Privacy Policy
Your privacy is very important to the entire team at Thayer Leader Development Group, Incorporated (“Thayer”). To help protect your privacy, we adhere to the following guidelines:
If you sign up to receive our newsletter or ask to be contacted by Thayer, you will be required to give your name and contact information. If you complete a registration form to participate in a Thayer program, you will also be required to provide certain additional personal and credit card information. This information is used to facilitate billing, fill your order and contact you about the products/services on our site in which you have expressed interest. Credit card numbers are only used for processing payments. If we have trouble processing an order, we'll use this information to contact you and potentially process any refunds.
If you are a participant in a Thayer program, we may collect personal information about you, including your name, contact information, job title, payment information, your image in photos or videos and other identifying information (“Personal Data”). We will not ask for sensitive personal information about you regarding, for example, health information, religious affiliation or political beliefs, and ask you not to provide us with such information not necessary to provide the Thayer programs and services. We will use your Personal Data to: (1) fulfill our contractual obligations to you by providing the Thayer materials and services, (2) verify your account information, (3) improve your user/participant experience, (4) send you occasional newsletters and other promotional and marketing information about Thayer, and (5) verify services to a faculty member’s credentialing organization in the event of an audit, but only if you received personal coaching services and only with your prior consent. We use your Personal Data for legitimate business purposes, to satisfy our contractual obligations to you, to comply with the law, and with your consent.
Certain Personal Data may be provided to our web site hosting server, credit card processor, our affiliates (The Thayer Hotel at West Point), subcontractors (including faculty) and other vendors (the platform provider of our digital programs, the company providing battlefield experiential programs and the company providing rowing and dragon-boating experiential programs, for example) necessary to process your payment, support our site and/or provide the products and services to you, all of whom are bound by obligations of confidentiality regarding such information. For on-site programs at our facility, we will also ask for government-issued photo ID information, solely to provide to the Historic Thayer Hotel for submission to the Frederick V. Malek Visitors Center at the United States Military Academy at West Point for their verification and approval of your access onto and tour of the grounds of West Point. For Thayer programs paid for by another party (i.e., your employer or a corporate host), we may provide information about your participation or attendance to the paying point of contact, without providing specifics regarding your contributions to any program. If we intend to use Personal Data for another use, we will not do so without your explicit prior consent.
Thayer does not collect Personal Data from anyone under the age of 18 years old. If we discover that a child has submitted Personal Data to us, we will attempt to delete such information as soon as possible. If you believe that we might have any Personal Data from a child under 18 years old, please contact us at info@Thayerleadership.com.
You may instruct us to provide you with any Personal Data we hold about you. We will provide such information to you free of charge upon your proof of your identity (for this purpose, we will usually accept photocopies of your current passport or driver’s license, as certified by a notary). We may withhold Personal Data that you request, to the extent permitted by law.
You may correct, update, amend, transfer, delete/remove Personal Data, or deactivate your account without charge, as well as object to or restrict the collection of further Personal Data, by emailing Thayer at mailto:info@thayerleadership.com. You may instruct us at any time not to process your personal information for marketing purposes. None of these requests will affect our services or prices to you, except to the extent that your deactivation of your account or deletion of Personal Data affects our ability to provide our services to you. You may also withdraw your consent to this policy by contacting us at the above e-mail address at any time. We will respond to your request within a reasonable timeframe. We will correct and update without delay information that we understand to be incorrect or outdated.
Thayer will retain Personal Data only for as long as necessary to provide services to you or as provided in this policy, and shall permanently delete such information promptly thereafter. Notwithstanding the other provisions of this policy, we will retain Personal Data to the extent that: (1) we are required to do so by law, (2) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings or investigations, (3) to establish, exercise, or defend our legal rights and (4) to verify accounts, monitor possibly fraudulent behavior and identify possible violations of this policy. Thayer may retain anonymous information about participants for statistical purposes. Information you provide in setting up your account with Thayer will be retained as long as you maintain the account. Your e-mail will be retained for the above-mentioned purpose (i.e., for future educational, training and promotional purposes) until you notify us of your wish not to be further contacted by us.
Thayer’s Executive Director is the data protection officer and employee responsible for maintaining and enforcing this policy (direct contact: mailto:kkuhla@thayerleadership.com). Thayer shall train all its employees and faculty in this policy and agrees to be responsible for any breach of this policy by such employees and faculty. Thayer shall also inform all subcontractors (other than faculty) about, and request their compliance with, this policy and/or with a separate data processing agreement containing Standard Contractual Clauses or similar provisions regarding the protection of your Personal Data. You may, at your expense, request an audit (during business hours upon reasonable advance notice and by qualified independent auditors) to confirm our compliance with this policy, and all expenses associated with Thayer fixing any breach shall be paid by Thayer.
Personal Data that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. Collected Personal Data may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area or the United States. Personal Data that you publish on our website or submit for publication on our website may be available, via the Internet, around the world. We cannot prevent the use or misuse of such Personal Data by others. You expressly agree to the transfers of Personal Data described in this policy.
Your visit to our site is tracked through a standard web traffic statistics program, which keeps records of traffic on the site. Our server automatically collects data about your server’s Internet address when you visit us. You should also be aware that your information may be automatically collected through the use of "cookies". "Cookies" are small text files that our site can use to recognize repeat users, facilitate your ongoing access to and use of the site and allow our site to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. Cookies are not programs that come onto a system and damage files. Generally, cookies work by assigning a unique number to each customer that has no meaning outside the assigning site. If you do not want information collected by cookies or wish to delete cookies already stored on your computer, most browsers have a simple procedure allowing you to deny or accept, and to delete, the cookie feature; however, you should note that cookies may be necessary to provide you with certain features (e.g., customized delivery of information) available on our web site.
We take reasonable, industry-standard technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information, including the storage of all Personal Data on our secure (password- and firewall-protected) servers. All electronic financial transactions entered into through our website will be protected by Secure Sockets Layer (SSL) encryption technology and will be processed in compliance with payment card industry standards (PCI DSS). However, you acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website). We do not use automated decision making in processing your Personal Data.
Thayer has controls to detect a breach of security that are standard for companies of its size and industry. In the event of a breach of security of your Personal Data, Thayer will promptly investigate and formally document the breach and any actions taken to address the breach, and, if appropriate and necessary, report the breach to you and/or the appropriate authorities.
Thayer may be the controller (when we ask you for Personal Data) and/or processor (when we receive your Personal Data from another party like your employer) of Personal Data under this policy. Thayer is based in the United States and maintains its servers in the United States. If you are attending a Thayer program outside of the United States, please note that Personal Data is not localized. If you are visiting from outside the United States, by using our site and services, your personal information will be transferred to the United States for processing. Thayer is obligated to comply with U.S. government laws and regulations related to data collected by Thayer for the purposes of providing the services for which you have engaged Thayer. This could require local data storage or duplication of data storage across geographic regions.
Our website may include hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
If you believe this web site has not adhered to these guidelines, please notify Thayer and we will use all commercially reasonable efforts to promptly determine and correct the problem.
California Do Not Track Disclosure: Thayer does not track you over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
California Privacy Rights Notice: Thayer does not share your Personal Data with any third parties for their direct marketing use unless you give us your explicit prior consent. Thayer does not sell any Personal Data. If you are a resident of California, California Civil Code Section 1798.83 allows you, once a year, to request information regarding the disclosure of your Personal Data by Thayer to a third party for such third party’s direct marketing purposes. To make such a request, please contact us at info@thayerleadership.com.
By using the Thayer website, you consent to our use of your information as described in this Privacy Policy (last revised on October 1, 2020). We reserve the right to change our privacy policy at any time without advance notice. Should a new policy go into effect, we will post it on this site, and the revised policy will apply only to information collected thereafter. You should check this page occasionally to ensure you understand any changes to this policy.
