Privacy Policy

CIALDINI INSTITUTE LLC

Updated: 06/12/2023

1.  INTRODUCTION 
1.1   This Privacy Policy (this “Privacy Policy”) governs the processing by Cialdini Institute LLC, a Delaware limited liability company (“Cialdini”, “we”, “our”), of information from customers, representatives of business partners, suppliers, other users of our website https://cialdini.com (“Website”) and those we interact with offline. Hereinafter we refer to such individuals as “you”. This Privacy Policy applies to U.S. residents only.  If you are not a U.S. resident, please see our Privacy Policy for non-U.S. residents. Depending on your place of residence in the U.S., certain state data protection laws and regulations grant you certain rights regarding your Personal Data. For more information on such rights, please see our State-Specific Notice. When we use the term “Personal Data” or “Personal Information”, we refer to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, or as otherwise defined in the state privacy laws applicable to you (“Personal Data” or “Personal Information”).
1.2   Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. If you do not agree with our practices, your choice is not to use our Website. By accessing or using our Website, you agree to this Privacy Policy.
1.3   Cialdini may amend this Privacy Policy at any time. In case the Privacy Policy is amended, the amended Privacy Policy will be made available to you through publication of the amended Privacy Policy on our Website. Please review this Privacy Policy whenever you visit the Website or when prompted when we collect Personal Information from you offline to check if there have been any changes, so that you know the terms that apply to you at that time. At the top of this Privacy Policy, you can see when this Privacy Policy has been last updated. Continued use of the Website following such changes constitutes the acceptance of those changes.

2.   PROCESSING OF PERSONAL DATA
2.1.  We collect and process several types of Personal Data from and about you, including information:
By which you may be personally identified, such as name, mailing address, e-mail address, telephone number and your purchase history;
Your IP address; and
Your Website usage and browser setting.
2.2.  We collect your Personal Data in different ways:
Directly from you: For example, by asking you to provide it to us (for example by filling out forms on our Website (e.g., registration, subscription, “contact us” forms etc.) or if you post contributions through interactive features on our Website (e.g., reviews, testimonials, social media feed etc.);
Indirectly from you: For example, through automatic data technologies or tools (e.g., cookies and other tracking technologies, including but not limited to Google Analytics and HubSpot) which collect certain information about your IP address, Website usage and browser setting. For more information on the automatic tools (cookies and scripts) we use, please see our Cookie Policy.
From third parties: For example, through advertising networks, from service providers, data analytics providers, social media, etc.
2.3.  We store your Personal Data as long as necessary to perform the purposes of processing as set forth in Section 3 of this Privacy Policy. This includes but not limited to storing your Personal Data at least for the period as is necessary to enable your use of our services or our Website.

3.   PURPOSES OF PERSONAL DATA COLLECTION
3.1.  Personal Data is collected and processed by Cialdini for the following purposes:
Fulfilling or meeting the reason you provided the Personal Data. For example, if you disclose Personal Data to request a price quote or ask a question about our products, we will use such Personal Data to respond to your request/inquiry. If you provide your Personal Data to purchase a product or service, we will use such Personal Data to process and fulfill your orders and transactions, verify your information, process payment, provide storage or similar services and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
Presenting our Website and its contents and interactive features to you, maintaining or servicing your accounts (e.g., we will contact you via the email address you provided to us if your password or your email address in our records has been changed), and providing customer service (including providing you with support, investigating and addressing your concerns and monitoring and improving our responses);
Providing, supporting, personalizing, and developing our Website, products, and services;
Personalizing your Website experience and delivering to you content and product and service offerings relevant to your interests, including offers and ads through our Website, third-party sites (e.g., social media platforms), and via email or text message (with your consent, where required by applicable law);
Notifying you about changes to our Website or any products we offer or provide though it;
Auditing related to counting ad impressions to you, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
Helping to ensure the safety, security and integrity of our Website, products, databases, other technology assets, and business;
Debugging to identify and repair errors that impair existing intended functionality of our Website;
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us;
Providing and obtaining services for advertising and marketing, and conducting related activities such as remarketing, targeted advertising, and profiling (see also Section 4.2 below for the description of these activities);
Undertaking internal research for technological development and demonstration, including testing, researching, and analyzing to develop and improve our Website and products;
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;
Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Website users is among the assets transferred;
Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your Personal Data;
For purposes you consented to.
3.2   We may also contact you to further promote Cialdini, our Website or any of our future services. If you do not wish to receive any such materials or information from us, please do not click the box on the Webpage when prompted. Should you wish to opt-out, please do so by selecting the desired options in your Cialdini Account or making use of the opt-out option provided to you in every email we send you.

4.   DISCLOSURE/SALE/SHARING OF YOUR PERSONAL DATA
4.1.  Cialdini discloses your Personal Data with the following third parties:
Service providers: We may disclose your Personal Data with service providers that provide services to enable your use of the Website and the fulfillment of the obligations of our contract (e.g., payment processors), including but not limited to the company that hosts our Website;
Marketing partners: We coordinate and disclose your Personal Data with our marketing partners, including advertising networks, internet service providers, data analytics providers, social networks, and marketing communication providers, in order to communicate with you about our products and services and market our products and services to you. They include Google LLC and Meta Platforms, Inc. for their remarketing and re-engagement of audiences. In addition to opt-out mechanisms that we offer pursuant to our State Specific Notice, you can also visit the privacy policies of Google LLC and Meta Platforms, Inc. to find out more about how to opt out of the mentioned uses. Such privacy policies are accessible here.
Business partners and affiliates: We may disclose your Personal Data with our local certified coaches to be able to offer courses locally. Our local certified coaches may then contact you to organize such local courses. We may also disclose your Personal Data with affiliates (i.e., those that promote our products and services) in order for us to assess inter alia whether such affiliates referred you to us as a client.
Other companies in the Cialdini group: We may disclose your Personal Data with companies within the Cialdini group to the extent necessary for us to fulfill the purposes mentioned under Section 3;
Business transactions or reorganizations: We may disclose your Personal Data with a third-party during negotiation of, in connection with, or as an asset in a corporate business transaction (such as a merger, acquisition, joint venture, or financing or sale of company assets). Your Personal Data may also be disclosed in the event of insolvency, bankruptcy, or receivership;
Legal representatives, government authorities, law enforcement representatives: We may disclose your Personal Data with third parties, such as legal advisors and law enforcement to comply with court orders, enforcement actions, and applicable laws, rules and regulations;
4.2.  We do not sell Personal Data for monetary consideration. However, the below activities may constitute as “sale” or “sharing” of Personal Data under certain state laws (e.g., California) regardless of whether an exchange of monetary consideration takes place or not:
Cross-context Behavior Advertising; Targeted Advertising; Profiling. We allow certain third-party companies to place tracking technologies like cookies and pixels on our sites, which enable those companies to receive information about your activity on the Website that is associated with your browser or device. Additionally, we might actively provide third-party companies (as e.g., Meta Platforms, Inc. and LinkedIn Corporation) information about you so that such third-party companies may create lookalike audiences based on the information provided about you. These third parties may use that data to serve you more relevant ads on our Website or the websites of others, or they may create lookalike audiences with other members who share your characteristics and provide us with the opportunity to expand and target our advertising efforts to the members of the lookalike audience. Such advertising is also known as interest-based advertising (also known as online behavioral advertising), cross-context behavior advertising, profiling or targeted advertising. We may receive from such companies discounts or certain free services (e.g., free analytical services from Google LLC, or free creation of a lookalike audience by Meta Platforms, Inc. or LinkedIn Corporation). Cross-context behavior advertising means targeted advertising sent to you based on your Personal Data obtained from your activity across businesses, websites, applications or services with which you intentionally interact. Profiling means any form of automated processing of Personal Data to evaluate and predict certain aspects about you.
The information being collected by these third-party companies may include anonymized information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, and session ID) and personally identifiable information (e.g., static IP address).
Please refer to our State Specific Privacy Notice for more information on the rights that you may be entitled to with respect to such activities, and how to exercise them.

5.   SECURITY
5.1   Cialdini is committed to secure the processing of your Personal Information, by maintaining administrative, technical and physical controls which are designed to protect your Personal Information against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification. Therefore, we implement security measures where appropriate and applicable, such as, but not limited to:
 - Pseudonymization and encryption of Personal Information;
- The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- The ability to restore the availability of and access to Personal Information in a timely manner in the event of a physical or technical incident; and
- A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures to ensure security of processing.
The safety and security of your Personal Data also depend on you. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for any circumvention of any privacy settings or security measures contained on our Website.

6.   RETENTION POLICY(our “Retention Policy”)
Personal Data are retained for the duration as shown in the below overview, unless we are required by applicable laws, rules or regulations to retain your Personal Data for a longer period of time. Please refer to our State-Specific Notice for situations where we are entitled to retain your Personal Information despite your request to delete. Any Personal Data which is not included in the overview below, will not be retained longer than reasonably necessary to fulfill the purpose for which it was collected.
How long we keep Personal Data can vary widely depending on the context of the services we offer. The following criteria are often used to determine the retention period: nature of the Personal Data, the context in which the Personal Data have been collected, the consequences for you and the existence of appropriate safeguards, such as pseudonymization.

7.   YOUR RIGHTS
7.1.  Please refer to our State Specific Notice for disclosures and rights that apply to residents of the States of California, Nevada and the Commonwealth of Nevada.
7.2.  Notwithstanding your state specific rights, every user of our Website may request from Cialdini (i) information on the Personal Data we collect from them, (ii) access to an overview of such Personal Data, (iii) to correct or delete their Personal Data by contacting us at the contact information mentioned in Section 8, and (iv) to receive the requested information on your Personal Data in a portable manner. You can make such request by contacting Cialdini using the contact information under Section 8 below.
7.3.  In order to fulfil your requests pursuant to the rights as stated above in Sections 7.1 and 7.2, we may request specific additional information from you to verify your identity. We collect and process such information for the sole purpose of enabling us to respond to your request.
7.4.   Please be informed that when you exercise certain rights mentioned in Section 7.1 and 7.2 (e.g., the right to deletion), we may no longer be able to offer you the use of the Website or portions thereof (e.g., access to your Cialdini account may be limited).
7.5.  We will remove your Personal Data pursuant to our Retention Policy. Should you decide to delete your account with Cialdini, please note that you will lose access to the Personal Data, courses, documents and other information in your Cialdini Account. Cialdini is not under any obligation to maintain a back-up of such information and data. 

8.   CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on our Website. We do not knowingly collect personal information from children under the age of 16. If you are under 16, do not use or provide any information on our Website or through any of its features, register on our Website, use any of the interactive features of our Website, or provide any information about yourself to us. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at info@cialdini.com. 

9.  LINKS TO OTHER SITES
The Website may, from time to time, contain links to and from the websites, plug-ins and applications of our partner networks, advertisers, affiliates or social media sites. You may also share your Personal Information on the Website (e.g., profile) or the Cialdini app with third party platforms or sites (including but not limited to social media sites). This Privacy Policy does not apply to your access to any Personal Information practices of such third-party websites and online services, which may (or may not) have privacy policies. Please understand that Cialdini does not control such “linked” websites (or the content contained on such websites) and takes no responsibility for their content. It should not be implied that Cialdini endorses or otherwise recommends such websites, or the products or services they offer. To learn about the Personal Data practices of these third parties, please visit their respective privacy notices or policies.

10.   CONTACT INFORMATION
To ask questions about or comment on this Privacy Policy, contact us at:
Phone:+1 (602) 834-9429‬ 
Email: info@cialdini.com
Postal Address: 2248 S. Forest Avenue, Tempe, Arizona 8528   Attention: Privacy officer of Cialdini
Website: cialdini.com
If you need to access this Privacy Policy in an alternative format due to having a disability, please contact info@cialdini.com or +1 (602) 834-9429‬.

SUPPLEMENTAL PRIVACY POLICY AND NOTICE AT COLLECTION FOR CALIFORNIA, VIRGINIA AND NEVADA RESIDENTS 

Updated: 06/12/2023

This Supplemental U.S. State-Specific Privacy Notice (hereinafter referred to as the “State-Specific Notice”) supplements the information in our Privacy Policy, available at https://cialdini.com/legal/privacy-policy (the “Privacy Policy”), and contains disclosures that the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”) and such other data protections laws in California (collectively, the “California Law”), the Virginia Consumer Data Protection Act of 2021 (“Virginia Law”) and/or Chapter 603A of the Nevada Revised Statutes (“Nevada Law”) may require from us, Cialdini Institute, LLC (“we” or “us”) with respect to Personal Information collected from residents of the State of California, the Commonwealth of Virginia and the State of Nevada.
For general information on our privacy practices, please refer to the Privacy Policy. Unless otherwise specified, Section 1 of this State-Specific Notice applies to California residents only, Section 2 of this State-Specific Notice applies to Virginia residents only and Section 3 of this State-Specific Notice applies to Nevada residents only. This State-Specific Notice is incorporated in the Privacy Policy hereby by reference.  Capitalized terms not defined in this State-Specific Notice shall have the meaning assigned to them in the Privacy Policy. 

1.   CALIFORNIA
We note that California Law uses the term “personal information”. Any references to “Personal Data” below and in the Privacy Notice shall have the meaning assigned to the term “personal information” under California Law.
1.1.  COLLECTED PERSONAL INFORMATION
Below is a chart containing categories of Personal Information under the California Law that we have collected within the last twelve (12) months and may continue to collect. All of the categories of Personal Information set forth in the chart below are collected and used for all the purposes mentioned in Section 3 of the Privacy Policy and were disclosed/may be disclosed for a business purpose to the following categories of third parties: service providers, marketing partners, business partners and affiliates, other companies in the Cialdini group. 

We do not collect your financial information (like bank account number, credit card number or debit card number). Payments on our Website are processed by one or multiple third-party service provider(s) (e.g., PayPal, Inc., or Stripe, Inc.), who do not disclose your financial information to us. Before conducting payments through our Website, please refer to the terms and conditions and privacy policy of the third-party service provider processing your payment. We entered into agreements with such service providers which require them, among others, to only use your Personal Information for the business purposes for which we engaged them.
Please refer to Section 2.2 of the Privacy Policy for information on the sources from which we collect your Personal Information.
Please refer to our Retention Policy in our Privacy Policy for information on how long we retain your Personal Information.
1.2.  COLLECTED SENSITIVE PERSONAL INFORMATION
In the preceding twelve (12) months, we have not collected Sensitive Personal Information as defined in the California Law (“Sensitive Personal Information”) and do not intend to collect such information on and after the date of this State-Specific Notice.
1.3.  SALE  AND SHARING OF PERSONAL INFORMATION
We have not sold Personal Information or Sensitive Personal Information in the preceding twelve (12) months for monetary consideration and do not intend to do so. However, there are certain activities being conducted by or on behalf of Cialdini that may constitute as “sale” or “sharing” of Personal Information under California Law. For more information: on these activities, please see Section 4.2 of the Privacy Policy.
The categories of Personal Information that we intend to “sell” or “share” as defined in the California Law are as follows: (i) Identifiers, (ii) Commercial Information, (iv) Internet or other similar network activity.
We “sell” and/or “share” the above categories of Personal Information for the business and commercial purposes set forth in Section 3 of the Privacy Policy.
We may “sell” or “share” Personal Information to the following categories of third parties: marketing partners. Please refer to Section 4.1 of the Privacy Policy for the description of such categories of third parties.
1.4.   YOUR RIGHTS AND CHOICES
California Law provides the below specific rights to California residents regarding their Personal Information. This section describes your rights under California Law and explains how to exercise those rights.
1.4.1.   RIGHT TO KNOW AND RIGHT TO ACCESS
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive your request and confirm your identity (see Section 1.5 of this State Specific Notice), we will disclose to you: 

- The categories of Personal Information we collected about you;
- The categories of sources from which we collected Personal Information about you;
- Our business or commercial purpose for collecting, disclosing, “selling” or “sharing” of such Personal Information;
- The categories of Personal Information we disclosed about you for a business purpose and the categories of third parties to whom such Personal Information was disclosed for a business purpose; and
- The categories of Personal Information that we “sold” or “shared” about you and the categories of third parties to whom your Personal Information was “sold” or “shared”, by category or categories of Personal Information for each category of third parties to whom the Personal Information was “sold” or “shared”;
- The specific pieces of Personal Information we collected about you.

1.4.2.  RIGHT TO DELETE
You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity (see Section 1.5 of this State Specific Notice ), we will review your request to see if an exception allowing us to retain the Personal Information applies. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:

- Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Help to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 of Title 12 of Part 2 of the Penal Code (Cal. Penal Code § 1546 et. seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research that adheres to all other applicable ethics and privacy laws, when our deletion of the Personal Information is likely to render impossible or seriously impair the ability to complete such research, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and/or
- Comply with a legal obligation.

We will then delete or de-identify Personal Information not subject to one of these exceptions from our records and will direct our service providers, contractors and third parties to whom we have sold or shared your Personal Information to take similar action, unless this proves impossible or involves disproportionate effort. However, we may maintain a confidential record of your deletion request solely for the purpose of preventing your Personal Information from being sold, for compliance with laws of for other purposes permissible under California Law.

1.4.3   RIGHT TO CORRECT
You have the right to request that we correct your Personal Information if you think they are inaccurate, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. Once we receive your request and confirm your identity (see Section 1.5 of this State Specific Notice), we will use commercially reasonable efforts to correct your inaccurate Personal Information and will direct our service providers to do the same.
1.4.4.  RIGHT TO OPT-OUT OF SALE OR SHARING
You have the right to direct us to stop “selling” (i.e., disclosing your Personal Information to third parties for monetary or other valuable consideration or “sharing” your Personal Information (i.e., disclosing your Personal Information to third parties for cross-contextual behavioral advertising).
In case our activities are qualified as a “sale” or “sharing” of your Personal Information (see Section 1.3 of this State-Specific Notice for more information on these activities, you can request to opt out of such “sale” or “sharing” through the following link cialdini.com/contact that you can also find on our Website titled “Do Not Sell or Share My Personal Information”. See also 1.5 of this State Specific Notice. At any time, you can also use our cookie preference tools to manage what kinds of cookies and other tracking technologies you’re comfortable with. You can also disable cookies altogether by adjusting the settings on your browser. However, if you choose to disable some or all cookies, many parts of our services may no longer work. Please refer to our Cookie Policy for more information.
Once we receive your request and confirm your identity (see Section 1.5 of this State Specific Notice), we will stop selling or sharing your Personal Information, unless you subsequently provide consent for the sale or sharing of your Personal Information.
1.4.5.  RIGHT TO LIMIT USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION
California Law provides its residents with a right to limit the use and disclosure of Sensitive Personal Information. [However, we do not currently collect, use or disclose Sensitive Personal Information triggering California Law’s opt-out requirements.]
1.4.6.  OTHER CALIFORNIA PRIVACY RIGHTS
California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@cialdini.com or write us at: 2248 S. Forest Avenue, Tempe, Arizona 8528   Attention: Privacy officer of Cialdini. Except for our affiliates, our policy is not to disclose any Personal Information to a third party for their direct marketing purposes without your approval.

1.5   EXERCISING YOUR RIGHTS UNDER CALIFORNIA LAW
You may exercise your rights mentioned above as follows:
To exercise your rights to know, access, delete or correct described above, please submit a request by either:
- Calling us at +1 (602) 834-9429‬ ;
- Emailing us at info@cialdini.com; or
- Completing the online form on the website.
- To exercise your rights to Opt-out of Sale or Sharing, please submit a request by using the following link cialdini.com/contact that you can also find on our website titled “Do Not Sell or Share My Personal Information”.
To exercise your rights pursuant to California's “Shine the Light” law, please submit a request by either
- Emailing us at info@cialdini.com; or
- Writing us at  2248 S. Forest Avenue, Tempe, Arizona 8528   Attention: Privacy officer of Cialdini
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.
You may only submit a request to know twice within a 12-month period and a request pursuant to California’s “Shine the Light” law once during the course of a calendar year.
Your request related to Personal Information must:
Provide sufficient information or documentation that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Such information or documentation may include:
-  Certain Personal Information about you that we have on file (e.g., postal address) or information related to the purchases you made on the Website.
- Certain information or certification showing your authority or relationship to the person on whose behalf you are submitting the request.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request related to Personal Information or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you or the person on whose behalf you are submitting the request.
You do not need to create an account with us to submit a request related to Personal Information. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.
1.6.  RESPONSE TIMING AND FORMAT
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at info@cialdini.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. For requests under the California’s Shine the Light Law, we will respond within thirty (30) days of receipt of your request.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. Upon your request, unless impossible or involving disproportionately effort, we will also provide you with disclosures beyond the 12-months period for Personal Information. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is manifestly unfounded or excessive, in particular because of its repetitive character. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
1.7.  NON-DISCRIMINATION
We will not discriminate against you for exercising any of your rights pursuant to Section 1.4 of this State-Specific Notice. Unless permitted by the California Law, we will not:
Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
1.8.  MINORS
We do not sell the Personal Information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization from the parent or guardian of a minor less than 16 years of age.
If you are under the age of 16 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at info@cialdini.com We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected Personal Information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

2.   VIRGINIA
We note that Virginia law uses the term “personal data”. Any references to “Personal Information” below shall have the meaning assigned to the term “personal data” under Virginia Law.
2.1.  DISCLOSURES UNDER VIRGINIA LAW
- Please refer to Section 2 of the Privacy Policy for information on categories of Personal Information we have collected in the preceding twelve (12) months and may continue to collect. For more specific categories, please refer to Section 1.1 of this State-Specific Notice.
- Please refer to Section 3 of the Privacy Policy for information on the purposes for our collection and processing of Personal Information.
-We are disclosing the following categories of Personal Information with third parties for a business or commercial purpose: (i) identifiers (ii) other types of Personal Information that identifies, relates to, describes or is capable of being associated with you which are also referred to in the California notice as Personal Information pursuant to the California Customer Records statute (Cal. Civ. Code §1798.80 (e)), (iii) commercial information (e.g., records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); (iv) Internet or other similar network activity, (v) geolocation data, (vi) sensory data, (vii) inferences drawn from any of the other Personal Information listed above to create a profile about a consumer. For types of Personal Information that fall under these categories, please refer to Section 1.1of this State-Specific Notice.
- Please refer to Section 4 of the Privacy Policy for information on the third parties we disclose Personal Information with.
2.2   YOUR VIRGINIA RIGHTS REGARDING YOUR PERSONAL DATA
Virginia law provides Virginia residents with the rights listed below. To exercise these rights, see Section 2.3 of this State Specific Notice.
2.2.1.  RIGHT TO KNOW
You have the right to know whether we have collected Personal Information about you.
You also have the right to know what Personal Information we have collected about you and to obtain a copy of such Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another controller without hindrance, where the processing is carried out by automated means.
2.2.2.   RIGHT TO CORRECT
You have the right to request that we correct inaccurate Personal Information about you.
2.2.3.  RIGHT TO DELETE
You have the right to request that we delete the Personal Information we have collected about you.
2.2.4.    RIGHT TO OPT OUT FROM THE SALE OF PERSONAL INFORMATION, TARGETED ADVERTISING AND/OR PROFILING
We use and share your Personal Data with third parties for targeted advertising (i.e., displaying advertisements to you where the advertisement is selected based on Personal Information obtained from your activities over time and across non-affiliates websites or online application and predicting your preferences or interests) and for profiling (i.e., any form of automated processing performed on your Personal Information to evaluate, analyze or predict certain personal aspects about you.
You have the right to opt out of (i) targeted advertising, (ii) the sale of your Personal Data (as defined under Virginia law), or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
2.3.  EXERCISING YOUR RIGHTS UNDER VIRGINIA LAW
You do not need to create an account with us to submit a request related to Personal Information. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Virginia law, please contact us using one of the following methods:
- Via Website: You may visit our website to authenticate and exercise rights via our website.
- Via email: You may write to us to exercise your rights at info@cialdini.com.
To opt out of targeted advertising and the sale of Personal Information, you may also visit website.
To appeal our decision regarding a request related to these rights, you may write to us at info@cialdini.com.
2.4.  RESPONSE TIMING AND FORMAT
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your verifiable consumer request unless it is manifestly unfounded or excessive, in particular because of its repetitive character. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

3.   NEVADA
Please refer to Section 2 of the Privacy Policy and Section 1.1 of this State-Specific Notice for the categories of Personal Information that we collect and Section 4 of the Privacy Policy for the categories of third parties with whom we may share such Personal Information.
If you wish to review or request changes to any of your Personal Information we collect, please contact us via any of the methods mentioned in Section 7 of this State-Specific Notice.
We conduct targeted advertising, cross-context behavioral advertising and profiling. Please refer to Section 4.2 of the Privacy Policy for more information.Nevada Law provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: info@cialdini.com or visit this contact form. However, we do not currently sell Personal Information triggering Nevada Law’s opt-out requirements.

4.   APPEALING PRIVACY RIGHTS DECISIONS
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to info@cialdini.com.

5.   [OPT-OUT]PREFERENCE SIGNAL
You can also exercise your opt out rights for the “sale” to or “sharing” of Personal Information (in each case as defined under California Law) with third parties through an opt-out preference signal such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Our Website is configured to detect and process these global privacy control signals, and as a result we do not sell or share your Personal Information following a detection of such signal.] 

6. CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this State-Specific Notice at our discretion and at any time. When we make changes to this State-Specific Notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

7. CONTACT INFORMATION
If you have any questions or comments about this notice, the ways in which we collect and use your Personal Information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under the state laws set forth in this State Specific Notice, please contact us at:
Phone: +1 (602) 834-9429‬
Website: https://cialdini.com/
Email: info@cialdini.com
Postal Address: 2248 S. Forest Avenue, Tempe, Arizona 8528   Attention: Privacy officer of Cialdini

If you need to access this State Specific Notice in an alternative format due to a disability, please contact info@cialdini.com and +1 (602) 834-9429‬.

PRIVACY NOTICE FOR NON-U.S. RESIDENTS 

CIALDINI INSTITUTE LLC

1.   CIALDINI
We are Cialdini Institute LLC, having our registered office at 2248 S. Forest Avenue, Tempe, Arizona 8528, United States (“Cialdini”, “we”, “us” or “our”). Unless expressly stated otherwise, we, including our affiliated companies,  are the “controller” for the processing of personal data as described in this Privacy Notice (“the Privacy Notice”).

2.   OBJECTIVE OF THIS PRIVACY NOTICE
2.1.  This Privacy Notice describes why and how Cialdini processes your personal data, with which parties Cialdini shares your personal data and which rights you have with respect to your personal data.
2.2   When processing your personal data, we focus on the following core principles:
- To keep and secure personal data: Cialdini does not take your trusting us with your personal data for granted. We take responsibility in ensuring that appropriate security measures are put in place and your personal data is protected;
- To be transparent and to properly inform you as a data subject: understanding which personal data is collected and how, for what purpose we process personal data and how we secure personal data;
- To abide by applicable law: Cialdini is a global company that is focused on complying with all relevant legislation. The processing of your personal data may be subject to various types of laws and regulations, including, but not limited to, the General Data Protection Regulation (“the GDPR”); and
- To collect and store personal data on the “need to collect” basis: Cialdini collects personal data for several purposes. However, we have measures in place to prevent collecting and storing personal data beyond what we need or what is necessary.

3. PERSONAL DATA WE MAY COLLECT AND PROCESS
3.1   PERSONAL DATA
Cialdini may collect and process the following personal data from you in the following instances:
a) When you interact with us through the contact form on the website, we may collect the following data:
- Identity data, such as: your full name(s); and
- Contact data, such as: your e-mail address and telephone number.
Purpose: We only use the data to communicate with you if questions arise with regard to the fulfilment of the contract. We do not use this data for advertising purposes. Furthermore, the use of the data may be necessary to fulfil a legal obligation.
Legitimation: Article 6 (1) (b), (c) GDPR.
b) When you subscribe for the newsletter, we may collect the following data:
- Identity data, such as: your full name(s); and
- Contact data, such as: your e-mail address.
Purpose: At your express request, we will send you our newsletter by e-mail. You can withdraw your consent to this at any time with effect for the future.
Legitimation: Section 7 UWG, Article 6 (1) (a), Article 7 GDPR.
c) When you apply to a vacant position through the website, we may collect the following data:
- Identity data, such as: your full name(s);
- Contact data, such as: your e-mail address and telephone number; and
- Other data, such as: your CV.
Purpose: We process your personal data for the purpose of establishing, implementing and terminating an employment relationship.
Legitimation: Article 6 (1) (b), (c) GDPR.
Please note: If you wish to be included in our talent pool, this requires your consent in accordance with Article 6 (1) (a), Article 7 GDPR.
d) When you order products or services through our online store, we may collect the following data:
Identity data, such as: your full name(s);
Contact data, such as: your e-mail address and telephone number;
Location data, such as: your residential address; and
Other data, such as: payment and credit information.
Purpose: We only use the data to communicate with you if questions arise with regard to the fulfilment of the contract. We do not use this data for advertising purposes. Furthermore, the use of the data may be necessary to fulfil a legal obligation.
Legitimation: Article 6 (1) (b), (c) GDPR.
e) When you use our website, we may collect the following data:
You can visit our websites without providing any personal information. Each time you access a website, the web server only automatically saves a so-called server log file, which contains, the name of the requested file, your IP address, the date and time of the request, the amount of data transferred and the requesting provider (access data).
These access data are evaluated exclusively for the purpose of ensuring trouble-free operation of the site and improving our offer. This serves to protect our legitimate interests in the correct presentation of our website offer, which outweigh our interests in accordance with Article 6 (1) (f) GDPR. All access data are deleted at the latest seven days after the end of your visit to the site. The collection of the access data are, if applicable, legitimated by relevant local laws, such as Section 25 (2) German Telecommunications Telemedia Privacy Act (TTDSG). In order to make visiting our website attractive and to enable the use of certain functions, we use technologies including so-called cookies on our websites. We also use other tools (e.g. analytics tools). The (personal) data that we collect in this context as well as the purposes of our further processing and the legal bases are described in our cookie policy, please see our cookie policy which can be found through this [link].
3.2   SOURCE OD PERSONAL DATA
We solely collect and receive your personal data necessary for the purposes as set out in paragraph 3.1 above. No other sources, including public sources, are used unless explicitly stated otherwise.
3.3   RETENTION PERIODS
Personal data are retained for the duration as shown in the below overview, unless we are required by statutory law to retain your personal data for a longer period of time. Any personal data which is not included in the overview below, will not be retained longer than necessary to fulfill the purpose for which it was collected.

4.   THIRD PARTIES, RECIPIENTS AND TRANSFERS
4.1   We may share your personal data with third parties (“recipients”) if necessary for one or more of the purposes set forth below. The following categories of recipients may, if necessary, have access to your personal data:  
- Affiliated companies within the group, if necessary for compliance, internal reporting, audit or security purposes, or for the performance of an agreement with data subjects;
- Our accountants, legal advisors and other professional service providers engaged by us as necessary;
- Government agencies, courts, supervisory authorities, law enforcement or intelligence agencies, if we have a legal obligation to provide your personal data to them;
- Suppliers of IT services which we rely on for our systems; 
- Third parties in the context of (preparing for) a merger or acquisition of the company; and 
- Other third parties necessary for the performance of the agreement.
4.2.  Cialdini may transfer or provide access to your personal data to these partners in order to perform the agreement concluded with these partners and in the normal course of its business. Our legal basis to do so is Article 6 (1) (b) GDPR. When we transfer your personal data to our partners, we strive to keep the transfer of personal data to a minimum and limit the transfer to that which is strictly necessary.

4.3   Our business is global with affiliates and service providers located around the world. As such, personal data may be stored and processed in any country where we have operations. Also, your personal data may be transferred to countries outside the European Economic Area (EEA) which may not have the same data protection laws as the country you initially provided your personal data, but whenever we transfer or transmit your personal data internationally, we will ensure or take reasonable steps to ensure your personal data is handled securely in line with the applicable data protection laws and EU standard contractual clauses. More information regarding the EU standard contractual clauses, as well as the original provisions can be found through this link. 

5.   RIGHTS OF DATA SUBJECTS
5.1.  Depending on the relevant circumstances, the GDPR may grant you the following rights:
- The right to access personal data;
- The right to rectification of personal data;
- The right to request the erasure of personal data from Cialdini;
- The right to request Cialdini to restrict the processing of personal data;
- The right to object to the processing;
- The right to data portability;
- The right to file a complaint with a relevant supervisory authority; and
- Where processing is based on consent: the right to withdraw such consent at any time, without such withdrawal affecting the lawfulness of the processing prior to the withdrawal.

5.2.  Cialdini does not carry out automated decision-making, including profiling, as referred to in Article 22(1) and 22(4) of the GDPR.

6. SECURITY OF PERSONAL DATA 
6.1.  Cialdini is committed to secure the processing of your personal data, by relevant maintaining administrative, technical and physical controls with are designed to protect your personal data against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification. Therefore, we implement security measures where appropriate and applicable, such as, but not limited to:
- Pseudonymization and encryption of personal data;
- The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- The ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident; and
- A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures to ensure security of processing.

7.   CHANGES 
7.1 Cialdini may change this Privacy Notice from time to time. Please see the website for any updates and always read our most recent Privacy Notice before providing any personal data to us.

8.   QUESTIONS
8.1   Do you have any questions, concerns or comments about this Privacy Notice or Cialdini’s processing of your personal data? Please contact us via info@cialdini.com or our contact form.