Privacy Matters

CONFERRR DOES NOT SELL YOUR PERSONAL DATA UNDER ANY CIRCUMSTANCES.

 

Conferrr Cares About Your Privacy

Last Update: January 25, 2025

 

At Conferrr, we deeply value your privacy and prioritize the psychological safety of our advisory environment. Whether you’re an HR Consigliere providing services, a User of our services, a User Organization contracting on behalf of Users, or a visitor to our website, we believe you should clearly understand how we collect, use, and share your data. Our goal is to communicate this as clearly and simply as possible.

Depending on the experiences you use, we may provide additional privacy notices at the time we collect your data.

 

Privacy Policy Table of Contents

1. Introduction and Definitions
2. What Data We Collect
3. How We Use Data
4. How We Share Data
5. Your Choices, Rights and Obligations
6. Other Important Information

 

1. Introduction and Definitions

This Privacy Policy describes our privacy practices relevant to the Site and Services, and the impact these practices have on Contributors, Site Visitors, Advisors, Users, and User Organizations. Each term is defined below. Let’s start with a brief overview of what we do, how and where we might be collecting data, and then define key terms.

Conferrr, a subsidiary of Shockingly Different Leadership [a.k.a. SDL] (“Conferrr”) is a private HR Advisory service that helps individuals, companies and Boards with HR-related issues at work.

We distinguish between individuals who receive Services directly via the website (referred to as “Users”) and the entities that contract with us to provide Services or Consulting to their employees or others (referred to as “User Organizations”). We collect, use, and share data differently for Users and User Organizations, although in some cases, they may overlap. If you receive Conferrr Services through your employer or another sponsoring organization, please note that limited data may be shared with your User Organization as a result of your use of Conferrr.  For example, while the details of your conversations will not be shared, trends of the topics the full organization discussed may be highlighted, such as “desire for hybrid work arrangements.”

We also collect data from our HR Consiglieres (“Advisors”), who typically contract with us to provide Services to Users, and from visitors (“Visitors”) to our website, www.Conferrr.com, and its subdomains (the “Site”).  If you apply for a job with Conferrr, you will be referred to as an “Applicant.” Lastly, if you provide a response to a User assessment, such as our 360 Feedback Tool, you will be referred to as a “Contributor.”

When data is associated with an identified or identifiable natural person and is protected as personal information under applicable data protection laws, we refer to it as “Personal Data.”  Please note that certain local laws may use the term “personal information” instead of “Personal Data,” but for the purposes of this Policy, Conferrr considers these terms interchangeable.

 

2. Data We Collect

2.1 Data you provide us

Data From Our Website

If you are a visitor to our Site, we and trusted third parties acting on our behalf will collect certain information. We use cookies and similar technologies (e.g., web beacons, pixels and ad tags) to collect data (e.g., device IDs) from our public Site to recognize you and your device(s) on, off, and across different Services and devices where you have engaged with our Site. We also allow third parties to use cookies as the Cookie Policy describes, including to assist in our marketing and advertising campaigns. We may also collect, or rely on others who collect, data about your device where you have first engaged with our Site (e.g., ad ID, IP address, operating system and browser data) so we can provide our Visitors with a better user experience. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

Data From Applicants

We collect personal information when you apply for a job with Conferrr. This includes your name, email address, phone number, location, and work history, which we use to evaluate your qualifications and communicate with you throughout the application process. Conferrr works with third-party vendors to assist in this process, and we will provide appropriate disclosures where these systems access your personal data. If any of these systems require highly sensitive personal data or request session recordings, you will be notified beforehand.

If you are an Applicant based in the European Union, U.K., or California, please review the Applicant Privacy Notice for detailed information on the personal information we collect, how we use and disclose it, the legal basis for doing so, and your rights regarding your data.

In compliance with the EU-U.S. Data Privacy Framework (“DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Conferrr commits to cooperate with and follow the guidance of the EU data protection authorities, the U.K. Information Commissioner’s Office, and the Swiss Federal Data Protection and Information Commissioner regarding any unresolved complaints about our handling of human resources data in the context of the employment relationship.

 

Data From Advisors

If you are an Advisor, we collect data when you submit an inquiry to provide advisory Services for us, when you use the Platform, when you request technical support, and when you otherwise initiate communication with us.

We never require Advisors to provide us any sensitive Personal Data (e.g. financial data), although we may request demographic or other personal data from Advisors when we are testing a new tool or feature, staffing a specific project for customers, or conducting research studies. The type of demographic or personal data we may request includes gender, race, ethnicity, specialized skills such as ASL, or for federal programs, your citizenship. When asking for demographic data, Conferrr does so because we believe it will improve the Services for our Users and Advisors; however, providing such personal information is optional.

We may ask for your consent as an Advisor to record your advisory session for training, research, or additional purposes as further described in section 2.6, in which case we may collect data capturing your image or voice, or a recording transcript to analyze it for the betterment of the User and your future advisory sessions. Conferrr understands video recordings may capture sensitive personal information; therefore, where possible, Conferrr will minimize the amount of personal data being accessed by analyzing the recordings after de-identification or conducting analysis on the transcript rather than the full video. We discuss this further within Section 2.6.

As an Advisor, we may ask you to provide us data to improve your experience with Conferrr. For example, we may ask Advisors to review your advisory experience and for personal preferences within your Advisor profile. In all circumstances, your decision to provide Conferrr with Personal Data has no impact on your role as an Advisor, and you may withdraw consent at any time by emailing letsconferrr@conferrr.com .

 

Data From Users

If you are a User, we collect data when you register for a ConferrrNow Session or when you join the Conferrr Ally Network. We require certain Personal Data to register your account, such as your name, email address, phone number, role or title, and country and state when applicable.

We require this data to create your account, ensure you are matched with an Advisor in an appropriate time zone, ensure we have minimum location data to honor your specific privacy rights, and ensure you receive applicable surveys or questionnaires commensurate with your management level. If your access to the Conferrr Services is being provided by your User Organization, this type of data may be shared with Conferrr from your User Organization.

We collect data to provide and improve your experience. For example, we may ask Users to:

• complete surveys to help us match you with an Advisor that aligns with your advisory goals
• review your advisory experience, and
• enter your personal preferences within your User or Advisory profile, such as preferred pronouns and preferred language.

Your sponsoring User Organization will never receive access to your individual conversations or personalization responses although they may see aggregate and de-identified reports of all Users connected to your sponsoring Organization so long as our data scientists can confirm a minimum threshold of Users from your organization to maintain anonymity.

We collect usage data from Users accessing our websites, such as which programs you respond to and attend, your session ratings, when you attend an advisory session, your employment details, and any other usage data you share with us, or your User Organization shares with us, in connection with Conferrr Services.

Your sponsoring User Organization will receive information from Conferrr about your usage in the following ways:

• Individually identifiable data, such as your registration date, number of advisory sessions completed, and similar engagement level metrics. We will never provide your sponsoring Organization details about the specific content of your advisory sessions, or the individual topics discussed.
• Aggregated and de-identified insights on the topics and themes discussed by all Users within your sponsoring Organization, as discussed within Section 4 below.

 

Data From Contributors

To participate in a user assessment, Contributors must create an account with us. We collect the following information from Contributors:

• Email address and password.
• Feedback responses.
• Metadata, including account creation time, time spent on assessments, location data (country, city, region), and language and browser information (IP address, browser type and version, operating system).

We use Contributor feedback responses to generate anonymized reports for the User requesting feedback, ensuring the Contributor’s identity remains confidential.

 

2.2 Data we collect about Users from others

If you are a User registering for Services through a license purchased by a User Organization, which may or may not be your employer, the User Organization may provide us with certain demographic data about you. If applicable, the User Organization may share employment data such as your hire date, job changes, or anything else your sponsoring Organization may choose to provide to Conferrr. If you as a User have concerns about this data collected, please speak with your Conferrr program manager or your contact at your User Organization.

2.3 Aggregated data from Services use

Whether you are an Advisor or User, we may aggregate and de-identify the data related to your use of the Services apart from what has been detailed above. We may analyze your usage data and content when it is uploaded, sent, received, or stored. We may use your data, activity logs, and direct feedback to improve our Services.

2.4 Cookies and similar technologies

While we use similar technologies within our Services ecosystem, they are distinct from the cookies and other technologies used on our Site, which are all disclosed within our Cookie Policy. To provide specific functionality, we make limited use of tracking technologies, as also disclosed within our Cookie Policy. Users can manage their Cookie preferences within their User Profile.

2.5 Your device and location

We collect data from Users, including information about your device and location via IP address, the type of browser you use, time spent on the website, pages viewed, forms submitted, and the digital channel that led you to our website. Conferrr does not request precise geo-location data from Users. If you access our websites through a mobile device or our mobile application, we may collect additional data such as the type of device used.

2.6 Audio and video data

We may record advisory sessions with the express consent of both Advisor and User (each a “Recording”). If you have consented to a Recording, it will be used to assess the quality and effectiveness of your advisory session. The session recording may be used in the following ways:

• analysis of aggregate call statistics
• text analysis
• audio analysis
• video analysis

2.7 Health-related information

We do not collect or process “Protected Health Information” as defined under the Health Insurance Portability and Accountability Act (“HIPAA”), and our Services do not require HIPAA compliance. We are not a “Covered Entity” under HIPAA.

However, we recognize that health information is defined more broadly under other privacy regulations, including the Washington My Health My Data Act, which cover data related to general well-being, such as social, psychological, behavioral, and medical interventions.

We may collect limited health-related information that you voluntarily provide, such as insights shared during your engagement with our Services, including advisory sessions related to your personal development and well-being. This information is used solely to enhance and deliver

our Services. We do not sell or share your health-related data with third parties, except as necessary to provide our Services or comply with legal requirements. We treat all health-related data as sensitive and apply additional privacy and security safeguards to protect it. You have the right to access, delete, and withdraw your consent for the collection and use of your health-related information. To exercise these rights, please submit your request via email at letsconferrr@conferrr.com.

 

3. How We Use Your Data

3.1 Services

Conferrr will use your data to drive insights and analytics to serve you, our Users. The primary way we use data is to provide Services and help us improve the Site and the quality of our Services, and this extends to Personal Data. As described in Section 2, we request sensitive Personal  Data only under very limited circumstances, providing it is always voluntary, and you may revoke permission at any time.

3.2 Communication with Users and Advisors

We require certain Personal Data from both Users and Advisors for routine communication with each and to facilitate relationships between them.

 3.3 Market to You

As further described in the Cookie Policy and in Section 2.4 and 2.5, we collect certain data from Site Visitors for marketing and advertising purposes. Site Visitors may also need to provide data to interact with a bot on our Site to receive information from us. We may also use this information to communicate with you or potentially your User Organization about product, services, offers, promotions, rewards, and events offered by Conferrr; provide news and information we think will be of interest to you or your User Organization; and deliver and measure advertisements on other media and third-party websites. You have control over what information is collected and used, per our Cookie Policy.

3.4 Provide support

You may provide data via the Site that we use to provide a better customer support experience to you. For instance, if you were to email letsconferrr@conferrr.com, our team would request specific information for verification purposes, and as necessary, to address your concerns.

3.5 Generate insights that do not identify You

Most data that we use internally is de-identified and aggregated.

 

4. How We Share Data with Third Parties

 CONFERRR DOES NOT SELL YOUR PERSONAL DATA.

We share certain Personal Data about Users with Advisors, and vice versa, such as contact information and responses to surveys, to facilitate the ability for Advisors to provide Services to Users. If you are a User who is accessing the Site through a paid subscription through a User Organization, we share certain usage data with your sponsoring User Organization, such as data about your Site usage (e.g. the number of sessions you attended, when the session was attended, or date of completion of an assessment). We share this information with your sponsoring Organization to ensure a User Organization has the tools necessary to ensure the Services are being utilized and that they are effective. We do not share any assessment or survey responses or your individual advisory sessions with your User Organization. Your sponsoring Organization may see de-identified and aggregated analysis from all participating Users within your organization as aggregated from your interactions with resources within the Conferrr Site and general session topics as identified by your Advisor, post-session. As discussed in 2.1 above, we do share limited individual-level data with the sponsoring Organization. Section 2.2 also discusses how third parties may access your data.

We may share opinions, feedback, or reviews you voluntarily provide as a User with your User Organization and Advisor in a de-identified manner for quality or educational purposes. If you respond to an assessment of a fellow User, such as a 360 review, or request to share your data with your manager or supervisor through a Manager Feedback request, we may also share your feedback or reviews, but only at your explicit request. The Site will remind you of this additional sharing, and you will always have the option to decline.

If you are a Visitor to our public site or an individual User of ConferrrNow, we may share data about your interactions with the Site and the Services, such as whether you purchased a subscription, with our marketing and advertising service partners to help us create and administer campaigns, target and deliver relevant advertisements on third-party websites, and measure and optimize their effectiveness. To opt-out of sharing your data for these purposes, please opt out via the provided links or manage within your cookie preferences.

If you are a Visitor, Advisor, User or User Organization, we may also share data about you as follows:

• With vendors, consultants, and other service providers, including Advisors, who need access to such data to carry out work on our behalf, on a need-to-know basis
• In response to a request for data if we believe disclosure is in accordance with any legitimate law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, to protect the rights, property, and safety of others
• In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company, and
• With your consent or at your direction, including if we notify you through the Site or Services that certain data you provide will be shared in a particular manner and you choose to provide this data.

 

5. Your Choices, Rights, and Obligations

5.1 Your general data choices

You may update, correct, or delete Personal Data at any time by contacting us at letsconferrr@conferrr.com. Your User Profile within the Site also affords you the ability to update certain preferences and personal information. Please note that we may retain certain data as required by law or for legitimate business purposes. We may also retain cached or archived copies of data about you for a certain period.

5.2 Email subscriptions and promotional communications

You may opt out of receiving email communications from us by following the unsubscribe link within those communications or by emailing us at letsconferrr@conferrr.com.

If you are outside of the European Union, you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at letsconferrr@conferrr.com. If you opt-out, we may still send you non-promotional communications specifically related to your use of the Site.

5.3 Your Jurisdiction-specific Rights

Your rights under state-level privacy laws:

Several U.S. states are enacting comprehensive privacy legislation aimed at protecting residents’ privacy rights. At Conferrr, we go beyond these state-by-state requirements by providing all Users with access, deletion, and correction rights, regardless of their location.

Your Rights under the General Data Protection Regulation (“GDPR”)

If you are a resident of the European Union (“EU”) and European Economic Area, the GDPR grants you certain rights, including:

• accessing, deleting, or updating the Personal Data we hold about you
• correcting your Personal Data if it is incomplete or inaccurate
• objecting to our processing of your Personal Data
• requesting restrictions on the processing of your Personal Data
• requesting a copy of your Personal Data in a machine-readable, commonly used format
• withdrawing your consent at any time where we rely on your consent to process your Personal Data

To exercise any of the above rights, please send a request to letsconferrr@conferrr.com. Please note that we may ask you to verify your identity before responding to such requests.

Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide the same level of data protection as your jurisdiction, such as the European Economic Area. We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law. Conferrr may be obligated to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For contact details of your local Data Protection Authority, please see here.

 

Your Rights under the California Consumer Privacy Act (“CCPA”)

If you are a California resident, you are entitled to learn what data we collect about you, ask us to delete your data, and ask us to not sell or share it. You may request what personal information we have about you. If you make this request, we will return to you:

• categories of personal information we have collected about you
• categories of sources from which we collect your personal information
• the business or commercial purpose for collecting or selling your personal information
• categories of third parties with whom we share personal information
• specific pieces of personal information we have collected about you
• a list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact
• a list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with

If you ask us to delete your data, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through deidentification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

We will not discriminate against you under any circumstances for exercising your rights in connection with the CCPA. To exercise your California data protection rights described above, please send a request to letsconferrr@conferrr.com or by mail to Conferrr Privacy Office, 4480-H South Cobb Drive, Smyrna, GA 30080

6. Other Important Information

6.1 Machine learning and artificial intelligence

We prioritize your and your organization’s consent when it comes to generative artificial intelligence features. Some Conferrr Services may use generative AI, and we ask that you purchase these Services with that understanding. For other Services, which do not require generative AI, we will always seek your consent before enabling any optional AI-driven features.

 6.2 Security and retention

At Conferrr, safeguarding your personal information is a top priority. We employ robust technical and organizational measures to protect your data from unauthorized access, unlawful processing, and accidental loss, destruction, or damage. Our security controls are regularly updated to ensure the highest standards of protection.

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by law. Once your data is no longer needed, it will either be securely deleted or anonymized. In determining the appropriate retention period, we consider factors such as our agreements with you, legal obligations, and the nature of the data.

6.3 Conferrr’s commitment to children’s privacy

Conferrr Services are designed for businesses and individuals over the age of 16 and we do not intentionally collect any data from persons under the age of 16 (each a “Child”). If you believe we may have directly collected Personal Data about a Child and wish to have us remove that Personal Data, please contact us at letsconferrr@conferrr.com to let us know. We’ll work with you to make sure that data is removed from our Site and Services. In the event that Conferrr discovers we may have collected Personal Data about a Child, we will proactively remove that information.

6.4 Conferrr is a data controller and a data processor

Certain data protection laws distinguish between data processors and data controllers, depending on how the data is collected and shared. Conferrr is a Controller with respect to our direct relationship with Users within our Platform. Conferrr is a Processor with respect to data provided by a User Organization when registering on behalf of Users it is contracting for.

6.5 Conferrr adheres to the Data Privacy Framework

Conferrr complies with the EU-U.S. Data Privacy Framework, UK Extension to the EU-US Data Privacy Framework, and Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to the United States. Conferrr has certified to the U.S. Department of Commerce that it adheres to the Data Privacy Framework principles. If there is any conflict between the terms in this Privacy Policy and the Data Privacy Principles, the Data Privacy Principles shall govern. For more information about the Framework and its status visit the Department of Commerce Data Privacy Framework.  Website at https://www.dataprivacyframework.gov/s/.

As discussed within Section 5.5, your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area. We ensure that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into appropriate agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (as described in Article 46 of the General Data Protection Regulation).

In compliance with the DPF (EU-U.S., UK Extension, and Swiss U.S.), Conferrr commits to refer unresolved complaints concerning our handling of personal data to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment or satisfactory resolution of your DPF Principles-related complaint, you may contact TRUSTe for more information or to file a complaint.

6.6 How we communicate changes to this Privacy Policy

If we update this Privacy Policy, we will revise the date at the top. For significant changes, we may provide additional notice, such as a homepage statement or email. We encourage you to review the Policy regularly to stay informed about our data practices and how to protect your privacy.

6.7 How to reach Us about this Privacy Policy

Two ways:

• email: letsconferrr@conferrr.com
• mail: Conferrr Privacy Office, 4480-H South Cobb Drive, Smyrna, GA 30080, United States