Privacy Policy

As of update date 9/1/2013

This website is owned and operated by EurekaConnect, LLC (“EC”, “we”, or “us”). We work diligently to protect the privacy, confidentiality, and security of the Personal Information that we receive. This Privacy Policy describes the principles and practices that apply to the Personal Information (defined below) that we collect from individuals online or offline (“visitor” or “you”), such as individuals who browse through our Site (defined below), register on the Site, use the services provided on the Site, interact with the Site, communicate with us through telephone, email, text or other communications means, participate in our interviews, surveys, or promotions, or read or receive our newsletters.

This Privacy Policy is based on the following values:

  • We will not collect your Personal Information without your knowledge
  • We will take reasonable measures to protect the security of your Personal Information
  • We will not disclose your Personal Information to third parties other than as described in this Privacy Policy
  • You will be able to view the Personal Information that we have about you, and to correct or modify it if it is inaccurate or incomplete.


In this Privacy Policy, the following terms are defined as set forth in this section:
“Assessment” means an instrument, questionnaire, or series of tests that are completed by an Assessment Taker in view of the preparation of a Report or to provide information about, or to, an Assessment Taker, Customer, or Test Administrator.

“Assessment Taker” means an individual who takes, will take, or has taken an Assessment.

“Customer” means an individual, business, or other entity that purchases EurekaConnect Products or Services, including, without limitation: (a) an individual or business that purchases reports sold by EC (b) an individual or business that purchases online Assessment services and Assessment Reports; © an entity with which EC has a contractual relationship to provide other Products or Services.

“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services. It also includes other information, such as IP address, device information, or other Session Data that can reasonably be linked to a specific individual, computer or other device.

“Products or Services” means the Products or Services promoted, sold, or available for sale from the Site or through EC personnel

“Report” means an analysis of the scoring and responses provided in connection with an Assessment, that is developed by EC, and which (i) a Test Administrator, using a validated methodology, may interpret for an Assessment Taker during one or several feedback sessions or interpretation sessions; or (ii) a Customer may use in its business with the Assessment Taker.

“Behavioral Specialist" means an individual who has been trained in the EC/Giombettis Associate methodology or otherwise qualified to review Assessments using said methodology, and who administers Assessments to Assessment Takers, analyzes the scores and Reports generated by EC from these Assessments, interprets these scores and Reports using the EC/GA Proprietary methodology, and, at the Test Administrator’s discretion provide these scores and reports to Assessments Takers.


By using the Site and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy and on the Site and agree that we may collect, use, disclose, store, transmit, or process such Personal Information in accordance with this Privacy Policy or as required by law.

If you reside in a country or territory that restricts the transfer of Personal Information out of that country or territory, you agree to the transfer, storage, and processing of your Personal Information to countries, including the United States, that may not have data protection laws that provide the same level of protection as those that exist in your country of residence.


This Site may link to websites that are operated by third parties. These websites are not subject to this Privacy Policy. We recommend that you read the privacy statements that are posted on these third-party websites to understand their procedures for collecting, using, and disclosing Personal Information.


We collect only such Personal Information as necessary to provide our Products or Services to you, inform you about our Products and Services, continue our research in the field, and improve our Site, Products, Services, and your experience interacting with EC. In some cases, we ask questions to which the response is optional, and these questions are identified as such. You are free not to respond to these optional questions. We describe below the different ways in which we collect or obtain Personal Information.

If you visit the Site -- If you visit the Site, we automatically collect the related Session Data. Session Data is provided to us by your browser and through our log files, which record your activities while browsing our Site, such as when you click on a link. We may record some of this data in one or several cookies that we send to your browser. This session data may be used for analysis purposes through a third party service such as Google Analytics

If you register or create an account -- If you register or create an account, we require that you fill out a form to register as a purchaser or Customer (as applicable). We collect your name, contact information, and other information, and may ask you for other optional information that helps us serve you better.

If you purchase a Product or Service -- If you purchase a Product or Service, we collect your contact information as necessary to fulfill the order (such as name, address, shipping information, email address, or telephone number) and optional information if you provide it. By providing another person’s Personal Information, you represent that you have that person’s permission to do so.

If you complete an Assessment -- If an Assessment Taker completes an Assessment at the direction of a Customer (e.g., an employer, a Test Administrator, etc.), whether online or offline, we collect the Assessment Taker’s unique identifier and in some cases, the Assessment Taker’s gender, and DOB. The Assessment Taker also has the option to provide demographic information such as highest level of education attained or occupation, as well as company information such as title, company, and address. We collect the responses provided to the questions in the Assessment.

If you participate in a survey -- If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address (to avoid duplicate responses), as well as any other Personal Information that you may provide in your survey responses. The responses from survey participants are compiled in an anonymized format.

If you sign up to receive an EC newsletter -- If you sign up to receive a EC newsletter, we may collect information on the open rate of the newsletter, and whether a specific individual has clicked on a link contained in a particular issue of our newsletter.

If you are a Customer or other business contact -- If you are a Customer or other business contact, or if you are an employee or agent of a Customer or business contact, we may collect your email address, telephone, contact information, and correspondence in the regular course of our interaction with you.

If you participate in our blogs or forums, or if you write to us -- We may collect the Personal Information that you provide in your correspondence and communications with us, or through your participation in surveys, blogs, and forums.

If you interact with third parties regarding our Products or Services -- We may receive Personal Information about you from third parties, such as from Customers, Test Administrators, Test Administrators’ employers, websites where we advertise, business partners, and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.


We use Personal Information in order to provide and enhance the Products or Services that we offer as explained below:

To facilitate the use of the Site -- We use the Session Data to ease navigation throughout the Site, to enhance navigation, such as to determine the language of the country where the visitor is located, keep track of the shopping cart or keep track of login name and password in order to avoid requesting identity information when the visitor moves from page to page, and in general to enhance the quality of our Site and the content provided on the Site.

In connection with Assessments -- We use the responses to an Assessment to score the Assessment and prepare the related Report about the Assessment Taker. The Report is delivered to our Customer. We retain a copy of your responses and the related Report in accordance with our record retention policy.

To provide our Products and Services -- The Personal Information collected from purchase order forms is used to send orders to our Customers. The limited payment information that we receive from our payment processors is used to verify that a Product or Service has been paid for.

For research purposes -- We may use aggregated Session Data to better understand how our Site is navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at our Site, the different types of searches of our Site content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Site, in order to improve our Site and enhance our content. We may use IP addresses to gather broad demographic information—information that is not associated with any individual, and is therefore anonymous. The IP addresses are then disposed of in accordance with our record retention policy.

For maintenance purposes -- We may use IP addresses and session data to diagnose problems with our server, and to administer our Site.

For marketing purposes -- We may use email addresses or other contact information to send mailings, newsletters, and other marketing collateral regarding product information and releases. We may use your telephone number to contact you for marketing purposes. We may use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of the communications that we send.

For survey analysis -- The information that we collect through our surveys is not used other than to garner survey results and statistical analysis. Such data are used in aggregate form only and never disclose an individual's identity.


From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:

Assessments Reports -- EC provides its Customers with the information that they need to properly counsel or advise their clients, customers, and employees, as applicable. If you are taking an Assessment at the direction of one of our Customers, that Customer will receive from EC a Report on the Assessment that you took, so that he or she may properly counsel or advise you or provide you with other services.

Service providers -- We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, shipment, order fulfillment, payment credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, and direct marketing campaign service providers. For example, If during the creation of your account, you affirmatively indicate to us that you are exempt from taxes, we share your email address with our service provider who will email you a link describing how you can use their service to verify your tax-exempt status. Pursuant to written agreements between EC and these service providers, each of these service providers only has access to such Personal Information as necessary to fulfill its obligation to EC, is not permitted to use Personal Information for any purposes other than those directed by EC, and is required to act in a manner consistent with the relevant principles articulated in this Policy

To defend or enforce our rights -- EC may use Personal Information to protect itself or to protect the Site, to respond to a breach of its Terms and Conditions, to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to EC, EC may send that EC customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments. Co-marketing -- We may collaborate with other companies to offer you additional Products or Services (e.g., book publishers). We will share Personal Information that is necessary for these other companies to provide the Products or Services that you have requested. This Privacy Policy does not cover the use of your Personal Information by these companies. We encourage you to read a company’s privacy policy before requesting any of its Products or Services.

Law Enforcement; Litigation -- Certain federal, state, local, or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information (a) if we believe in good faith that a law, regulation, rule or guideline requires it; or (b) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person.

Aggregated data -- Other than as stated above, if EC provides a third-party with Personal Information, it will be in the form of aggregated data and used for product development, research, or statistical analysis. Aggregated data are created from records that are stripped of all personal identifiers, such as a combination of thousands of answers to survey questions and instrument responses, or on-site behavior.


A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected, or identified by configuring a browser’s preferences. Pixel tags or clear gifs are tiny graphics with a unique identifier, that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. We do not tie the information gathered by clear gifs to Personal Information.

Cookies and pixel tags are used to help recognize a returning visitor, and to help customize the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (e.g., by registering with us), we will not know who the individual visitor is. The Site uses cookies as follows:


We retain scored item responses and the related Report associated with the user ID or transaction number that our Customer provided us in accordance with our internal record retention policy and for at least four (4) years from the date when an Assessment Taker took an Assessment. Thereafter, we retain the scored item responses and Report in an anonymized format, for as long as the information is needed for our research, statistical analysis, or product development.


Security -- We follow generally accepted industry standards to protect Personal Information, during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect it from any unauthorized access, loss, misuse, disclosure, alteration, or destruction. When we need to transfer information out of our firewall, we use industry-standard technological means to protect Personal Information while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security.

No method of transmission over the Internet, or method of electronic storage, is fully secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Identity Theft -- Identity theft and the practice currently known as “phishing” are of great concern to us. For more information about protecting yourself from these practices, you may want to visit


We exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting us as indicated in the “Contact Us”


Right of access, modification -- If you wish to have access to your Personal Information, or to correct or update the Personal Information that you have provided to EurekaConnect, please contact us with proof of identity, as provided in the Contact Us section. You can expect a response to your request within 30 days. If you are an Assessment Taker, and you wish to have access to a copy of your responses to an Assessment, or a copy of the Assessment Report that EC prepared from the evaluation of your responses, please contact the Test Administrator who is managing your specific Assessment.

If you wish to have access to the Assessment Report that EC prepared about a third party, please contact that third party.

Right of deletion -- If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at the address provided below. We will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Right to opt-out of the use of your Personal Information -- You may unsubscribe from receiving any of the EC surveys by selecting the appropriate option during account setup or modification once you are logged into your account. You may unsubscribe from receiving a newsletter by clicking on the unsubscribe link provided in the newsletter.

Right to block cookies -- You have the right to block cookies and pixel tags. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access most of our Products or Services.


If you have questions or complaints regarding our privacy policy or practices, you should first contact the Legal Department of EurekaConnect as indicated in the section “Contact Us” below. We will respond to your questions and will attempt to resolve all complaints promptly.


We may from time to time change this Privacy Policy. If we make material changes, we will place a prominent notice on the Site or will send you a notice to the email address that you provided to us.


If you have any question about (a) this Privacy Policy, or (b) the collection, use, management, or disclosure of your Personal Information, or © accessing, modifying, or closing your account, please contact us as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them.

  • By email:
  • By phone: 781.245.7773
  • By mail: EurekaConnect, LLC
  • 2 Central Street, Suite 18
  • Ipswich, MA 01938
  • USA