Thank you for: (i) accessing www.system-3.com (the “Site”), and/or (ii) participating in System-3’s software as a service (SaaS) based predictive leadership simulation (the “Leadership Simulation”), and/or (iii) accessing System-3’s analytics dashboard including any information or reports provided therein (the “S-3 Dashboard” and, together with the Site and the Leadership Simulation, the “S-3 Solution”).

The S-3 Solution is owned and operated by System-3 Inc. (“System-3”). All references to ‘we,’ ‘us’ or ‘our’ within this Privacy Policy (the “Policy”) refer to System-3.
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1. Agreement to The Policy & Modifications
a) Agreement to this Policy. By accessing or using the S-3 Solution, you indicate that you understand, accept, and consent to the practices described in this Policy. If you have any questions about the Policy, please email us at privacy@system-3.com.
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b) Modifications to this Policy. We may modify the Policy at any time, at our sole discretion, by posting the modified Policy at https://www.system-3.com/privacy-policy. It’s important that you review the Policy on a regular basis. If you are an Admin (as defined below) we will notify you of any changes to the Policy that we consider to be material modifications by sending an email to the email address affiliated with your Admin ID (as defined below). If you are a User (as defined below), we will notify you of any changes to the Policy that we consider to be material by sending an email to the email address to which your User ID (as defined below) was initially sent. As a User, you can update your contact email with us by emailing privacy@system-3.com and notifying us of your new email. You hereby agree that: (i) if you are an Admin, your continued use of the S-3 Solution after we’ve posted the modified Policy on the Site, and (ii) if you are a User, your failure to notify us via email at privacy@system-3.com that you do not consent to the modified Policy; shall indicate and constitute your agreement to be bound by the modified Policy. If you don’t agree to be bound by the modified Policy, then you may no longer use the S-3 Solution and, if you are a User, please email us and notify us that you do not consent to the modified Policy.

2. Description of the S-3 Solution and Important Definitions
‍Below is a brief outline of the nature of the S-3 Solution. This background will help you better understand the Policy.
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‍Leadership Simulation
‍The Leadership Simulation is a SaaS based predictive simulation designed to minimize bias and objectively measure whether a participant deploys “today’s must have Leadership Competencies” when under executive pressure.

‍S-3 Dashboard
‍The S-3 Dashboard is a unique, state of the art, analytics dashboard providing data and information regarding the results generated from Leadership Simulations.

‍User Reports
‍Participants in the Leadership Simulation (“Users”) will receive personal reports regarding the results of their participation (“User Reports”).

‍Customers and Customer Reports
‍The System-3 customer (“Customer”) who has referred the User to participate in the Leadership Simulation will receive reports, data and analysis regarding the results of such User’s participation in the Leadership Simulation including, but not limited to, through data provided on the S-3 Dashboard (all such information and reports, in any form whether written or oral, together, “Customer Reports”).

The Customer may share Customer Reports internally, with their personnel, affiliates and contractors who have a need to know such information pursuant to the MSA, and, when applicable, with Customer’s clients, consultants, portfolio companies, investors or other permitted third-party recipients on a confidential basis (all together “Permitted Recipients”). The Permitted Recipients are identified in the applicable MSA (as defined below). System-3 may also share Customer Reports directly with Permitted Recipients and Permitted Recipients may be granted access to the S-3 Dashboard to access Customer Reports.

Customers engage System-3 in a variety of circumstances, including (i) for the purposes of an internal talent management/assessment/recruitment for their organization, (ii) to assess existing or potential portfolio companies, or (iii) to utilize the Solution with their clients as part of a service that Customers provide to their clients (each such engagement, a “Project”). Each Project is governed by a Master Services Agreement between the Customer and System-3 (the “MSA”).

‍Independent Users
‍If you are a User who was not referred to System-3 pursuant to an MSA or by a Customer, no reports regarding the results of your participation in the Leadership Simulation will be sent to any third parties without your consent. Notwithstanding the above, System-3 will be permitted to collect and make use of your personal information, the results of your participation in the Leadership Simulation and any other information pursuant to the terms of this Policy.  

3. Personal Information We Collect & Where We Get it From
‍We collect personal information: (i) from the Customer to enable us to provide Users and Admins access to the S-3 Solution, (ii) directly from Users and Admins provided to us voluntarily when using the S-3 Solution, (iii) from publicly available and/or accessible sources, and (iv) through automated tracking technologies.  Below is a detailed list of what information we collect and how it is collected.  

a) Personal Information Collected Regarding Users:
We collect the names and email addresses of Users from the Customer so that we can grant Users access to the Leadership Simulation. In certain cases, we may collect additional information regarding Users from the Customer (“Additional Information”) including performance reports and other information regarding the User’s professional performance, all as set out in the applicable MSA. If you are a User and want to know specifically what personal information we will collect about you from the Customer pursuant to the applicable MSA, please email us at privacy@system-3.com.

‍When you participate in the Leadership Simulation we will collect, your name, contact information and assessment responses, as well as metrics on how you used and interacted with the Leadership Simulation by using a combination of automated technology and other methods. We may also request additional information from Users, such as employment and education history and professional credentials.

At the end of the Leadership Simulation, you may be asked to participate in a voluntary survey which will include a diversity survey (the “Diversity Survey”) and other specific questions related to your professional experience (the “Professional Experience Survey”). The responses you provide to the Diversity Survey and the Professional Experience Survey, if you elect to participate, will not have any impact on your Leadership Simulation results.

System-3 may also, from time to time, collect publicly available and/or accessible business and career information about Users both prior to and following a User’s participation in the Leadership Simulation (“Public Data”). This Public Data may be collected from a variety of sources including, but not limited to, information available on Users’ LinkedIn profiles as well as information provided about Users on their employers’ or personal websites.

b) Personal Information Collected Regarding Admins:
‍We collect the names and email addresses of Admins from the Customer so that we can grant Admins access to the S-3 Dashboard. We may also collect certain metrics and usage information regarding how you interact with the S-3 Dashboard.

c) Automatic Information Collection & Tracking Technologies
When you use the S-3 Solution, our technology may automatically collect a variety of technical information as well as information regarding your usage of the S-3 Solution. We may either collect such information ourselves or authorize third party service providers to collect this information on our behalf utilizing their software tools integrated into the S-3 Solution. Information collected via automated tracking technologies may include: IP address, browser and device characteristics, operating system, location information and usage information regarding the way you use and interact with the S-3 Solution.

System-3 uses cookies and other similar tools to conduct web analytics, in order to optimize the S-3 Solution’s performance and functionality. Web browser settings can allow you to control the cookies stored on your hard drive. If you choose to disable cookies, you will still be able to visit the Site but certain functionalities of the S-3 Solution may be limited.

4. How We Use the Personal Information We Collect
a) Use of Users’ Personal Information
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‍Name & Contact Information
‍We use the names and email addresses of Users to contact Users to enable them to participate in the Leadership Simulation. With a User’s consent, we may also use such information for marketing purposes.  

‍Leadership Simulation Data & Results
‍The data obtained through the User’s participation in the Leadership Simulation will be analyzed by predictive models and machine learning algorithms developed by us to produce an evaluation of a User’s leadership profile and competencies. The results will be shared with the Customer and, as applicable, the Permitted Recipients, in the form of Customer Reports. Customer Reports may also include recommendations to be considered, along with other information to support discussions about talent recruitment, talent development, succession planning, team building and other recommendations related to the applicable Project.

‍If you are a User and want to know more about who the Permitted Recipients are who will be receiving the Customer Reports generated from your personal participation in the Leadership Simulation, please email us at privacy@system-3.com.

‍Users will receive a User Report outlining the results of the User’s participation in the Leadership Simulation.

System-3 will use the data obtained through the Leadership Simulation (including from the Diversity Survey and Professional Experience Survey) as well as Public Data, and Additional Information for internal research and analysis, product refinement, and testing to develop and to improve the Leadership Simulation and System-3’s products and services on an ongoing basis. The Public Data may also be used to track Users’ professional and/or career development in order to improve and refine Sytem-3’s ability to make accurate predictions and enhance its products.

‍Diversity Survey Information
System-3 uses the data obtained through the Diversity Survey on an ongoing basis to improve our  Leadership Simulation and our other products and services and to reduce bias and improve decision-making in leadership identification and talent management.

Professional Experience Survey Information
‍System-3 uses the data obtained through the Professional Experience Survey on an ongoing basis to improve our  Leadership Simulation and our other products and services and improve decision-making in leadership identification and talent management.

b) Use of Admins’ Personal Information
We use the names and email addresses of Admins to to enable them to access the S-3 Dashboard. With an Admin’s consent, we may also use such information for marketing purposes.  

c) Use of Anonymized Data & Aggregated Data
‍Notwithstanding anything to the contrary in this Policy, we may use, share and sell aggregated or anonymized data either collected by us or generated from information collected by us for any purpose and without restriction including to develop, improve and commercialize products and services.

5. Who We Share Personal Information With 
We understand the importance of limiting the sharing your personal information with third parties to what is reasonably necessary for providing and improving our products and services and otherwise fulfilling the purposes for which the information is collected. We may share your personal information in the following circumstances:
- With Developers: System-3 software and technology developers have access to information that is related to or useful for the development and improvement of our software, machine learning algorithms, products and services.
- Customer Reports: We share System-3 Leadership Simulation results, in the form of Customer Reports, through secure means with the Customer and Permitted Recipients.
- Our Service Providers: We may share information with contractors, services providers and other third parties we use to support the S-3 Solution and our products, services and business operations.
- Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of System-3 assets, financing, or acquisition of all or a portion of our business.
- Affiliates: We may share your information with our affiliates. Affiliates include any parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Comply with Applicable Law: We may share your information as required by any court order, law, legal process or government or regulatory request.
- Enforce Our Rights: We may share your information as reasonably necessary to enforce our rights arising from any contract between us and you, including the Terms of Service applicable to you or the applicable MSA.
- Protect Us or Others: We may share or transfer your information if we believe it is necessary to protects the rights, property or safety of us, our customers or other Users or Admins.

Note that, pursuant to the above, we may transfer personal information to other countries in which case the personal information transferred will be subject to those countries’ laws.

We do not share or sell any personal information with third parties for marketing or other purposes. The safeguards we put in place to ensure third parties protect the personal information we share with them are described in Section 6 below.
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6. How We Protect Your Personal Information
a) Protective Measures.
We use a combination of physical, technological, and organizational controls to protect the personal information we collect.
- System-3 uses Microsoft Azure for data processing and storage, and data is stored on secure servers.
- We retain data for the period of time that we deem necessary depending on the purposes for which it is collected and the permitted uses we make of the data. While data is retained, it is protected, when we deem it no longer necessary to be retained, we destroy the data. Notwithstanding the above, we will retain data as required by applicable law.
- When we transfer personal information to third parties, we use secure channels to transfer information and we ensure the recipients of the information are subject to confidentiality agreements that protect the information being transferred.
- All of our employees and contractors sign confidentiality agreements with us.  

b) Inherent Risk.
Despite the above measures, no safeguards are guaranteed and any collection or transfer of personal information poses risks. No electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Furthermore, we can not guarantee that third parties will abide by their confidentiality obligations or data security responsibilities. ‍

‍c) Breach Protocols.
As a result of the aforementioned risks, System-3 has risk mitigation protocols in place, including protocols for responding to data breaches which include assessing whether it is reasonable in the circumstances to believe that a breach has created a real risk of significant harm to an individual and, if such a risk is confirmed, reporting the breach to the relevant authorities and to the affected individuals.

7. Your Rights & How to Exercise Them 
Depending on where you are located geographically and where your residency is, applicable privacy law may provide you certain rights regarding your personal information beyond what is explicitly provided for in this Policy. We have outlined some rights that may apply to you below.

If you have any questions about our information management practices or to exercise your rights, please contact us at privacy@system-3.com with your request and we will respond promptly.

If you are located in Canada, your rights likely include:
- The right to access your personal information that we have collected.
- The right to request that we amend any errors in your personal information.
- The right to be notified of a data breach that creates a real risk of significant harm to you.

For general information on privacy rights in Canada visit www.priv.gc.ca. To make a request with respect to your personal information, please contact us at privacy@system-3.com. We will comply with applicable legal obligations and our obligations under this Policy with respect to requests we receive.  


Last updated May 22, 2023.

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Summary of the personal information System-3 collects and how we use it

Research, Product Development and Testing

User Leadership Simulation Results for Customers