Privacy Policy



 Last Updated:   July 15, 2022


This Privacy Policy (“Privacy Policy”) sets out how Pitts Leadership Consulting LLC (referred to as “PLC”) uses and protects any information that you (referred to as “you” or “your”) provide when accessing, browsing, purchasing Services, contacting, and/or using our Website, (the “Website”).


PLC is committed to ensuring that your privacy is protected. You can be assured that any personal identifying information (hereinafter referred to as “Personal Information” and defined below) you provide when using the Website will only be used in accordance with this Privacy Policy. This Privacy Policy describes the type of information PLC may collect from you or that you may provide when using the Website and/or Services (as defined below), as well as PLC’s practices for collecting, using, keeping, protecting, and/or disclosing any Personal Information.




What Personal Information is Collected?


When browsing, entering, engaging with, or otherwise accessing the Website; contacting or engaging PLC for its services, which include, but are not limited to: (a) Leadership and Executive Coaching; (b) Training and Facilitation; (c) Keynote Speaking; and (d) Human Capital Consulting and Advising (the “Services”); or conducting any other activity on the Website as described in the Terms and Conditions (the “Terms”), you may be asked to enter or disclose various types of Personal Information, which may include, but is not limited to:


* Contact Information: name, e-mail, postal address, telephone number, business contact information, or any other similar information.

* Identification and Demographics: date of birth, gender, nationality, ethnicity, interests, lifestyle information, photos, social media credentials, contacts, or referrals.

* Transactional: payment information, billing address, and registration information.

* Customer Content: photos, videos, reviews, and other information you may submit, such as comments on the Website, other online forums, and social media platforms.

* Research and Feedback: reviews and comments that you send through the Website and social media platforms; by e-mail, over the phone or by mail.

* Device Information and Identifiers: IP addresses, cookie IDs, browser types and language, operating systems, platform type, and device type.

* Connection and Usage: domain names, browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an e-mail, content you view and duration, quality of the service, and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded when you next connect.

* Geolocation: city, state, and ZIP code associated with your IP address or derived through Wi-Fi triangulation. PLC will ask for your permission before using your precise location from GPS-based functionality on your mobile devices.

* Social Media Information: if you interact through a Third Party Platform or social media website using your social media credentials, depending on your social media settings, PLC may have access to your information from that social network such as your name, e-mail address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments, and the people and other websites you follow.

* Additional Information: any additional information you provide either directly through the Website or through your participation, support request, interaction through PLC’s social media accounts, or any other communications.


When is Personal Information Collected?


Generally, you are not under any statutory or contractual obligation to provide PLC any Personal Information; however, certain Personal Information may be automatically collected in order for you to use the Website and/or Services.


PLC collects information from you when you browse, enter, or use the Website; contact or engage PLC for its Services; fill out an online form; or otherwise enter any information on the Website or PLC’s social media platforms which may include, but are not limited to, Facebook, Instagram, Twitter, SoundCloud, YouTube, Pinterest, Google, or other third party applications (together the “Third Party Platforms”).


How do you get my Consent?


When you provide any Personal Information on the Website, verify, or change your transactional details, complete a contact form, verify, or change your credit/debit card information, comment on a forum, or anything of the like, you are automatically consenting to collecting, storing, and using that information for your benefit and to improve PLC’s offerings and your experience.


If PLC asks for your Personal Information for any other reason, it will either: (a) ask directly for your express consent; or (b) provide you with an opportunity to say no or otherwise decline by contacting PLC directly.


How do I withdraw my consent?


If you change your mind, you may withdraw your consent for the continued collection, use, or disclosure of your Personal Information at any time by contacting PLC directly. PLC reserves the right to retain any information previously collected for the purposes of resolving any disputes, as well as for obtaining and/or analyzing its aggregated data analytics.


How is your Personal Information used?


PLC may use such Personal Information in any of the following ways:


*To personalize your experience on the Website.

* To provide and implement the Services.

* To maintain and improve the Website to better serve you and provide a more seamless experience across all devices.

* To allow PLC to better service you in responding to your service requests or other queries.

* To quickly process your transactions.

* To send periodic e-mails regarding products, services, events, or subscriptions, as they become available.

* To investigate and help prevent security issues, abuse, or violations of law or the Terms.

* Displaying content you generate, such as video, audio, and comments on the Website or on Third Party Platforms.

* Compliance with laws, regulations, and ethical business conduct.


How is your Personal Information protected?


PLC takes the security of your Personal Information very seriously. PLC implements a variety of security measures when you use the Website, engage PLC for the Services, or otherwise enter or input your Personal Information. You must prevent unauthorized Personal Information by selecting and protecting your password and/or other sign-on mechanisms appropriately. Your Personal Information is accessible only to a limited number of persons who have the authority to access it, including but not limited to, contractors or agents PLC that may employ to perform tasks, fix bugs, and/or monitor the Website on behalf of PLC.


Does PLC collect information from minors?


PLC does not want to, and does not knowingly, collect any data from individuals under the age of eighteen. If PLC learns that it has collected any such data without the supervision of a parent or legal guardian, PLC will take all reasonable measures to delete such information and will not use it for any purposes. If you become aware of any Personal Information that PLC has collected from a child under the age of eighteen without the supervision of a parent or legal guardian, please contact PLC immediately.


How do I opt-out, remove, or modify any Personal Information I have provided?


You can request to have your Personal Information removed by contacting PLC directly. Please note that PLC may retain information about individual sales transactions in order to complete said transactions and for record keeping purposes.


How do I opt-out, remove, or modify any Personal Information I have provided?


You can request to have your Personal Information removed by contacting PLC directly. Please note that PLC may retain information about individual sales transactions in order to complete said transactions and for record keeping purposes.


Acceptance of Terms


Through the use of the Website, you are hereby accepting this Privacy Policy and each of the terms and conditions stipulated herein. If you are not in agreement with this Privacy Policy, you should refrain from any further use of the Website and Services. Your continued use of the Website and Services, following the posting of any updates or changes to this Privacy Policy, shall indicate that you are in agreement and acceptance of such changes.


Limitation of Liability


You acknowledge and agree that to the fullest extent allowed by applicable law, under no circumstances will you hold PLC liable for consequential, indirect, incidental, special, exemplary, punitive, or enhanced damages, that are caused or alleged to be caused in connection with your use of the Website, or your purchase or engagement with any of its Services. For clarity, under no circumstances will you hold PLC liable for any damages caused by or related to the Website and/or your use of the Services.


Does the Website use 'cookies'?


Yes. PLC and its service providers, advertisers, and other third parties use cookies and similar technologies (e.g., HTTP cookies, HTML 5, flash local storage cookies, web beacons, GIFs, embedded scripts, ETags/cache browsers, and software development kits) to recognize you on, off, and across your devices. Cookies are small files that PLC or its service providers transfer to your computer's hard drive through your web browser (if you allow) and/or your device that enables PLC or its service provider's systems to recognize your browser or device to capture and remember certain information. They are also used to help PLC understand your preferences based on previous or current Website activity, which enables PLC to provide you with improved services. The Website also uses cookies to help PLC compile aggregate data about Website traffic and interaction so that PLC can offer better experiences and services in the future.


PLC and its Third Party Partners and vendors may use tracking technologies, such as cookies, pixels, and web beacons and collect and store information about you when you use or interact with the Website, marketing communications, advertising content and/or third party websites, in order to provide you with targeted advertising based on your browsing activities and interests. These third parties automatically receive your IP address or mobile device identifier when you access the Website or third party websites. They may also use Tracking Technologies to measure the effectiveness of advertisements, to personalize the advertising content, and to serve you advertisements that are relevant to your regional location. PLC may also use information collected using third party cookies and beacons in its emails to deliver advertising when you visit third party websites.


You can opt-out of targeted advertising by visiting the following pages:





Cookies are used to:


* Understand and save your preferences for future visits.

* Compile aggregate data about traffic and interactions in order to offer better experiences in the future. PLC may also use trusted third party service providers that track this information on its behalf.


You can choose to have your computer or device warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser or device settings.


If you disable cookies, some features on the Website may be disabled. Disabling cookies may also affect your experience by decreasing the Website’s efficiency or causing it to not function properly.


Third Party and other disclosures of your Personal Information


PLC may share your non-private or Personal Information with other companies, advertisers, partners, social networks, service providers, research and management companies, search engines, law enforcement, hosting partners, and other parties who assist in operating the Website, conducting its business, or otherwise servicing you. Similarly, if PLC is involved in a merger, collaboration, or acquisition, your Personal Information may be transferred. However, PLC will provide you with notice before your Personal Information is transferred and becomes subject to a different privacy policy.


PLC may also release your Personal Information under certain circumstances where PLC believes release is appropriate to comply with the law, enforce its policies, and/or protect PLC or others' rights, property, or safety. PLC may also be required to disclose your Personal Information if required by law or in response to a valid request by a public authority (e.g., a court or governmental agency).


How is your Personal Information Shared and Disclosed?


PLC may share and disclose your Personal Information for the following reasons:


* Customer Instructions: You can determine your own policy for the sharing and disclosure of your Personal Information and PLC does not control how you choose to share or disclose your Personal Information. PLC will share and disclose your Personal Information in accordance with your instructions and in compliance with applicable law.

* Compliance with Applicable Law: If PLC receives a request for information, PLC may disclose Personal Information if it reasonably believes disclosure is in accordance with or required by any applicable law, regulation, or legal process.

* To Enforce Our Rights, Prevent Fraud, and For Safety: To protect and defend the rights, property, or safety of PLC or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

* Third Party and other disclosures of your Personal Information: PLC may share your non-Personal Information with related Third Party Platforms, companies, advertisers, social networks, service providers, research companies, search engines, law enforcement, hosting partners, and other parties who assist PLC in operating the Website, conducting business, or otherwise servicing you.


PLC may also release your Personal Information under certain circumstances when PLC believes it is appropriate to comply with the law, enforce its policies, and/or protect PLC or others' rights, property, or safety. PLC may also be required to disclose your Personal Information if required by law or in response to a valid request by a public authority (e.g., a court or governmental agency).

* With Consent: PLC may share Personal Information with third parties when it has consent to do so.


Retention of your Personal Information


PLC will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. PLC will retain and use your Personal Information to the extent necessary to comply with its legal obligations (for example, if it is required to retain your data to comply with applicable laws), resolve disputes, complete audits, and/or enforce its legal agreements and policies.


Third Party Links


Occasionally, at its discretion, PLC may include or offer third party advertisements or services on the Website. These third parties have separate and independent privacy policies. Therefore, PLC has no responsibility or liability for the content and activities of these third parties. Nonetheless, PLC seeks to protect the integrity of the Website and welcome any feedback about these other third party links.


Behavioral Advertising


As described above, PLC may use your Personal Information to provide you with targeted advertisements or marketing communications PLC believes may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at




As a condition of certain Services offered by PLC, you consent to the collection, use, transfer, and storage of employee data as described below. You hereby understand that PLC may hold certain information regarding your employees, including, but not limited to, their names, home addresses, telephone numbers, dates of birth, social security numbers, salaries, nationalities, job titles, shares of common stock or directorships held, employee options (the “Employee Data”). You further understand that PLC may transfer Employee Data amongst PLC personnel as necessary for the purposes of implementation, administration, and management of the Services and that PLC may further transfer Employee Data to any third parties assisting PLC in the implementation, administration, and management of the Services. For the avoidance of doubt, all Employee Data will be held in the strictest confidence and shall not be transferred, sold, or otherwise provided in any way to any third party outside of PLC.




PLC is headquartered in the United States; however, PLC may transfer your information to service providers and other third parties located outside of your country of residence, including in the United States. This may be necessary to provide its Services and for the purposes outlined in this Privacy Policy. Data privacy laws vary from country to country and may not be equivalent to, or as protective as, the laws in your home country. PLC takes steps to ensure that reasonable safeguards are in place with the aim to ensure an appropriate level of protection for your Personal Information, in accordance with applicable law. These measures include data transfer agreements. By providing PLC with your Personal Information you acknowledge and agree to any such transfer, storage or use.


Some Services can only be provided if PLC has your Personal Information and Employee Data, therefore deletion of your Personal Information and Employee Data may result in termination of such Services. PLC will take reasonable steps to verify your identity, including authenticating you through your e-mail address. PLC may require further documentation before granting access to your information.




Special Notice for California Residents


PLC shall not market or advertise to minors specified products or services that minors are legally prohibited from buying. PLC shall not market or advertise any products based on the Personal Information provided that is specific to any minor, nor shall it knowingly use, disclose, compile, or allow a third party to do so. Under California's Privacy Rights for California Minors in the Digital World Act, any minor may request and obtain removal of Personal Information posted on the Website.


Your California Privacy Rights. California residents are entitled once a year, free of charge, to request and obtain information regarding PLC’s disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. To obtain this information, please send an e-mail to PLC directly.


California Consumer Privacy Act (CCPA)


The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of Personal Information, as well as the right to access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”


“Do Not Sell My Personal Information” (California Residents only)


California residents may opt-out of the “sale” of their Personal Information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior to add to a profile about your mobile device, browser, or you.


Depending on how you use the Website, PLC may share the following categories of information for such advertising which may be considered a sale (as defined by California law):


* Identification and demographics; device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history; geolocation information, such as city; and inference data.


If you would like to opt-out of the use of your Personal Information for such purposes (to the extent this is considered a sale), you may do so as by contacting PLC directly.


Third Parties’ List – Shine the Light (California Residents only)


California residents can also request a list of all the third parties to which PLC has disclosed certain Personal Information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. You will need to attest to the fact that you are a California resident. PLC will not accept requests by telephone, e-mail, or facsimile, and PLC is not responsible for notices that are not labeled or sent properly, or that do not have complete information.


Special Notice for Nevada Residents


Nevada law requires PLC to post the following: certain Nevada consumers may opt-out of the sale of “Covered Information” for monetary consideration to a person for that person to license or sell such information. Covered information includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.


Virginia Consumer Data Protection Act (Effective January 1, 2023)


Under the Virginia Consumer Data Protection Act (“VCDPA”), certain businesses must give consumers the ability to access, control, and delete personal data that the business collects about them, or that consumers have otherwise provided. Consumers have the right to obtain a copy of data the consumer has previously provided, in a usable format “to the extent technically feasible.”


Virginia consumers can opt out of targeted advertising, the sale of their personal data, or profiling that results in the business providing or denying “financial and lending services, housing, insurance, education enrollment, criminal justice, employment opportunities, health care services, or access to basic necessities, such as food and water.”


Utah Consumer Privacy Act(Effective December 31, 2023)


The Utah Consumer Privacy Act (“UCPA”) provides Utah residents with the right to (1) confirm whether a controller is processing the consumer’s personal data and to access that personal data; (2) delete the consumer’s personal data that the consumer provided to the controller; and (3) obtain a copy of the consumer’s personal data that the consumer previously provided to the controller.


The UCPA defines “Personal Data” as information that is linked or reasonably linkable to an identified or identifiable individual. Data that cannot be linked to a consumer and publicly available information and the processing of personal data for purely personal or household purposes are excluded from the UCPA. Data controllers must provide consumers with reasonable, accessible, and clear privacy notice. Controllers must establish and maintain reasonable administrative, technical, and physical data security practices to protect the confidentiality and integrity of personal data and reduce reasonably foreseeable risks of harm to consumers relating to the processing of personal data.


Connecticut Data Privacy Act(Effective July 1, 2023)


The Connecticut Data Privacy Act (“CTDPA”) defines “Consumer” as a Connecticut resident and excludes persons acting in a commercial or employment context. The “Sale of Personal Data” refers to the exchange of personal data for monetary or other consideration by the controller to a third party.


Personal data excludes any deidentified data or publicly available information, where publicly available information means information that is lawfully made available through government records or widely distributed media and a controller has a reasonable basis to believe a c


onsumer has lawfully made available to the general public. Under the CTDPA, Connecticut consumers are provided with (1) the right to access; (2) right to correct; (3) right to delete; (4) right to data portability; and (5) right to opt out of the sharing of any Personal Data.


Colorado Privacy Act (Effective July 1, 2023)


Under the CPA, “Consumers” are defined as residents acting in their individual or household contexts and excludes individuals acting in a commercial or employment capacity, job applicants, and beneficiaries of someone acting in an employment context from its definition of “consumer.” “Personal Data” is defined to mean information that is linked or reasonably linkable to an identified or identifiable individual. The CPA does not extend to deidentified data or publicly available information. Under the CPA, businesses will need to provide consumers with clear privacy notices and conduct data protection assessments for any personal data processing that presents a heightened risk of harm to consumers. Consumers are afforded the right to opt out of the processing personal data for targeted advertising or for the sale of personal data and provides a “user-selected universal opt-out mechanism.”


Changes to this Privacy Policy


PLC is constantly aiming to improve its Website and Services, so it may need to change this Privacy Policy from time to time. PLC reserves the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Website. If PLC makes any material changes to this Privacy Policy, PLC will notify you here that it has been updated so you are aware of what information PLC collects, how PLC uses it, and under what circumstances, if any, it uses and/or discloses it to any third party.


If you have any questions regarding this Privacy Policy or if you want to verify, modify, receive, suspend, or delete your Personal Information stored, you can reach PLC directly using the contact information provided below:


Pitts Leadership Consulting LLC


Email: Address: 90 State Street, Suite 700, Office 40, Albany, NY 12207