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PRIVACY POLICY

Last updated December 2022

Kotter International, Inc., along with its subsidiaries and affiliates
(collectively, “Kotter”), helps organizations mobilize their people to achieve
unimaginable results at unprecedented speed. Kotter values your privacy and is
committed to protecting your personal data. This online Privacy Policy applies
to each of our websites that display or link to this Privacy Policy (including
kotterinc.com, community.kotterinc.com, and learn.kotterinc.com), and
html-formatted email messages we send to you that link to this Privacy Policy,
all of which are collectively referred to in this Privacy Policy as the
“Website”. This Privacy Policy applies to data collected by us through the
Website and describes the information we collect and how we use it. We ask all
users to review this Privacy Policy carefully. By visiting our Website, you are
accepting the practices described in this Privacy Policy. If you do not agree to
the terms of this Privacy Policy, please do not use the Website. We reserve the
right to modify or amend the terms of our Privacy Policy from time to time
without notice. We will post all changes to this Privacy Policy on this Website,
and they will become effective upon posting. Your continued use of this Website
will mean that you accept those changes.

Personal Information We collect

We collect and store personal information that you voluntarily provide to us or
our third-party vendors through the Website, such as your name, email address,
mailing address, phone number, voluntary posts, responses to survey and
assessment questions, and login user credentials like usernames, passwords, and
password hints. Registration may be required, and personal information collected
in certain areas of the Website in which you specifically and knowingly provide
such information, e.g., community postings, purchases, suggestions, or customer
service requests.

Through your use of our Website, we may also gather certain information about
such use (“Usage Information”). Generally, this information is collected through
“traffic data.” We collect and store certain other information automatically
whenever you interact with our Website. For example, we may collect your IP
address, browser information, and reference site domain name every time you
visit our Website. We also collect information regarding user traffic patterns
and site usage.

Additionally, we use forms on our Website, each of which states what you will
receive and can expect by providing your information. By submitting a form on
our Website, you are consenting to an internal score and grade being tabulated
and added to your Personal Information. This data will never be shared publicly
and is only used to help us better identify what content and information you
might find useful in the future.

Indirect Data Collection and Cookies/Pixel Tags

This Website automatically may collect certain device information such as your
IP address, unique device identifier, Cookies (as discussed below), geographic
data, country, browser, device operating system, application version, language
settings, and pages that have been shown to you. Note, however, we do not
consider this device information to be Personal Information except where we link
it to you as an individual or where applicable law requires.

Cookies are small bits of information that are stored by your computer’s web
browser.  Pixel tags are very small images or small pieces of data embedded in
images, also known as “web beacons” or “clear GIFs,” that can recognize cookies,
the time and date a page is viewed, a description of the page where the pixel
tag is placed, and similar information from your computer or device.

All browsers have a setting to opt you out of accepting cookies. Doing this will
remove some of the functionality of ours, and other, websites. You can find
steps to complete this using the links below:

 * Chrome
 * Firefox
 * Safari
 * Internet Explorer

The Cookies on our Website are generally divided into:

 * Strictly Necessary Cookies: Cookies that are necessary in order to operate
   our Website, such as to identify unique visitors and maintain the security of
   the Website.
 * Analytical Cookies: These cookies give us insights into how our Website is
   performing, how our Website is used, and how users interact with the Website.
   The information collected is anonymous and statistical.
 * Functional Cookies: Cookies that improve the functional performance of our
   Website and make it easier for you to use, including that you have previously
   visited our website in order to maintain your language preferences. These
   Cookies qualify as persistent Cookies, because they remain on your device so
   we can provide the same experience during your next visit to our website.
 * Targeting Cookies: Cookies placed by trusted partners which we use to
   understand how visitors interact with our Website and other third party
   websites you visit, including the pages you have visited and the links you
   have followed, in order to show you advertisements based on your interests
   (also known as interest based advertising). These Cookies qualify as
   persistent Cookies, because they remain on your device for us to use during a
   next visit to our Website.

Our Website employs cookies and/or pixel tags from the following third parties,
as follows:

 * Google Analytics: this allows us to gather insights into how visitors use and
   interact with our Website. To obtain these insights, Google Analytics uses a
   number of cookies. The information collected is anonymous and statistical. To
   give you additional control, Google Analytics gives users the ability to
   opt-out of these cookies, http://tools.google.com/dlpage/gaoptout.
 * Google Ads: Google Ads is an online advertising program of Google Ireland
   Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We display Google
   ads and use Google remarketing and conversion tracking. The ads are displayed
   on Google’s advertising network web pages in response to search queries. We
   also use Google ads remarketing lists for search ads. This allows us to
   customize search ad campaigns for users who have visited our website before.
   This service allows us to combine our ads with specific search terms or to
   display ads to previous visitors promoting our services. We may therefore
   display interest-based ads on other websites within the Google advertising
   network (as “Google ads” in Google search or on other sites) to users of our
   website. You can find more information on data protection in the context of
   Google Ads at: https://policies.google.com/technologies/ads?hl=de
 * YouTube: YouTube cookies are used to track viewing statistics and assign a
   unique identifier to the device on which the video is viewed, enabling
   YouTube to recognize the device. This data is sent to Google for use in its
   advertising platforms.
 * Salesforce Pardot: we use Pardot to help us in our marketing efforts. These
   cookies provide insights into how visitors interact with our marketing
   materials. You can find more information about Pardot’s privacy policies
   here: https://www.salesforce.com/company/privacy/
 * Meta: we use cookies and pixel tags from Meta (Facebook and Instagram) to
   support our marketing, retargeting, and advertising efforts. You can find
   more information about Facebook’s privacy policies here:
   https://www.facebook.com/privacy/explanation
 * Twitter: we use cookies and pixel tags from Twitter to support our marketing,
   retargeting, and advertising efforts. You can find more information about
   Twitter’s privacy policies here:
   https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
 * Zoominfo: we use this to collect statistics on users’ visits to our website,
   such as the number of visits, average time spent on the website and what
   pages have been read, preserve user states across page requests, and to
   distinguish between humans and bots.
 * LinkedIn: We also use conversion tracking on our Website with LinkedIn
   Insights Tag, a tool from LinkedIn Ireland, Wilton Plaza, Wilton Place,
   Dublin 2, Ireland. For more information on Conversion Tracking, see
   https://www.linkedin.com/help/linkedin/answer/67595/linkedin-conversion-trackingubersicht.
   Please be aware that LinkedIn’s data can be stored and processed so that a
   connection to the respective user profile is possible and LinkedIn can use
   the data for its own advertising purposes. For more information, please see
   LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy.
   You can prevent LinkedIn from analyzing your usage behavior and from
   displaying interest-based recommendations at
   https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

How We use the Personal Information We Collect

We will never sell, trade, or give away your personal information. In addition
to the uses stated elsewhere in this Privacy Policy, we use your personal
information for various other purposes, including:

 * To provide you services, both through the Website and directly, to improve or
   enhance the Website, and to develop new products and services
 * To respond to your inquiries, to verify your information, and to share
   information with you, including sending you marketing materials, newsletters,
   information about our services, opportunities, and provide customer support
 * For our internal business purposes, such as audits, internal communications
   regarding clients, and determining the effectiveness of our promotional and
   marketing activities
 * For research, publication, development, benchmarking and norms, validation,
   longitudinal studies, and trend analysis
 * To ensure that our services conform with legal requirements like equal
   opportunity laws
 * To charge you for the purchase of services through one or more payment
   processing partners, and handle tax matters related thereto

We also use your name and other personal identifiers to associate and combine
information about you that is collected from our Website with information about
you collected through other services.

We disclose personal information to third parties as part of their providing
services to us, including without limitation, website hosting and IT consulting
services, marketing services, legal services, accountancy, and other
administrative and back-up and security services.

We may also use your personal information to confer online course completion
badges via a third-party credentialing entity, such as Credly.

We may access or disclose personal information about you, including the content
of your communications, in order to: (a) comply with the law or respond to
lawful requests or legal process; (b) protect the rights or property of our
company or our customers, including the enforcement of our agreements or
policies governing your use of our Website and services; or (c) act on a good
faith belief that such access or disclosure is necessary to protect the personal
safety of our employees, customers, or the public.

We may disclose personal information as part of a corporate transaction such as
a merger or sale of assets. To that end, we may transfer your personal
information as part of a merger, acquisition, or sale of all or a portion of our
business.

Security of Personal Information

We maintain what we consider to be reasonable and appropriate technical and
organizational measures designed to protect Personal Information from accidental
loss, misuse and unauthorized or unlawful access or processing, disclosure,
alteration and destruction. To the extent that we disclose Personal Information
to third-party service providers, we require that such third parties also
maintain reasonable security and confidentiality measures and use the Personal
Information in accordance with our instructions and applicable law.

Cross-border Transfers

This Website may be operated, in whole or in part, from a country other than the
United States. By using our Website, you consent to having your personal
information transferred to and processed in a jurisdiction outside of the United
States. We take appropriate steps to safeguard your personal information that is
transferred. Where required by law, you can request a copy of such safeguards by
contacting us as detailed below.

Retention

We retain your Personal Information for as long as needed or permitted
considering the purpose(s) for which it was obtained.

Choices and Access

You have the right to request to see your personal data in our database and
request it be removed at any time. To make one of these requests, please send an
email to info@kotterinc.com.

Applicable Law and Jurisdiction

Massachusetts, USA state law governs the interpretation of this Privacy Policy
and applies to claims for breach regardless of conflict of laws principles. Both
parties consent to exclusive jurisdiction and venue in courts sitting in Boston,
MA, USA. Both parties waive all defenses of lack of personal jurisdiction and
forum non conveniens.

Additional Information for California Residents

California Civil Code Section 1798.83 grants users of the Website who are
California residents certain additional rights, as listed below. However, these
rights are not absolute, and in certain cases we may decline your request as
permitted by law.

 * Information. You can request the following information about how we have
   collected and used your personal information during the past 12 months:

o   The categories of personal information that we have collected.

o   The categories of sources from which we collected personal information.

o   The business or commercial purpose for collecting and/or selling personal
information.

o   The categories of third parties with whom we share personal information.

o   Whether we have disclosed Your personal information for a business purpose,
and if so, the categories of personal information received by each category of
third party recipient.

o   Whether we’ve sold your personal information, and if so, the categories of
personal information received by each category of third party recipient.

 * Access. You can request a copy of the personal information that we have
   collected about you during the past 12 months.
 * Deletion. You can ask us to delete the personal information that we have
   collected from you.
 * Opt-out of sales. If we sell your personal information, you can opt-out. In
   addition, if you direct us not to sell your personal information, we will
   consider it a request pursuant to California’s “Shine the Light” law to stop
   sharing your personal information covered by that law with third parties for
   their direct marketing purposes.
 * Opt-in. If we learn that you are younger than 16 years old, we will ask for
   your permission (or if you are younger than 13 years old, your parent or
   guardian’s permission) to sell your personal information before we do so.
 * Non-discrimination. You are entitled to exercise the rights described above
   free from discrimination. This means that we will not penalize you for
   exercising your rights by taking actions such as denying you services;
   increasing the price/rate of services; decreasing service quality; or
   suggesting that we may penalize you as described above for exercising Your
   rights.

To request to exercise your information, access and deletion rights, please send
an email to info@kotterinc.com. We will need to confirm your identity and
California residency to process your requests to exercise your information,
access or deletion rights. We cannot process your request if you do not provide
us with sufficient detail to allow Us to understand and respond to it.

Additional Information for European Territory Residents

In compliance with certain privacy laws, in particular the European General Data
Protection Regulation (“GDPR”), we provide specific additional rights for
individuals who interact with our Website such as the right to access,
rectification, right to object, to complaint, erasure and blockage. More
specifically and under certain circumstances:

 * the right to request information about whether and which personal information
   is processed by us, and the right to demand that personal information is
   rectified or amended.
 * the right to request that personal information should be deleted.
 * the right to demand that the processing of personal information should be
   restricted.
 * withdraw your consent to the processing and use of your personal information
   completely or partially at any time with future application.
 * have the right to obtain your personal information in a common, structured
   and mechanically readable format.
 * contact us if there are any questions, comments, complaints or requests in
   connection with our statement on data protection and the processing of your
   personal information.
 * the right to complain to the responsible supervisory authority if believed
   that the processing of Your personal information is in violation of the GDPR.

Pursuant to the GDPR, citizens from “European Territories” mean the European
Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland. For
the purpose of this Privacy Policy, the term “European Territories” shall
continue to include the United Kingdom.

Please email info@kotterinc.com with any questions about exercising any of the
above rights.



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     * Leadership Development
   * Learning + Development
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     * Custom Training Programs
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   * 8 Steps
   * 4 Principles
   * The Science of Change
 * Insights
 * Bookshelf
 * Contact Us



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