Privacy Policy

This Privacy Policy describes how Grace & Steel Associates LLC (“Grace & Steel”, “we”, “us”, or “our”) collect, use, transfer, and share information about its clients and website visitors (“you” or “your”) when you access or use our services (“Services”), including our website, platforms, and applications that help us provide leadership development, coaching, training, and executive services. 

By accessing or using our Services, you are agreeing to our collection, use, and disclosure practices as described in this Privacy Policy. This policy describes the choices you have regarding our use of your Personal Data, and how to contact us regarding our privacy practices.

Please note that this Privacy Policy does not apply to your use of third-party sites, services, or applications you may access through our Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.

Introduction

Grace & Steel provides executive development, leadership, coaching, assessment, and other talent-related services. 

Our work inherently requires Personal Data, 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.

We respect your concerns about privacy and value the relationship we have with you. We urge anyone who interacts with our firm to carefully read the following Privacy Policy and understand our approach to handling Personal Data. If at any time you have any questions regarding the Privacy Policy or our information practices, we encourage you to contact us.

Definitions

  1. “Personal Data” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, individual’s device, or household. Personal data includes but is not limited to name, alias, postal address, unique personal identifier, online identifier internet protocol address, email address, phone number, account name, social security number, driver’s license number, passport number, or other similar identifiers.

  2. “Data Subject” is the individual to whom Personal Data relates.

  3. “Standard Contractual Clauses”, in relation to the Processing of Personal Data pursuant to this Privacy Policy, means the latest standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council. The current approved version is available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010D0087-20161217 (amended 16 December 2016).

  4. “Data Protection Laws” relating to privacy, security, data protection, or confidentiality or the use, safeguarding, and Processing of Personal Data, specifically include: (a) the EU General Data Protection Regulation (Regulation 2016/679) (“GDPR”); (b) the Federal Data Protection Act of 19 June 1992 (Switzerland) (“Swiss DPA”); (c) the UK Data Protection Act 2018 (“UK DPA”); (d) Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003; (e) the California Consumer Protection Act (“CCPA”); or any laws or regulations that succeed, replace, or amend the foregoing.

  5. “Processing” is any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

  6. “Processor” is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

  7. “Recipient” is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with law and due process shall not be regarded as recipients; the processing of such data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

  8. “Third Party” is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

  9. “Consent” of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

  10. “Security Breach” is a breach of security involving Grace & Steel leading to the accidental or unlawful destruction, loss, misuse, alteration, disruption, acquisition, or unauthorized disclosure of, damage, or access to Personal Data transmitted, stored, or otherwise Processed that may adversely affect the privacy or security of Data Subjects, including any event deemed to be a security breach under the Data Protection Laws.

  11. The terms “controller”, “processor”, and “supervisory authority” as used in this Privacy Policy will have the meanings ascribed to them in the GDPR.

Collection of Information

Purpose of Collection

Grace & Steel collects Personal Data to provide Services to you and our clients and to operate our business. The type of Personal Data we collect about you depends on the situation.

  • We may collect your name, contact details, and your preferred means of communication. We may also collect your responses to survey and assessment questions.

  • In the course of providing or marketing our Services, we may collect the following types of information about you as a potential client: name, address, telephone number, e-mail address, resume information (employment history, education, professional credentials, skills, etc.)

  • We may collect information from in-person discussions, telephone conversations, video platforms, and through non-electronic communications.

  • When you utilize video conferencing Services, we may collect login user credentials like user names, passwords, and password hints.

  • In certain cases, we request sensitive Personal Data about you. We may use this information to ensure that our Services conform with legal requirements, including equal opportunity laws. Our assessments and surveys may include demographic survey questions like questions about gender, race, age, or country of origin. Except in these limited cases, we encourage you not to provide any other sensitive Personal Data to us, such as government identification numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership.

Please do not provide us with any Personal Data if you do not agree with this Policy.

How We Collect Personal Data

As you interact with Grace & Steel, you provide some Personal Data directly.

  • We may collect Personal Data when you register with us online, complete online assessments or surveys, participate in online courses, provide Personal Data about yourself to our coaches or contact us via e-mail, electronic forms, telephone or postal mail.

  • If you submit any Personal Data about other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.

  • Personal Data about you may also come from our clients to whom we provide Services.

  • We may also obtain Personal Data about you from third parties.

  • When someone participates in an assessment or coaching experience, they may share Personal Data about you.

Information You Provide Us

We collect Personal Data 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 Data you provide may include: (i) contact information, such as an email address you provide when contacting us, subscribing to receive information, newsletter, marketing materials, 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 Data 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 Data you may choose to provide us.

Prospective Grace & Steel Employees

We may collect information if you apply for a job with us. We collect certain Personal Data from you in order to process your application, such as your name, email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you.  

For product development, staffing specific programs for clients, or conducting research, we may ask for your consent to collect demographic information such as gender, race or ethnicity, or pronouns, or we may request your consent to record interviews. In all such instances, your involvement and providing such information is voluntary and will have no impact on your ability to obtain employment with Grace & Steel if you decline. If you provide consent, such consent may be withdrawn at any time. 

Personal Data 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 may 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.

  • Cookies: Our Website may use “cookies.” Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify site features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site.

For additional information regarding your choices relating to Tracking Technologies, see below under “Choices”.

Personal Data We Collect From Other Sources

We also may obtain information about you from other sources, including your employer or other organizations with which you are affiliated, our business partners, and our research of publicly available sources (including organizational or corporate websites, LinkedIn profiles and other social media, and conference brochures and similar materials). We will treat such data in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided by third parties or for third-party policies or practices.

Links to Third-Party Sites

This Website may contain links to other websites or services that are not controlled by Grace & Steel; 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 Data 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, the information you post or provide access to may be publicly displayed by the third-party service you use. Also, both Grace & Steel 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 use Google Analytics, Adobe Analytics, or other service providers to help us analyze Website users and how they use the Website. These analytics services may use cookies and other Tracking Technologies to help us analyze Website users and how they use the Website. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these service providers and these service providers may use this information for purposes such as evaluating your use of the Website, compiling statistic reports on the Website’s activity, and providing other services relating to Website activity and other internet usage.

Choices

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.

Some browsers have “Do Not Track” features that allow you to tell a website not to track you. These features are not all uniform. 

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 Data We Collect by Automated Means.”

Opt-Out of Analytics and Interest-Based Advertising

You may exercise choices regarding the use of cookies from Google Analytics by visiting this page or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by clicking here.

Use and Disclosure of Personal Data

In general, we use your Personal Data 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 Data 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 Data with our affiliates and business partners.

We may disclose your Personal Data if we believe that such disclosure is necessary to comply with relevant laws or to respond to subpoenas or court orders served on us; to respond to requests by government agencies, including law enforcement authorities; if we believe your actions are inconsistent with our terms of use, applicable terms or policies; or to protect the rights, property, life, health, security, or safety of Grace & Steel, our employees, you, the Website, our business partners, or any third party.

We may share or transfer your Personal Data in the event of a business transaction (e.g., further to a merger, acquisition, reorganization, liquidation, or any other business transaction, including negotiations of such transactions). You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.

Personal Data may be used to determine compensation, respond to questions or comments, send technical and administrative information, communicate, monitor, analyze, and conduct research and services.

How your Personal Data is disclosed will depend upon the situation. We use your Personal Data to provide our Services. 

While providing our Services, we may disclose your Personal Data to clients who have engaged our services. 

  • In the course of our Consulting Services and in providing our Services, we disclose Personal Data to our client. Our client can be your employer or an organization with whom you are seeking employment.

  • If you have completed an assessment or survey at our client’s request as part of our Consulting Services or related to a Service, we will not share your assessment results with other clients without obtaining the appropriate consent.

From time to time, we disclose Personal Data to our strategic alliance partners and to our network of independent consultants who provide services on Grace & Steel’s behalf for the purposes stated above. 

Grace & Steel discloses Personal Data to third parties who provide support for our Services or business operation.

  • Grace & Steel works with third parties who provide services that may include, but are not limited to, assessment services, including assessment validation services, website hosting and IT consulting services, data analysis, resume verification, background checking, payroll services, public relations services, marketing services, attorneys, accountants, and other administrative and back-up and security services.

  • As part of providing services, these third parties may be provided with access to Personal Data. In addition, our software development partners may use Personal Data to modify, improve, refine, and validate their technology, research, and development.

  • Grace & Steel may also use or disclose Personal Data (i) to comply with applicable laws, (ii) to respond to inquiries, requests, or orders from public or government authorities, including those outside of your country of residence, or (iii) to protect the rights, privacy, safety or property, of Grace & Steel and our affiliates, you or others.

  • We are not responsible for the actions or omissions of third parties, such as clients, including the way they use Personal Data received either from Grace & Steel or from other independent sources.

Use Limitation

Grace & Steel does not sell Personal Data, and uses Personal Data only as necessary to perform a business purpose pursuant to applicable privacy laws.

Data Security

To mitigate the risk to information processing resources, unauthorized disclosure or erasure of information and interruption of support for business processes which may result from unauthorized access, Grace & Steel maintains appropriate security measures designed to prevent unauthorized access to Personal Data.

Grace & Steel uses reasonable measures to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Unfortunately, however, no security system, or system of transmitting information over the Internet can be guaranteed to be 100% secure. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Grace & Steel Site. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices.

Transferring Personal Data to the United States

Grace & Steel is located in the United States. Please be aware that any Personal Data 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.

Children’s Privacy

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.

Data Retention

We will store your Personal Data 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.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you or our client (e.g., for as long as you have an account with us or keep using the Services),

  • A period beyond the time of the ongoing relationship if we have a legitimate internal operations need, such as a need to retain such information for analysis, record-keeping and compliance with data retention schedules,

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them), or

  • Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation, or regulatory investigations).

Revisions

This Privacy Policy is subject to change. We will indicate changes to this Privacy Policy by updating the “Last Updated” date at the top of the page. Your continued use of this Website after any update to this Privacy Policy will constitute your acceptance of the changes.

Contacting Us Regarding Your Personal Data

You can contact us at any time at info@graceandsteel.co with questions regarding this Privacy Policy or to ask that we do any of the following:

  • Erase or delete all or some of your Personal Data.

  • Change, update or correct your Personal Data.

  • Restrict how we use all or some of your Personal Data.

  • Provide you with information about our processing of your Personal Data and give you access to or a copy of your Personal Data.

  • Object to our processing of your Personal Data.

We will consider and respond to any such requests promptly and otherwise in accordance with applicable 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.

If you have any questions about this or any Policy of this Site, please contact: info@graceandsteel.co.

Terms and Conditions

This website, including but not limited to all materials, content, and functions made available herein (“the Site”), is published and maintained by Grace & Steel Associates, LLC, (“Grace & Steel Associates, LLC”). When you access, browse, or use this Site you accept, without limitation or qualification, the terms and conditions set forth below.

  1. This Site is for your personal use only. Unless if Grace & Steel Associates, LLC explicitly consents otherwise, you may not distribute, exchange, modify, sell, or transmit anything you copy from this Site for any business, commercial, or public purpose.

  2. You agree not to affect or interrupt the operation of this Site in any way.

  3. Unless otherwise explicitly noted, all materials contained on the Site are the copyrighted property of Grace & Steel Associates, LLC. You agree not to engage in any unauthorized use of such materials. Please be advised that such unauthorized use may violate copyright laws, trademark laws, the laws of privacy and publicity, and certain civil and criminal statutes.

  4. Unless otherwise explicitly noted, all logos, service marks, and trademarks contained on the Site are property of and proprietary to Grace & Steel Associates, LLC. You agree not to engage in any unauthorized use of such proprietary logos, service marks, and trademarks. Please be advised that such unauthorized use may violate copyright laws, trademark laws, the laws of privacy and publicity, and certain civil and criminal statutes.

  5. No materials from the Site may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that you may print (or download to a single computer) one copy of such materials for your personal, noncommercial use only, provided that (i) you keep intact all copyright and other proprietary notices, (ii) you make no modifications to the materials, and (iii) you do not use the materials in a manner that suggests an association with any Grace & Steel Associates, LLC products, services, or brands. If you are interested in reproducing, distributing, or using the materials on the Site for any commercial purpose, please contact Grace & Steel Associates, LLC at info@graceandsteel.co.

  6. Except as explicitly provided in paragraph 5 above, the use of any materials contained on this Site on any other website or computer environment is strictly prohibited.

  7. We explicitly disclaim any responsibility for the accuracy, content, or availability of information found on websites that link to or from this Site.

  8. YOUR USE OF THIS SITE IS AT YOUR OWN RISK. THIS SITE AND THE MATERIALS PROVIDED THEREON ARE PROVIDED “AS IS” AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. GRACE & STEEL ASSOCIATES, LLC MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING THE ACCURACY, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT OF ANY CONTENT PUBLISHED ON OR AVAILABLE THROUGH THE SITE. GRACE & STEEL ASSOCIATES, LLC MAKES NO REPRESENTATIONS OR WARRANTIES THAT THE SERVER THAT MAKES THIS SITE AVAILABLE IS FREE OF VIRUSES OR OTHER COMPONENTS THAT MAY INFECT OR HARM YOUR COMPUTER EQUIPMENT, SOFTWARE, OR ANY OTHER PROPERTY WHEN YOU ACCESS, BROWSE, DOWNLOAD FROM, OR OTHERWISE USE THE SITE.

  9. UNDER NO CIRCUMSTANCES SHALL GRACE & STEEL ASSOCIATES, LLC BE LIABLE FOR ANY CONSEQUENTIAL, DIRECT, INCIDENTAL, INDIRECT, PUNITIVE OR SPECIAL DAMAGES RELATED TO (A) THE USE OF, (B) THE INABILITY TO USE, OR (C) ERRORS OR OMISSIONS IN THE CONTENTS AND FUNCTIONS OF THIS SITE.

  10. Grace & Steel Associates, LLC reserves the right to modify these terms and conditions without prior notice. Accordingly, please refer to these terms and conditions on a regular basis.

Please contact us at: info@graceandsteel.co, if you have any questions about these terms and conditions or your use of this Site.