavioralessentials.com and blindspotting.com. Your continued interaction with us or use of the Services, Websites, or mobile applications after any policy changes is deemed to be acceptance of those changes.

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Our Business Purpose

We are a workplace development company that helps organizations hire better and grow leaders and teams. Behavioral Essentials provides assessment tools to businesses and other organizations (“Client(s)”) to support their workforce and development strategies. Through our Blindspotting™ products and platform, we provide coaching services to assessment participants (“Participant(s)”). As part of providing the foregoing services (collectively, the “Services”) to Clients and Participants, we may collect Personal Data as detailed below.

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Notice to U.S. Residents

This Policy provides the following information to U.S. residents:

  • Categories of Personal Data we collect;
  • Purposes for which we use Personal Data;
  • Categories of Personal Data we share with third parties;
  • Categories of third parties with which we share Personal Data; and
  • How US residents can exercise their rights under U.S. Privacy Law including:
    • The rights to access, correct, or delete Personal Data;
    • The right to obtain a portable copy of Personal Data;
    • The right to limit the use of sensitive Personal Data in certain circumstances;
    • The rights to opt out of targeted advertising, sales of Personal Data, or profiling;  
    • The right not to receive discriminatory treatment for exercising privacy rights;
    • The right to appeal our decisions about your requests.

Categories of Personal Data We Collect

The below outlines the categories of data we collect, how we may use the specific data in each category, and whether it is shared with third parties. Additional ways we may use the data we collect are provided in the section titled: Additional Purposes For Which We Use Personal Data.  

Non-Sensitive Personal Data: Identifiers

  • Real Name.  We use your real name to communicate with you and provide Services to you.  Some examples of this include interacting with you in person, online, or by phone, and linking your real name to assessments or coaching. We may receive your real name directly from you when you interact with us, or we may receive the real name of an assessment Participant from a Client when a Client provides it to us to conduct an assessment on a Participant.  We do not sell or share your real name with third parties outside of the Client-Participant relationship. We may use your real name when discussing or disclosing Participant assessment results with the Client who requested the Participant’s assessment.  
  • An Alias or Alternative Name. We do not request aliases; however, if you provide an alias or alternative name in lieu of your real name, it is possible that the alias or alternative name would be used or disclosed in the same manner indicated as Real Name above.  
  • Zip Code. We may use your zip code to verify your identity for credit card payments when processing payments through a third-party payment processor. We do not sell or share this data with third parties, except for our payment processors. We may also use zip code data as non-precise geographic data to conduct longitudinal research studies, market studies, analytics, and technological research and development. Zip Code data is retained by us, however it is de-identified and used as aggregated data when conducting market research or studies.  
  • Email Address.  We use your email address to communicate with you, to respond to you, to perform our Services, to conduct assessments and coaching, to fulfill contractual obligations, or to send marketing communications to you such as promotional offers, or information on products or events.  We may receive your email address directly from you when you interact with us, or we may receive the email address of an assessment Participant from a Client when a Client provides it to us to conduct an assessment on a Participant. We do not sell or share your email address with third parties.  
  • Phone Number. We may use your phone number to communicate with you in the performance of our Services.  We do not sell or share your phone number with third parties.  

Non-Sensitive Personal Data- Personal Characteristics

  • Age. We may use your age to conduct longitudinal research studies, market studies, analytics, and technological research and development. When you provide this data to us, it is linkable to you as an individual; however, it is de-identified when used for market research and studies. We do not sell or share this data with third parties when it is linked to an individual or household. We reserve the right to sell or share de-identified or aggregated data now or at any point in the future.
  • Gender. We may use your gender to conduct longitudinal research studies, market studies, analytics, and technological research and development. When you provide this data to us, it is linkable to you as an individual; however, it is de-identified when used for market research and studies. We do not sell or share this data with third parties when it is linked to an individual or household. We reserve the right to sell or share de-identified or aggregated data now or at any point in the future.    

Non-Sensitive Personal Data- Other

  • Non-Precise Geographic Location. We may use non-precise geographic location to conduct longitudinal research studies, market studies, analytics, and technological research and development. When you provide this data to us, it is linkable to an individual; however, it is de-identified when used for market research and studies. We do not sell or share this data with third parties when it is linked to an individual or household. We reserve the right to sell or share de-identified or aggregated data now or at any point in the future.    
  • Job Title and Organization. We collect job title and company/organization information to perform our coaching services for our Participants and to assist Clients with their workforce goals. We may also use this information to conduct longitudinal research studies, market studies, analytics, and technological research and development as de-identified data. We do not sell or share this data with third parties when it is linked to an individual or household. We reserve the right to sell or share de-identified or aggregated data now or at any point in the future.    
  • Signatures. In some instances, we may collect your signature when processing a payment or when you sign a contract. This data is used for payment processing and legal/contractual purposes and is not sold or shared with third parties aside from our payment processors or third-party document signing services. We do not sell or share this information.  
  • Events. If you register for an event that we host, whether in-person or online, we may collect relevant data such as your name, address, job title, company, phone number, or email address, as well as any specific data relevant to the event for which you are registering.
  • Job Applications. If you apply for a job with us, we may collect relevant information personally identifying information, including but not limited to, your name, phone number, email address, address, telephone number, current job position, job history, education history, references, cover letter, resume, and other similar job-application information.  
  • Any Other Data You May Provide. If you contact us directly, we may collect additional that you send. For example, when you contact our customer support team, we may request your name, email address, mailing address, phone number, or other relevant contact data to verify your identity and facilitate communication. We may also store the contents of any message or attachments that you send to us, as well as any data you submit through any forms or questionnaires.  

Sensitive Personal Data: Financial Data

  • Credit card, debit card, bank account numbers, or other payment data. If you sign-up for our Services, your payment-related data, such as credit card or other financial data, may be collected by third-party payment processors on our behalf and we may collect data including credit card numbers, name of cardholder, CCV number, bank account numbers, routing numbers, account holder name, bank name, address, zip code or email addresses to process payments, complete purchases, or send receipts. We do not sell or share this data with third parties except those processing payments on our behalf.  

You have the right to limit some uses of sensitive Personal Data. In general, you may direct companies not to use your sensitive Personal Data except as necessary to provide goods or services you have requested or to further certain other exempt purposes. We do not sell or share sensitive Personal Data for monetary gain or cross-context behavioral advertising. We use sensitive Personal Data for exempt purposes, such as to provide you with goods or services you have requested.  

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Internet or Online Data/Data We Collect Automatically When You Use Our Services

  • Device Data. We may collect data about the devices and software you use to access our Services, Websites, or mobile applications, including Internet Protocol (“IP”) addresses, web browser type, operating system version, device identifiers, data about your internet connection, usage details, and other similar data.  
  • Usage Data. To help us understand how you use our Services and to help us improve them, we may collect data about your interactions with our Services. This includes Data such as crash reports, session lengths and times, the pages or other content you view, and any searches you conduct on our site.
  • Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. We ask for user consent before placing non-essential cookies on your device.  

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Additional Purposes We May Use The Data We Collect

In addition to the purposes listed above, we may use data that we collect about you or that you provide to us, including any Personal Data:

  • To present our Websites and their contents to you.
  • To provide, maintain, improve, and enhance our Services.
  • To provide you with data, products, or services that you request from us.
  • To facilitate purchases of products or Services that you order.
  • To fulfill any other purpose for which you provide it.
  • To understand and analyze how you use our Services and develop new products, services, features, and functionality.
  • To host events.  
  • To communicate with you, provide you with updates and other data relating to our Services, provide data that you request, respond to comments and questions, and otherwise provide User support.
  • For marketing and advertising purposes, including developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you.
  • For compliance purposes, including enforcing our Terms, Conditions and Disclaimer policies or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Websites or any products or services we offer or provide through it.
  • To book a demonstration of our Services.  
  • To allow you to participate in interactive features on our Websites.
  • To administer assessments, schedule coaching sessions, and provide feedback to Clients in line with their organizational goals.  
  • To deliver personalized reports and development resources.  
  • To evaluate and process applications for jobs with us.  
  • To fulfill any legal or statutory obligations we may have.  
  • In any other way we may describe when you provide the data.
  • For any specific purpose detailed in this notice.
  • To detect and prevent fraud and respond to trust and safety issues that may arise.

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How We May Collect Data

Specific instances of how we may collect data include:

  • Directly from you when you provide it to us.
  • Automatically as you navigate our Websites. Data collected automatically may include usage details, IP addresses, and data collected through cookies, web beacons, and other tracking technologies.
  • Data that you provide by filling in forms on our Websites. This includes data provided by utilizing any “Contact Us” form, requesting assessments on our Websites, subscribing to email lists, or subscribing to our services. We may also ask you for data if you report a problem with our Websites.
  • During consultation or onboarding calls, Clients may share optional information about their organization, team structure, or development needs, which we use to recommend relevant products or coaching pathways.  
  • Corresponding with us in writing. Records and copies of your correspondence (including email addresses) may be retained if you contact us, or for any other reason that may be required by law.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Transactions you carry out through our Websites.  
  • Your search queries on the Websites to improve our Websites.
  • You also may provide data to be published or displayed on public areas of our social media sites that may be transmitted to other users of the social media sites or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages and set specific privacy settings on our social media accounts, please be aware that no security measure is perfect or impenetrable. Additionally, we cannot control the actions of other users of the internet with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions and their content will not be viewed by others.

If you delete your User Contributions from our Websites or social media platforms, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users.

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Data We May Receive From Sources Other Than You

We may receive data about you from other sources, including third parties that may include data a Client provides regarding a Participant. We may also receive data about you from social media platforms, for example, if you interact with us on social media platforms or access our social media content. Any data we receive from third parties is governed by the privacy settings, policies, and/or procedures of the relevant organizations, such as LinkedIn® or other social media, and we encourage you to review their privacy policies when interacting with us on these platforms.

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Data We Collect Through Automatic Data Collection Technologies:

As you navigate through and interact with our Websites, hardware or software, we may use automatic data collection technologies to collect certain data about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Websites, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Websites.
  • Data about your computer and internet connection, including your IP address, operating system, and browser type.

The data we collect automatically is statistical data, and we do not collect Personal Data automatically, but we may tie this data to Personal Data, or maintain it or associate it with Personal Data we collect in other ways or receive from third parties. This helps us to improve our Websites and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store data about your preferences, enabling us to tailor our Websites to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.  
  • Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store data about your preferences and navigation to, from, and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).  

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Disclosure of Your Data

We may disclose aggregated data and data that does not identify any individual without restriction.  

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

  • To our subsidiaries, affiliates and representatives as needed to provide our Services.
  • To contractors, service providers, and other third parties retained in connection with the provision of our Services. These companies are only permitted to use the data to help us provide our Services, not for their own purposes.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Behavioral Essentials or Blindspotting’s™ assets, whether as a restructuring or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Behavioral Essentials or Blindspotting™ about our consumers is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to refer an individual or business to our Services, we may transmit the contents of that email and your email address to the recipients.
  • To our partners, including any analytic service partners or third-party advertising partners, who have their own privacy policies.  
  • If you are a Participant, your data may be shared with the Client organization that requested the assessment or coaching, to provide insight and support aligned with their goals.
  • For any other purpose disclosed by us when you provide the data.
  • To respond to your requests.
  • With your consent.

We may also disclose your Personal Data:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of sale and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • To protect your, our, or others’ rights, property, or safety. In particular, we may disclose relevant data to the appropriate third parties if you post any illegal, threatening, or objectionable content on or through the Services.

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Your Rights And Choices

  • Our Communications. From time to time, you may receive marketing or other informational email messages from us. You can unsubscribe from our promotional and informational emails via the link provided in the emails. Users may continue to receive administrative messages necessary to provide our Services after opting out of receiving promotional messages from us. For example, you may receive an order confirmation email or assessment and coaching emails that fulfill the objective of our Services.  
  • Tracking Technologies and Advertising. Although we currently do not use cookies on our Websites, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. Most web browsers allow you to manage cookies through the browser settings. To find out more about cookies, you can visit www.aboutcookies.org or allaboutcookies.org.

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Third Party Content

Our Services, Websites, or mobile applications may contain links to other Websites, products, or services that we do not own or operate. We are not responsible for the content provided by, or the privacy practices of, these third parties. Please be aware that this Privacy Policy does not apply to your activities regarding these third-party services or any data you disclose to these third parties. We encourage you to read their privacy policies before providing any data to them.

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Security

We make reasonable efforts to protect your data by using administrative, technological, and physical safeguards designed to improve the security of the data we maintain and protect it from accidental loss, unauthorized access or use, or any other inappropriate or unlawful processing. However, because no data system can be 100% secure, we cannot guarantee the absolute security of your data.

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Retention

We retain Personal Data to provide Services to you, for our business and marketing purposes, and for any other legal or security reasons we may need the Personal Data.  Personal Data retention periods may vary depending on how long the Personal Data is needed to fulfill a business purpose for which it was collected. Our recently implemented data retention practice is to review our database biannually to determine if an individual has not utilized our Services or interacted with us in over two years.  Personal Data of the identified individuals will be analyzed for if it still meets a business purpose and will be de-identified if the Personal Data no longer serves a business purpose. We will delete the specific pieces of Personal Data that do not meet a business purpose from our database.  

Some examples of instances where we may retain Personal Data for longer than the period indicated above include:

Marketing: We may retain real name and email addresses for the business purpose of providing marketing emails to you, including information on new products or events you may be interested in. You may unsubscribe from our marketing emails at any time by utilizing the “Unsubscribe” link within our marketing emails. We may still use your email address to communicate with you to provide Services or fulfill orders even if you unsubscribe from marketing emails.  

Job Applications: Job applications may be retained to comply with any state or federal laws regarding employment practices.

To carry out our obligations and enforce our rights arising from any contracts, agreements, or other legal documents entered into between you and us, including for billing and collection: We may retain your name, signature, emails, or other writings to prove the existence of or enforce contracts, as proof of consent, and for other legal purposes involving the Services.  

For compliance purposes: Personal Data may be retained to enforce our Terms, Conditions and Disclaimer policies or other legal rights, or as may be required by applicable laws and regulations or if requested by any judicial process or governmental agency, including but not limited to, litigation holds, court, regulatory, or governmental orders or policies.

If you would like your Personal Data retained for longer than the timeframe indicated in this Policy, you may submit a request in writing to support@blindspotting.com or support@behavioralessentials.com for our review.  

We may indefinitely retain de-identified portions of data for longitudinal research studies, market studies, analytics, and technological research and development. We reserve the right to sell or share de-identified or aggregated data now or at any point in the future.

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Accessing and Correcting Your Data

You may send us an email at info@behavioralessentials.com, info@blindspotting.com or call us toll free at 866-379-4549 to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data in its entirety without also ending any Services you may have already paid for or subscribed to. We may also be contacted through the above means to appeal any decision about your request. We may not accommodate a request to change data if we believe the change would violate any law or legal requirement or cause the data to be incorrect.

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Data Collection from Minors

Our Services are not intended for, and we do not knowingly collect any Personal Data from, children under the age of 13. If we learn we have collected or received Personal Data from a child under 13 years old, we will delete that Personal Data. If you are under 13, do not attempt to use our Services, make any purchases through our Websites or use any interactive or public comment feature that may exist or may become available on the Websites or provide any data about yourself to us, including your name, address, telephone number, email address, or any other data. If you believe we might have any data from a child 13 years of age or under please contact us at info@behavioralessentials.com, info@blindspotting.com or call us toll-free at 866-379-4549 so we may investigate.  

Our Blindspotting™ assessment and coaching services are not intended for use by minors under the age of 18. If you are under 18, do not attempt to use our Blindspotting™ services, make any purchases through Blindspotting™, use any interactive or public comment feature that may exist or may become available on the Websites or provide any data about yourself to us, including your name, address, telephone number, email address, or any other data.  

Our Behavioral Essentials assessment tools are not directed at minors, however, unemancipated minors aged 15 years and older may use our assessment tools and Behavioral Essential services when a Client refers them as part of an employment or potential employment relationship. We do not sell Personal Data or share Personal Data of minors with third parties, and we use Personal Data for minors in the same manner as  described within this Policy. Any Client, Participant or other individual who would like to delete their Personal Data may contact us as described below.  

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California Resident Privacy Rights

Effective January 1, 2023, California Residents have a right to:

  • Know what Personal Data a business has collected, sold, shared for cross-context behavioral advertising, or disclosed about them, including the specific pieces of Data held.
  • Require a business to correct inaccurate Personal Data.
  • Require a business to delete Personal Data (unless the Data is required to be maintained by law or for certain statutory business purposes)
  • Opt-out of the sale or sharing of their Personal Data for cross-context behavioral advertising.  
  • Restrict the use and disclosure of their sensitive Personal Data as defined by California statute; and
  • Not be retaliated against for exercising these rights.  

The data we collect and how we use your data are outlined above.  We do not sell Personal Data to third parties in exchange for monetary compensation or other valuable consideration. We do not currently share Personal Data for the purpose of cross-context behavioral advertising. California residents have a right to request twice in a twelve-month period, the following:

  • The categories of sources from which we collected Personal Data
  • Our business or commercial purposes for collecting that Personal Data
  • The categories of third parties to whom that Personal Data was sold or disclosed for a business purpose; and
  • The business or commercial purpose(s) for which the Personal Data was sold or disclosed

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Exercising Your Rights

You can submit a request regarding your privacy rights by emailing info@behavioralessentials.com, info@blindspotting.com or calling us toll-free at 866-379-4549. To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We may ask you for additional data as part of this process, (i.e. the last 4 digits of a phone number or for other data contained in our records, or by sending a link in an email, etc.). If you do not complete the verification process, we may be unable to process your request. Any data you provide to authenticate your identity will only be used to process your rights request and not for any other purpose.  

We will respond to your rights request within 45 days (or within 15 days when required by applicable state law), and in certain cases, we may inform you that we will need an additional 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay acting on your request until we can appropriately verify your identity and the request as authentic. Also note that each of your rights are subject to certain exceptions that may permit or require us not to process your request.

We reserve the right to decline to process, or charge a reasonable fee for, requests that are manifestly unfounded, excessive, or repetitive.

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by using the method(s) described above. We may require verification of your authorized agent’s authority in addition to the Data we require for verification of your identity.

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Notice of Right to Opt-out of Sale/Sharing for Targeted Advertising

U.S. Privacy Law gives U.S. residents the right to direct a business that sells their Personal Data or shares it for targeted advertising purposes to stop selling and/or sharing their Personal Data at any time. As used here, “selling” means exchanging Personal Data with a third party for money or anything of value, and “sharing for targeted advertising” is the practice of displaying advertisements to a person that are selected based on that person’s activities over time and across non-affiliated Websites or applications. We do not currently sell Personal Data or share Personal Data with third parties as described above.

International Users

Our Services are operated and hosted in the United States. If you are accessing the Services from another country, your Personal Data may be transferred to the U.S. for processing in accordance with this Policy. By using the Services, you consent to this transfer and the application of U.S. privacy laws, which may differ from those in your home country.

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Changes to our Privacy Policy

It is our policy to post any changes we make to our privacy policy on our Websites with the date of the change displayed on the first page of the updated policy. You are responsible for periodically visiting our Websites and this Privacy Policy to check for any changes. By continuing to use our Services or providing us with Personal Data after any such updates, you are deemed to accept any changes.  

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Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: info@behavioralessentials.com, info@blindspotting.com or call us toll-free at 866-379-4549

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