Last Updated: April 7, 2020
Mobius is an industry leader in providing executive development, skills training, transformational coaching and related programs and services.
Our work inherently requires personal information, not only for basic functions like contacting you and processing payments, but also to ensure that we have the background and context we need about you to appropriately tailor our services to your needs and goals.
Personal Information We Collect
Personal Information You Provide
We collect personal information that you provide to us through the Website or by otherwise interacting or corresponding with us, whether by telephone, email, in-person meetings or otherwise, including as part of your participation in and interaction with the Services.
Personal information you provide may include: (i) contact information, such as an email address you provide when subscribing to receive publications, alerts, announcements and other communications; (ii) registration information, such as organization and title information and payment information you provide when registering for our Services, including our programs and events; (iii) other personal information you provide when actively participating in and interacting with the Services, such as information you share with a leadership coach when participating in a training session; (iv) testimonials to be displayed, along with your name and photograph, on our Website and in other marketing materials, as discussed with you prior to such display (and subject to your subsequent instructions to update or delete your testimonial); and (v) any other personal information you may choose to provide us.
Personal Information We Collect by Automated Means
We may also automatically collect certain information about you when you access or use the Website or any Services offered online or via applications (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Website, and data regarding network-connected hardware (e.g., computer or mobile device). By collecting Usage Information, we learn how best to tailor our Website to our visitors.
As explained below, we collect Usage Information through various automated means (“Tracking Technologies”), such as server logs, cookies, and web beacons, both on our Website and in emails that we send to you:
- Log Information: When you interact with the Website, our servers automatically record Usage Information that your browser or device sends such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data. This information may be stored in log files.
- Web Beacons. Web beacons are small graphic images, also known as “Internet tags,” “pixel tags” or “clear gifs,” embedded in web pages. Web beacons may be used, for example, to count the number of visitors to the Website, to monitor how users navigate the Website, and to count content views.
- In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs,” to associate app user activity to a particular app and to track user activity across apps and/or devices.
Some information about your use of the Website and certain third-party services may be collected using Tracking Technologies across time and services, and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Website and certain other sites or online services.
For additional information regarding your choices relating to Tracking Technologies, see below under “Your Choices.”
Personal Information We Collect From Other Sources
Use and Disclosure of Personal Information
In general, we use your personal information to provide you access to the Website, provide our Services, send you communications, improve the Website, tailor Website features to you, and offer you additional information and functionality.
Your personal information may be disclosed to third-party service providers (including members of our coaching and instructional network) who work with us in order to provide or support our Website and Services. We may also share your personal information with our affiliates and business partners including, but not limited to Egon Zehnder International AG.
Links to Third-Party Sites
This Website may contain links to other websites or services that are not controlled by Mobius; these links are provided for your convenience and information. Third-party sites may use their own Tracking Technologies to independently collect information about you or solicit personal information from you. We are not responsible for any third party’s data collection or privacy practices, and we encourage you to review the privacy policies or notices posted on those third-party websites for further information.
Social Features, Advertising, and Analytics
Certain functionalities on the Website permit interactions that you initiate between the Website and third-party services, such as social networks (“Social Features”) including Facebook, LinkedIn, and Twitter. Social Features may enable you to send content between the Website and a third-party service. If you use Social Features, and potentially other third-party services, information you post or provide access to may be publicly displayed by the third-party service you use. Also, both Mobius and the third party may have access to certain information about you and your use of the Website and the third-party service.
We may engage and work with service providers and other third parties to serve advertisements on third-party services. These ads may be tailored to your interest based on your use of the Website and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising,” which may include sending you an ad on a third-party service after you have left the Website (i.e., “retargeting”).
Unsubscribe from Emails
Should you receive promotional emails from us, you may opt out of receiving additional email communications from us by following the unsubscribe instructions in the emails. Please note that even if you opt out of receiving promotional emails from us, we may continue to send you other email communications.
Opt Out of Tracking Technologies
Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. To learn more about how to configure your browser’s cookie setting, click “help” on your browser’s menu. In addition to browser-based controls, you can manage third-party cookies by visiting www.aboutads.info/choices and www.youronlinechoices.eu.
Some browsers have “Do Not Track” features that allow you to tell a website not to track you. These features are not all uniform. Like many websites, our Website is not currently designed to respond to those signals.
Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies or other Tracking Technologies. Please be aware that if you disable or remove these technologies, some parts of the Website may not work and that when you revisit the Website your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
For additional information regarding Tracking Technologies, see above under “Personal Information We Collect by Automated Means.”
Opt Out of Analytics and Interest-Based Advertising
You may choose whether to receive some Interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit here. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, visit here. see here. http://www.networkadvertising. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out program.
Contacting Us Regarding Your Personal Information
- Erase or delete all or some of your personal information.
- Change, update or correct your personal information.
- Restrict how we use all or some of your personal information.
- Provide you with information about our processing of your personal information and give you access to or a copy of your personal information.
- Object to our processing of your personal information.
We will consider and respond to any such requests promptly and otherwise in accordance with applicable laws (European residents should review the “Note for European Residents” below for special considerations under European privacy laws). We may request specific information from you to help us confirm your identity prior to processing your request. If we decline your request, we will tell you why, subject to legal restrictions.
Transferring Personal Information to the United States
Mobius Executive Leadership LLC is located in the United States. Please be aware that any personal information we collect may be transferred to and processed in the United States and be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to the laws in your country of residence.
Note for European Residents
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will typically collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the U.S. personal information only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Mobius in a manner that does not outweigh your rights and freedoms.
You also have the right to lodge a complaint with a supervisory authority. You can find information about your data protection regulator here. For complaints from EU data subjects that cannot be resolved with Mobius directly, Mobius will cooperate with such EU authorities and will implement advice they provide with respect to such unresolved complaints.
We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements.
We take reasonable measures to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, we cannot guarantee the security of your personal information.
This Website is not intended for, nor targeted to, children under 18, and we do not knowingly or intentionally collect information from children under 18. If we learn that we have received information directly from a child who is under the age of 18, we will delete the information in accordance with applicable law.
Your California Privacy Rights
California law permits customers in California to request certain details about how their “personal information” (as defined by California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. Californians may request information about our compliance with this law by contacting us at firstname.lastname@example.org or by postal mail sent to:
Mobius Executive Leadership LLC
Attention: California Privacy Rights Inquiry
35 Highland Circle, 2nd Floor
Needham, Massachusetts 02494
Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per California resident each year.