Privacy Policy
Effective Date: January 1, 2025
Astute Performance Consulting (“APC,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us online or offline.
1. Information We Collect
We collect personal and non-personal information in the following ways:
Information You Provide to Us:
Name, email address, phone number, company name
Billing and payment details (if applicable)
Information shared through contact forms, newsletter sign-ups, or coaching session bookings
Automatically Collected Information:
IP address, browser type, device information
Usage data through cookies and analytics tools
Third-Party Sources:
Information from partners, social media platforms, or referrals (only if you’ve consented)
2. How We Use Your Information
We may use your information to:
Provide and improve our services
Respond to inquiries and communicate with you
Process payments and manage transactions
Send newsletters, updates, or marketing (with your consent)
Analyze usage to improve user experience
Comply with legal obligations
3. Sharing of Information
We do not sell your personal information. We may share information with:
Service providers (e.g., payment processors, CRM platforms)
Legal authorities when required by law
Business partners, only with your explicit consent
Third-party analytics or marketing tools (non-identifiable data)
4. Cookies and Tracking Technologies
We use cookies and similar technologies to:
Remember user preferences
Analyze website traffic
Personalize your experience
You can adjust your browser settings to refuse cookies, though this may affect site functionality.
5. Your Rights and Choices
You may:
Access, update, or delete your personal information
Opt out of marketing communications at any time
Request data portability or restriction of processing
Submit a privacy-related complaint or inquiry
To make a request, contact us at: info@astuteli.com
6. Data Security
We implement reasonable administrative, technical, and physical safeguards to protect your personal information. However, no method of transmission over the internet is 100% secure.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.
8. Children’s Privacy
Our services are not directed to individuals under the age of 13. We do not knowingly collect personal data from children.
9. Third-Party Links
Our website may contain links to external websites. We are not responsible for the privacy practices or content of those sites.
10. Your Rights Under GDPR (If You Are in the EU)
If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):
Right to Access – Request a copy of your personal data
Right to Rectification – Request correction of inaccurate or incomplete data
Right to Erasure – Request deletion of your data ("right to be forgotten")
Right to Restrict Processing – Request to limit how your data is used
Right to Data Portability – Receive your data in a structured, commonly used format
Right to Object – Object to the processing of your personal data in certain situations
Right to Withdraw Consent – Withdraw consent at any time if processing is based on your consent
If you have questions or requests related to your rights under GDPR, please contact us at contactus@astuteli.com
11. Changes to This Policy
We may update this Privacy Policy occasionally. The revised version will be indicated by an updated “Effective Date” and will be effective as soon as it is posted.
12. Contact Us
If you have any questions about this Privacy Policy or our practices, contact us at: Astute Performance Consulting
info@astuteli.com
13. Consulting and Advisory Client Engagements
This section applies to individuals and organizations that engage Astute Performance Consulting directly for consulting, advisory, diagnostic, coaching, or other professional services under a formal service agreement or statement of work (each, a "Client Engagement").
13.1 How We Collect Client Information
APC may collect information from consulting and advisory clients through the following mechanisms:
Information provided directly by the client or their designated representatives during discovery calls, intake processes, or onboarding
Documents, reports, organizational data, or other materials shared by the client for the purpose of delivering contracted services
Notes, observations, and findings developed by APC in the course of delivering services
Communications including email, video calls, messaging platforms, and written correspondence
Assessments, diagnostics, surveys, or other instruments administered as part of the engagement scope
13.2 What We Collect from Consulting and Advisory Clients
In the course of a Client Engagement, APC may collect and hold the following categories of information:
Contact information for client representatives including name, title, email address, and phone number
Organizational information including company name, structure, size, and relevant operational context
Performance data, workflow information, and organizational findings shared or developed during the engagement
Financial context provided by the client to the extent necessary to deliver contracted services
Strategic information, planning documents, or proprietary business information shared by the client
Feedback, survey responses, and evaluation data collected as part of engagement measurement
13.3 How We Use Client Information
APC uses client information solely for the following purposes:
To deliver the services described in the applicable service agreement or statement of work
To communicate with client representatives regarding the engagement
To develop deliverables, reports, recommendations, and other contracted outputs
To measure engagement outcomes and program effectiveness using aggregate or de-identified data
To improve APC's service methodology and curriculum where data is used in de-identified form only
To comply with applicable legal obligations
APC does not use client information for marketing, promotional, or business development purposes without the client's explicit written consent. APC does not reference a client engagement, client name, or client-specific details in any public-facing material without the client's explicit written consent.
13.4 Confidentiality of Client Information
APC treats all organizational information, strategic data, financial context, and proprietary business information shared during a Client Engagement as confidential. APC does not disclose client information to third parties except as follows:
To subcontractors or support personnel engaged by APC to assist in delivering contracted services, subject to confidentiality obligations equivalent to those in this policy
As required by applicable law, regulation, or court order
With the client's explicit written consent
Confidentiality obligations survive the termination or completion of a Client Engagement.
13.5 Data Shared Within the Engagement
APC may develop notes, findings, reports, and strategic recommendations as part of a Client Engagement. These materials are produced for the client's use and remain the client's property upon delivery unless otherwise specified in the service agreement. APC retains working copies of engagement materials for internal records purposes only and does not repurpose, publish, or distribute client-specific materials without written consent.
13.6 Data Security for Client Engagements
APC implements reasonable administrative and technical safeguards to protect client information including:
Limiting access to client information to APC personnel directly involved in the engagement
Using password-protected and encrypted platforms for document storage and communication where reasonably practicable
Not transmitting sensitive client information through unsecured channels
APC acknowledges that no method of digital transmission or storage is completely secure and cannot guarantee absolute security of client information.
13.7 Data Retention for Client Engagements
APC retains client engagement records for a period of three years following the completion or termination of the engagement unless a longer retention period is required by law or agreed upon in writing. Retention covers deliverables, key correspondence, and engagement notes. At the end of the retention period, APC will securely delete or destroy client information unless the client requests otherwise in writing.
13.8 Client Rights
Consulting and advisory clients have the right to:
Request confirmation of what information APC holds related to their engagement
Request correction of inaccurate information
Request deletion of their information following the applicable retention period
Request that APC return or destroy specific materials shared during the engagement
Receive information about how their data has been used
Requests related to client data should be directed to info@astuteli.com. APC will respond within 30 days of receipt.
13.9 Testimonials and Case Studies
APC may request client permission to reference an engagement for marketing, thought leadership, or case study purposes. Any such reference requires the client's explicit written consent prior to publication. Clients may consent to a de-identified reference, a named reference, or decline entirely. Declining does not affect the delivery or quality of contracted services.
14. Program Participants and Partner Engagements
This section applies to individuals who participate in programs, workshops, sessions, or educational events developed and delivered by Astute Performance Consulting in partnership with or on behalf of third-party organizations, including but not limited to banks, credit unions, chambers of commerce, nonprofit organizations, and other institutional partners (each, a "Partner Institution").
14.1 How We Collect Participant Information
APC may collect personal information from program participants through the following mechanisms:
Voluntary opt-in forms administered at the close of a program session, including digital surveys distributed via QR code, web-based forms, or other electronic means
Follow-up surveys distributed after a session to measure program outcomes and participant application of session content
Direct communication initiated by the participant in response to APC follow-up outreach
APC does not collect personal information from program participants through Partner Institutions. Partner Institutions do not provide APC with participant contact lists, registration data, or any other individually identifiable participant information unless a participant has separately and voluntarily provided that information directly to APC.
14.2 What We Collect from Program Participants
When a participant voluntarily opts into APC follow-up communication, APC may collect:
Email address
General information about how the participant applied program content to their business following the session
Self-reported business outcomes related to program participation
APC does not collect names, business names, financial data, account information, or any other sensitive identifying information through its follow-up process. Program evaluation surveys are designed to collect aggregate, non-identifying responses. Email addresses collected through opt-in mechanisms are stored separately from survey response data and are not linked to individual survey responses.
14.3 How We Use Participant Information
APC uses participant contact information solely for the following purposes:
To conduct a scheduled follow-up communication within the timeframe disclosed to the participant at the time of opt-in
To deliver free resources, tools, or information relevant to the participant's business as described at the time of opt-in
To measure program outcomes and improve APC curriculum and program design using aggregate, de-identified data
APC does not use participant contact information for general marketing, promotional campaigns, or any purpose not disclosed to the participant at the time of collection without the participant's explicit additional consent.
14.4 What We Share with Partner Institutions
APC provides Partner Institutions with aggregate, de-identified program evaluation data only. This includes summary statistics, response distributions, and outcome indicators drawn from participant survey responses. APC does not share individual participant contact information, individual survey responses, or any personally identifiable information with Partner Institutions at any time.
14.5 Participant Consent and Opt-In
Participation in APC follow-up surveys and communications is entirely voluntary. Participants are informed at the time of collection of the specific purpose for which their contact information will be used, the approximate timeframe of follow-up communication, and their right to decline or withdraw at any time. Declining to provide contact information does not affect a participant's access to any program content or materials.
14.6 Participant Rights
Program participants have the right to:
Request confirmation of whether APC holds their contact information
Request deletion of their contact information from APC records at any time by contacting info@astuteli.com
Withdraw consent for follow-up communication at any time by notifying APC at info@astuteli.com or by using any unsubscribe mechanism included in APC communications
Request information about how their data has been used
APC will respond to participant data requests within 30 days of receipt.
14.7 Data Retention for Program Participants
APC retains participant contact information only for the duration of the disclosed follow-up period. Once follow-up communication is complete, participant contact information is deleted from APC records unless the participant has separately consented to ongoing communication. Aggregate, de-identified survey response data may be retained indefinitely for program evaluation and curriculum improvement purposes.
14.8 Partner Institution Responsibilities
Partner Institutions that co-deliver or sponsor APC programs are responsible for their own data collection and privacy practices regarding their clients, members, or community participants. APC's privacy practices govern only data collected directly by APC. Partner Institutions are encouraged to inform their communities that APC may offer an optional follow-up opt-in at the end of any co-delivered session.