Privacy Policy
Effective Date: January 1, 2025
Astute Learning Innovations LLC (“ALI,” “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, participate in our programs, or interact with us online or offline.
Astute Performance Consulting, APC Academy, and related learning tools or service lines may operate as brands, programs, or service offerings of Astute Learning Innovations LLC where applicable.
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, and job title
• Billing and payment details, if applicable
• Information shared through contact forms, newsletter sign-ups, assessments, coaching session bookings, diagnostic inquiries, event registrations, or other intake processes
Automatically Collected Information
• IP address, browser type, and device information
• Usage data collected through cookies, analytics tools, and similar technologies
Third Party Sources
• Information from partners, social media platforms, referrals, or third party tools, only where permitted or where you have provided consent
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, resources, or marketing communications with your consent
• Analyze usage to improve the website, programs, and user experience
• Administer assessments, diagnostics, workshops, advisory services, or learning programs
• Comply with legal obligations
3. Sharing of Information
We do not sell your personal information.
We may share information with:
• Service providers such as payment processors, CRM platforms, scheduling tools, email platforms, analytics providers, or website hosting providers
• Legal authorities when required by law
• Business partners only with your explicit consent
• Third party analytics or marketing tools using aggregate or non-identifiable data where applicable
4. Cookies and Tracking Technologies
We use cookies and similar technologies to:
• Remember user preferences
• Analyze website traffic
• Improve website performance
• Personalize your experience where applicable
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 where applicable
• 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 or method of digital storage is completely secure.
7. Data Retention
We retain 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, security, or content of those sites.
10. Your Rights Under GDPR, If You Are in the European Economic Area
If you are located in the European Economic Area, you may have the following rights under the General Data Protection Regulation:
• Right to access personal data
• Right to request correction of inaccurate or incomplete data
• Right to request deletion of your data
• Right to request restriction of processing
• Right to data portability
• Right to object to the processing of your personal data in certain situations
• Right to withdraw consent at any time when processing is based on consent
If you have questions or requests related to your rights under GDPR, please contact us at info@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 when posted.
12. Contact Us
If you have questions about this Privacy Policy or our practices, contact us at:
Astute Learning Innovations LLC
13. Consulting and Advisory Client Engagements
This section applies to individuals and organizations that engage Astute Learning Innovations LLC directly for consulting, advisory, diagnostic, coaching, workshop, training, or other professional services under a formal service agreement or statement of work, each a “Client Engagement.”
13.1 How We Collect Client Information
ALI 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, onboarding, interviews, workshops, or advisory sessions
• Documents, reports, organizational data, or other materials shared by the client for the purpose of delivering contracted services
• Notes, observations, and findings developed by ALI 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, ALI 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, role information, learning 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
ALI 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, tools, learning materials, and other contracted outputs
• To measure engagement outcomes and program effectiveness using aggregate or de-identified data
• To improve ALI’s service methodology, learning design, diagnostics, and curriculum where data is used in de-identified form only
• To comply with applicable legal obligations
ALI does not use client information for marketing, promotional, or business development purposes without the client’s explicit written consent. ALI 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
ALI treats organizational information, strategic data, financial context, operational information, employee information, and proprietary business information shared during a Client Engagement as confidential. ALI does not disclose client information to third parties except as follows:
• To subcontractors or support personnel engaged by ALI to assist in delivering contracted services, subject to confidentiality obligations
• 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
ALI may develop notes, findings, reports, learning materials, tools, strategic recommendations, and other deliverables 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.
ALI may retain 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
ALI implements reasonable administrative and technical safeguards to protect client information, including:
• Limiting access to client information to ALI personnel or approved support personnel directly involved in the engagement
• Using password protected and encrypted platforms for document storage and communication where reasonably practicable
• Avoiding the transmission of sensitive client information through unsecured channels where reasonably practicable
ALI 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
ALI 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 may include deliverables, key correspondence, engagement notes, assessment data, and project documentation.
At the end of the retention period, ALI will securely delete or destroy client information unless the client requests otherwise in writing or a longer retention period is required or permitted.
13.8 Client Rights
Consulting and advisory clients may request to:
• Confirm what information ALI holds related to their engagement
• Correct inaccurate information
• Delete their information following the applicable retention period
• Return or destroy specific materials shared during the engagement, subject to applicable agreements and legal requirements
• Receive information about how their data has been used
Requests related to client data should be directed to info@astuteli.com. ALI will respond within 30 days of receipt where reasonably practicable.
13.9 Testimonials and Case Studies
ALI 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 Learning Innovations LLC 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
ALI may collect personal information from program participants through the following mechanisms:
• Voluntary opt-in forms administered before, during, or after 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 ALI follow-up outreach
• Registration, intake, or participation forms completed directly through an ALI platform or form
ALI does not collect personal information from program participants through Partner Institutions unless a participant has separately and voluntarily provided that information directly to ALI or the Partner Institution has been authorized to share that information.
14.2 What We Collect from Program Participants
When a participant voluntarily opts into ALI follow-up communication, ALI may collect:
• Name, email address, or other contact information provided by the participant
• General information about how the participant applied program content to their business or work
• Self-reported business, learning, or performance outcomes related to program participation
Program evaluation surveys may be designed to collect aggregate, non-identifying responses where appropriate. When email addresses are collected through opt-in mechanisms, ALI may store them separately from survey response data where reasonably practicable.
14.3 How We Use Participant Information
ALI uses participant contact information for the following purposes:
• To conduct 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 or professional needs
• To measure program outcomes and improve ALI curriculum and program design using aggregate or de-identified data
• To communicate about related programs, services, or resources when the participant has provided consent
ALI does not use participant contact information for purposes not disclosed to the participant at the time of collection without the participant’s consent where required.
14.4 What We Share with Partner Institutions
ALI may provide Partner Institutions with aggregate, de-identified program evaluation data. This may include summary statistics, response distributions, and outcome indicators drawn from participant survey responses.
ALI does not share individual participant contact information, individual survey responses, or personally identifiable information with Partner Institutions unless the participant has consented, the sharing is necessary for program delivery, or the sharing is otherwise permitted by law.
14.5 Participant Consent and Opt-In
Participation in ALI follow-up surveys and communications is voluntary. Participants are informed at the time of collection of the purpose for which their contact information will be used and their right to decline or withdraw where applicable. Declining to provide contact information does not affect a participant’s access to available program content or materials unless contact information is necessary to deliver the requested item.
14.6 Participant Rights
Program participants may request to:
• Confirm whether ALI holds their contact information
• Request deletion of their contact information from ALI records
• Withdraw consent for follow-up communication by notifying ALI at info@astuteli.com or by using any unsubscribe mechanism included in ALI communications
• Request information about how their data has been used
ALI will respond to participant data requests within 30 days of receipt where reasonably practicable.
14.7 Data Retention for Program Participants
ALI retains participant contact information only for as long as necessary to fulfill the disclosed purpose, unless the participant has separately consented to ongoing communication or a longer retention period is required or permitted by law. 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, sponsor, host, or promote ALI programs are responsible for their own data collection and privacy practices regarding their clients, members, employees, or community participants. ALI’s privacy practices govern only data collected directly by ALI or collected on ALI’s behalf.