1. Who we are

This website is operated by Kevin Hanegan, a sole proprietor doing business as Data into Wisdom Consulting ("we," "us," or "our"), based in Massachusetts, United States. Data into Wisdom Consulting has operated since 2023.

For the purposes of the EU General Data Protection Regulation (GDPR) and the UK GDPR, we act as the data controller for personal information collected through this website.

If you have any questions about this policy or your personal information, contact us at [email protected].

2. Information we collect

We collect the following categories of information:

Information you provide to us

• Account information. When you create a free or paid membership, we collect your name and email address, and account preferences.
• Payment information. When you purchase a paid membership, payment is processed by our payment provider. We do not store full payment card numbers on our systems.
• Contact form submissions. When you contact us, we collect the information you submit, such as your name, email, organization, and the content of your message.
• Assessment responses. If you complete an assessment or diagnostic, we collect your responses in order to generate your results.

Information collected automatically

• Usage data. We collect information about how you interact with the site, such as pages and resources viewed, searches, and filter selections.
• Device and connection data. This may include your browser type, device type, approximate location derived from your IP address, and referring pages.
• Learning progress. If you use the Learning Hub, we store your bookmarks, recently viewed items, and progress through Learning Journeys. For free members this is stored in your browser; for paid members it may also be synced to our servers so it is available across your devices.
• Cookies and similar technologies. See the Cookies and tracking section below.

We do not intentionally collect special categories of personal data (such as health, race, or religious information), and we ask that you not submit such information through the site.

3. How we use information

We use the information we collect to:

• Provide, maintain, and operate the website and its services
• Create and manage your membership account
• Process payments and manage subscriptions
• Deliver content, learning resources, and assessment results
• Save and sync your learning progress and bookmarks
• Respond to your inquiries and provide customer support
• Send you service-related communications and, where permitted, newsletters and updates
• Understand how the site is used so we can improve it
• Detect, prevent, and address security issues, fraud, or abuse
• Comply with legal obligations

4. Legal bases for processing (EU/UK users)

If you are located in the European Economic Area or the United Kingdom, we process your personal data only where we have a legal basis to do so. Our legal bases are:

• Performance of a contract. To provide the membership and services you have signed up for.
• Legitimate interests. To operate, secure, and improve the site, where those interests are not overridden by your rights.
• Consent. For non-essential cookies and for marketing communications, where consent is required. You may withdraw consent at any time.
• Legal obligation. Where we must process information to comply with applicable law.

5. Cookies and tracking

We and our service providers use cookies and similar technologies to operate the site, keep you signed in, remember your preferences, and understand site usage.

Essential cookies are necessary for the site to function, such as keeping you logged in to your membership account. Non-essential cookies support analytics and usage measurement.

You can control cookies through your browser settings, including blocking or deleting them. If you are in a region that requires consent for non-essential cookies, we will seek your consent before setting them. Disabling some cookies may affect how the site works for you.

6. How we share information

We do not sell your personal information. We share information only in these circumstances:

• Service providers. With the third parties that help us operate the site and deliver our services, described in the next section.
• Legal and safety reasons. Where required by law, legal process, or to protect the rights, safety, or property of our users or others.
• Business transfers. In connection with a merger, acquisition, or sale of assets, in which case we will notify affected users.
• With your direction. When you ask us to share your information, or otherwise consent.

7. Service providers

We use trusted third-party service providers to operate the website and deliver our services. Each processes personal information only as needed to provide its service to us. These include:

These providers may process data in the United States or other countries. Each processes personal information only as needed to provide its service to us.

8. International data transfers

We are based in the United States, and our service providers may process information in the United States and other countries. If you are located in the European Economic Area or the United Kingdom, your personal data may be transferred to and processed in a country that does not provide the same level of data protection as your home country.

Where we transfer personal data internationally, we take steps to ensure it remains protected, including relying on appropriate safeguards such as Standard Contractual Clauses where applicable.

9. Data retention

We keep personal information for as long as it is needed for the purposes described in this policy. In general:

• Account and membership information is kept while your account is active and for a reasonable period afterward.
• Payment records are kept as required for tax, accounting, and legal purposes.
• Contact form submissions are kept as long as needed to address your inquiry and for our records.
• Usage and analytics data is kept for a limited period to support site improvement and security.

When information is no longer needed, we delete it or anonymize it.

10. How we protect information

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

11. Your privacy rights

Depending on where you live, you may have some or all of the following rights regarding your personal information:

• Access. Request a copy of the personal information we hold about you.
• Correction. Ask us to correct inaccurate or incomplete information.
• Deletion. Ask us to delete your personal information.
• Restriction and objection. Ask us to limit or stop certain processing.
• Portability. Receive your information in a portable format.
• Withdraw consent. Withdraw consent where we rely on it, without affecting prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within the time required by applicable law. We may need to verify your identity before acting on a request.

If you are in the EU or UK and believe we have not handled your information properly, you have the right to lodge a complaint with your local data protection authority.

12. California privacy rights

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives you specific rights regarding your personal information:

• Right to know. Request the categories and specific pieces of personal information we have collected about you.
• Right to delete. Request deletion of personal information we have collected from you.
• Right to correct. Request correction of inaccurate personal information.
• Right to opt out. Opt out of the "sale" or "sharing" of personal information.
• Right to non-discrimination. We will not discriminate against you for exercising any of these rights.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. To exercise your California rights, contact us at [email protected]. You may use an authorized agent to make a request on your behalf, subject to verification.

13. Children's privacy

This website is intended for adults and is not directed to children. We do not knowingly collect personal information from children under the age of 16. If you believe a child has provided us with personal information, contact us and we will take steps to delete it.

14. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. If we make material changes, we will provide additional notice as appropriate. We encourage you to review this page periodically.

15. Contact us

If you have questions or requests regarding this Privacy Policy or your personal information, contact us: