PRIVACY POLICY

VitalSmarts, LC, dba Crucial Learning is committed to protecting the privacy of those who visit our websites and with whom we do business. As part of our normal operations, we collect different kinds of information about our website visitors. We have, however, structured our websites so that people have the option to visit without identifying themselves or revealing any personal information. The following are things you can do while visiting our website if you prefer NOT to have information about your visit collected:

Disable cookies within your browser before visiting our website
Choose not to submit information via web forms located within our website
Choose not to purchase from our online store (if applicable)
Choose not to “opt-in” to certain programs that are available on our websites
Choose not to complete any surveys available on our website

The following describes the information we collect and how that information is used to provide our
visitors with the optimal online experience.

COOKIES AND SPOTLIGHT IMAGES OR WEB BEACONS

We sometimes use session cookies to limit popup windows to a single browser instance. We also use
Java scripting in cooperation with cookies and “spotlight images” or “web beacons” to track website
traffic and email response. A “spotlight image” or “web beacon” is an electronic image, called a
1-by-1 pixel or clear GIF, that can recognize certain types of information on your computer, such as
a cookie number, time and date of a page view and so on. These methods do not collect any personal
information, but simply aggregate information that allows us to research patterns of behavior on
our site to learn how to better meet our visitors’ needs. Our online store uses cookies to store order
information. You may refuse cookies by turning off that feature on your web browser.

This website uses Marketo Munchkin cookies (“Marketo”). Marketo’s cookie allows us to track
repeated visits to the website and link each visit to the information voluntarily provided by the visitor.
For example, if the visitor is asked to provide us with name, company name and email address, we will
know the identity of the visitor when they visit the site at a later date. We also use Munchkin code to
track email open rates and click-through rates, allowing us to manage the email marketing experience.
By using this website, you are consenting to the above use of your data.

For more information on Adobe Marketo’s privacy and cookie policy, please visit Adobe Marketo’s privacy policy: http://www.marketo.com/trust/legal/privacy.

In addition, we may use or allow third parties to serve cookies on our site — specifically we use Google
Analytics and Marketo to help us monitor our website traffic and understand visitor behavior.

INFORMATION WE COLLECT

You may be visiting our website for a variety of reasons. For the purpose of this privacy policy, we will
classify these reasons as (i) browsing, (ii) submitting forms, (iii) purchasing products and services
and (iv) completing surveys. Please note that not all activities may be available on our website at a given time. For each different type of activity, we collect and store different types of data for different
reasons.

Browsing—If you are simply browsing or navigating through our website, we collect information about your computer and the pages you visit on our website in the aggregate (not individual or personal information). This data is often referred to as clickstream or navigation data. We use this information for research, analysis and reporting so that we can improve our navigation, page structure and page content to help visitors find information more quickly and provide more value when they find what they are looking for on our website.
Submitting Forms—Certain pages of our website contain forms that allow you to request information about our services and solutions or to gain access to valuable resources (like white papers and research documents) in exchange for contact information. In completing one of these forms, you may be required to provide contact information, such as your name, phone number and/or email address. By filling out a form on this website, you are agreeing to our privacy policy. You are also acknowledging that your data may not be subject to EU regulations, like the GDPR, as this is a U.S. based company and website.
Purchasing—For purchasing in our online store or registering for events or courses, we will require you to create an account with us. We collect information in this account that enables us to complete your order and/or registration and streamline your purchasing process the next time you order from us. Furthermore, we will give you the ability to view and update this information if you so choose.
Completing Surveys—For surveys, we collect responses to help us improve various aspects of our business based on aggregate and individual feedback provided. These surveys are sent via opt-in marketing programs or are made available on our website for you to participate if you so choose.

HOW WE USE AND SHARE YOUR INFORMATION

If you choose to provide us with your personal data, as contemplated above, in addition to using the
data for the express purpose for which it was provided, we may, if permitted by applicable law, use
your information to:

Process a payment that you have made
Process orders that you have submitted
Carry out our obligations arising from any contracts entered into by you and us (or by your employer and us)
Seek your views or comments on the services we provide through surveys or otherwise
Notify you of changes to our services
Send you communications that you have requested or that may be of interest to you, including activities or promotions of our products or services, or those of our affiliates
Send you newsletters, event notices and announcements
Process a job application

As a global organization offering a wide range of products and services, with business processes,
management structures and technical systems that cross borders, we have implemented global
policies, along with standards and procedures, for consistent protection of personal information. As a
global company, we may share information about you with our subsidiaries worldwide and transfer it
to countries in the world where we do business in accordance with this Privacy Notice.

Between our controlled subsidiaries, we only grant access to personal information on a need-to-know
basis, necessary for the purposes for which such access is granted. In some cases, we use suppliers
located in various countries to collect, use, analyze, and otherwise process personal information on
our behalf.

Where appropriate, we may also share your personal information with selected partners to help us
provide you, or the company you work for, products or services, or to fulfill your requests, or with
your consent. When selecting our suppliers and partners, we take into account their data handling
processes.

If we decide to sell, buy, merge or otherwise reorganize businesses in some countries, such a
transaction may involve the disclosure of personal information to prospective or actual purchasers,
or the receipt of such information from sellers. It is our practice to require appropriate protection for
personal information in these types of transactions.

If you do not wish for us to use your data in the ways described above, you may follow the instructions
contained in the relevant communication, update your communication preferences in your online
account (if applicable), or follow the instructions below, under the heading “YOUR RIGHTS.”

Please be aware that, in certain circumstances, personal information may be subject to disclosure to
government agencies pursuant to judicial proceedings, court order, or legal process. We may also share
your personal information to protect our rights or property, or that of our business partners, suppliers
or clients, and others when we have reasonable grounds to believe that such rights or property have
been, or could be, affected.

We may place email links on this site to allow you to contact us directly via email. The information you
provide is used to respond directly to your questions or comments. Those comments may be stored to
improve the quality of our site and our services.

In addition, from time to time, we will purchase or rent relevant public mailing lists from reputable
agencies that have obtained your prior approval to receive relevant information based on your
personal preferences. Any promotional information sent to you by us will contain instructions on how
to be removed from a mailing list source. We will also freely provide information about how and from
whom your personal details were given to us when requested.

INTERNATIONAL TRANSFERS

Our international footprint may involve the transfer of personal information between different
subsidiaries, as well as to third parties located in the countries where we do business. Some countries
have implemented transfer restrictions for personal information. Where required, we implement
Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in
other jurisdictions. This includes transfers to suppliers or other third parties.

INFORMATION SECURITY AND ACCURACY

We intend to protect your personal information and to maintain its accuracy. We implement
reasonable physical, administrative and technical safeguards to help us protect your personal
information from unauthorized access, use and disclosure. We also require that our suppliers protect
such information from unauthorized access, use and disclosure.

RETENTION PERIOD

We will not retain personal information longer than necessary to fulfill the purposes for which it is
processed, including the security of our processing complying with legal and regulatory obligations
(e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment,
exercise or defense of legal claims in the countries where we do business.

Because the circumstances may vary depending on the context and the services, the information
provided in Online Privacy Statement or provided in a specific notice may provide more detailed
information on applicable retention terms. In the event that we process your data for marketing
purposes, we will delete your data if we have not received any responses to our marketing activities for
a period of three years.

The deletion will occur within six months of such three-year period elapsing.

HOW TO CONTACT US

If you have a question related to this Privacy Notice, please contact us by sending an email to privacy@
cruciallearning.com.

For the purposes of the EU General Data Protection Regulation (“GDPR”), the controller of your
personal information is Crucial Learning, Attn: Crucial Learning Data Privacy Officer, 320 River Park Dr., suite SWB, Provo, Utah 84604, United States of America.

Crucial Learning is not the controller in situations such as personal information processed in
connection with a contractual relationship. In this case, the controller of personal information is the
company with which we have contracted (such as your employer) unless otherwise agreed in that
contract.

YOUR RIGHTS

You can request to access, update or correct your personal information. You also have the right to
object to direct marketing. To make such a request or lodge such an objection, please send an email
to privacy@cruciallearning.com. Please specify our company name (so that we know which company
you are contacting us about) and provide details of your request. We will contact you if we need more
information to process your request.

You may have additional rights pursuant to your local law applicable to the processing. For example, if
the processing of your personal information is subject to the EU General Data Protection Regulation
(“GDPR”), and your personal information is processed based on legitimate interests, you have the
right to object to the processing on grounds relating to your specific situation. Under GDPR you
may also have the right to request to have your personal information deleted or restricted and ask
for portability of your personal information. You can make these requests by sending an email to
cruciallearning.com, providing the details of your request.

RIGHT TO LODGE A COMPLAINT

In the event you consider our processing of your personal information not to be compliant with
the applicable data protection laws, you can lodge a complaint directly with us by sending an email
to cruciallearning.com and providing specific details of the complaint, including the name of the
company to which it pertains. You may also be eligible to lodge a complaint with the competent
data protection authority. The names and contact details of the Data Protection Authorities in the

European Union can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-
authorities/index_en.htm.

CHILDREN

We are concerned about the privacy of young children and do not knowingly collect any personal
information from a child under the age of 13. If we learn that we have personal information on a child
under the age of 13, we will delete that information from our records and systems.

SECURITY

We employ procedural and technical measures that are designed to help protect your personal
information from loss, unauthorized access, disclosure, alteration or destruction. However, we
cannot guarantee that third parties will not overcome any such measures and gain access to your
information for unauthorized purposes. By using the website, you accept the risk that compromise
of and unauthorized access to your information is possible. To the fullest extent permitted by
law, we disclaim any warranty or guarantee that your information will be protected from misuse,
appropriation, alteration, or loss.

All data submitted in our online store (if any) is submitted using secure transport technologies to
provide you with the utmost in protection for your private information.

DISCLOSURE OF INFORMATION

We may disclose or access customer information when we believe in good faith that the law requires
it, or in response to any demand by law enforcement authorities in connection with a criminal
investigation or civil or administrative authorities in connection with a pending civil case or
administrative investigation.

TERMS OF SERVICE

The content on this website is copyrighted material owned by us. It is provided for your general information only, and is subject to change without notice. We reserve all rights with respect to the website, including without limitation, copyright and intellectual property rights.
The website is provided on an “as is” basis. We make no representations or warranties of any kind, express or implied, with respect to the accuracy, completeness, suitability, timeliness, availability or reliability of the website or the information or materials found or offered on the site. We disclaim all implied warranties, including without limitation, warranties of merchantability, fitness for a particular purpose, accuracy of data and non-infringement.
Neither we, nor any of our affiliated companies, directors, officers, employees, partners or owners shall be liable for any loss or damage whatsoever related to the use of this website.
VitalSmarts, Crucial Learning, Crucial Conversations, Crucial Accountability, Influencer Training, Crucial Skills, and the Vital Head are registered trademarks and CCORE, Style Under Stress, and Six Sources of Influence are trademarks of Crucial Learning.
GTD, Getting Things Done, Mind Like Water, Horizons of Focus, and “Your mind is for having ideas, not holding them” are registered trademarks owned by David Allen Company and used with permission by Crucial Learning. Crucial Learning distributes Getting Things Done® Training within the United States and Canada only.
Any claim or cause of action arising out of, or related to, the use of the website shall be governed by the laws of the State of Utah regardless of where the website was accessed or the country of origin of the claimant.

CALIFORNIA PRIVACY RIGHTS

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Crucial Learning is providing
California residents with the following details regarding how we collect, use and share your Personal
Information.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect and have collected within the past 12 months the following categories of Personal
Information:

Identifiers (such as name and title, contact details, IP address);
Commercial information (such as transaction information and purchase history);
Internet or other network or device activity (such as browsing history or app usage);
Professional or employment-related information (such as a job application);
Inference data drawn from the information above to create a profile about, for example, an individual’s preferences and abilities; and
Other information that identifies or can be reasonably associated with you.

SOURCES OF PERSONAL INFORMATION WE COLLECT

For information on the sources of these categories of Personal Information, please refer to the
“Information We Collect” section of this Policy.

PURPOSE OF PERSONAL INFORMATION WE COLLECT

For information on the purpose for collecting the above categories of Personal Information please
refer to the “How We Use and Share Your Information” section of this Policy.

DISCLOSURE OF PERSONAL INFORMATION WE COLLECT

We have disclosed the following categories of Personal Information to third parties for our operational
business purposes within the past 12 months: Identifiers, Commercial information, Internet or other
activity, professional or employment-related information, Inference data, and Other information.
In addition, we do allow third parties to collect certain information as explained in the “Cookies and
Spotlight Images or Web Beacons” section of this Policy.

SALE OF PERSONAL INFORMATION

We have not sold Personal Information, as “sale” is defined in the CCPA, in the past 12 months
(including that we do not “sell” the personal information of minors under the age of 16). Individual
Rights. If you are a California resident, you may request that we:

Provide you with the categories of Personal Information we have collected about you and the
categories of sources of that information.

Provide you with the business or commercial purpose of collecting your Personal Information.
Provide you with the categories of third parties with whom we shared Personal Information.
Provide access to or a copy of certain information we hold about you.
Delete Personal Information we collected from you.

To make a request for disclosure or deletion as described above, please contact privacy@
cruciallearning.com, call our toll free number at 1-800-449-5989, or you may send notice to Crucial
Learning, Attn: Data Privacy, 320 River Park Dr., suite SWB, Provo, Utah 84604. You will be required
to verify your identity before we can fulfill your request. You can also designate an authorized agent to
make a request on your behalf.

You have the right to not be discriminated against for exercising your rights under CCPA.

QUESTIONS ABOUT THE PRIVACY POLICY

If you have any questions or complaints about this privacy policy, the practices of this site or your
interactions with this site, please contact:

VitalSmarts, LC dba Crucial Learning
320 River Park Dr., suite SWB
Provo, UT 84606
privacy@cruciallearning.com

Please note that any requests described above to be made to privacy@cruciallearning.com may
also be made by sending a letter to the above postal address. Any such letter should include contact
information—preferably an e-mail address—so that we can contact you. Requests made by standard
mail will take longer to process due to the time it takes for correspondence to be exchanged.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this policy at any time.

A PDF version of this is available.