About The Psychologically Safe Leader Coaching CultureSafe Journal My Library

Privacy Policy

 

Updated 8/31/2026

CultureSafe Consulting, LLC — www.jamesheffner.com

CultureSafe Consulting, LLC, which operates this website, is committed to handling your personal data lawfully and transparently, including under the European Union General Data Protection Regulation (GDPR), and the Connecticut Data Privacy Act. This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

CultureSafe Consulting, LLC (“us”, “we”, or “our”) operates the https://www.jamesheffner.com website (the “Service”).

1. Who We Are

CultureSafe Consulting, LLC is the publisher of this website. We are a Connecticut-based organizational development and learning consultancy specializing in psychological safety, culture transformation, and leadership development. We are located at 30 Woodruff Avenue, PO Box XX, Watertown, Connecticut, 06795. This website exists to share our work and to connect leaders and organizations with our coaching, training, and consulting services.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used here have the same meanings as in our Terms and Conditions, accessible from https://www.jamesheffner.com.

2. Definitions

Service. The https://www.jamesheffner.com website is operated by CultureSafe Consulting, LLC.

Personal Data. Data about a living individual who can be identified from that data, or from that data combined with other information either in our possession or likely to come into our possession.

Usage Data. Data collected automatically, either generated by use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies. Small pieces of data stored on your device (computer or mobile device).

Data Controller. The natural or legal person who, alone or jointly with others, determines the purposes for which and the manner in which personal information is processed. For the purpose of this Privacy Policy, we are the Data Controller of your Personal Data.

Data Processor (or Service Provider). Any natural or legal person who processes data on behalf of the Data Controller. We use various Service Providers to process data on our behalf.

Data Subject (or User). Any living individual who uses our Service and is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes, including to provide, market, and improve our Service.

When we collect data about you

We collect personal data about you when:

  • You use the Service or purchase our products or services;
  • You subscribe to our newsletter, download a resource, or register for a program, workshop, or community;
  • You interact with us in person, by phone, by email, through social media, or through the Service; and
  • We receive your information from a client organization that has engaged us to deliver training, coaching, or consulting to you or your team.

Personal Data

While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Employer, job title, and industry
  • Address, state, province, ZIP/postal code, city
  • Information you voluntarily include in a contact form, intake questionnaire, or program application
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any or all of these communications by following the unsubscribe link or instructions in any email we send, or by contacting us directly.

Assessment and program data

If you participate in one of our assessments, surveys, or training programs, we may collect the responses you provide. Where we deliver a program under contract with your employer, we report findings to that employer in aggregated or de-identified form unless you have been told otherwise in writing at the point of collection. We do not sell this data, and we do not use it to train large language models or other artificial intelligence systems.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). Usage Data may include your device’s Internet Protocol (IP) address, browser type and version, the pages of our Service you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Location Data

We may use and store information about your general location, such as the region inferred from your IP address, to understand where our audience is and to comply with regional privacy requirements. We do not collect precise geolocation from your device unless you give us permission through your device settings, which you can enable or disable at any time.

Cookies and tracking technologies

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We also use beacons, tags, pixels, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you do not accept cookies, some portions of our Service may not function properly.

Examples of cookies we use:

  • Strictly necessary and session cookies. Used to operate the Service, keep you logged in, and process transactions.
  • Preference cookies. Used to remember your preferences and settings.
  • Security cookies. Used for security purposes, including fraud prevention.
  • Analytics cookies. Used to understand how visitors find and use the Service.
  • Advertising cookies. Used to serve advertisements that may be relevant to you and your interests.

4. Use of Data

CultureSafe Consulting, LLC uses the collected data for the following purposes:

  • To provide and maintain our Service
  • To respond to your inquiries and deliver the coaching, training, and consulting services you request
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis and insight so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent, and address technical issues and fraud
  • To process payments for products and services you purchase
  • To provide you with news, special offers, and general information about goods, services, and events we offer that are similar to those you have already purchased or inquired about, unless you have opted not to receive such information

We do not sell your personal data for money. Our use of advertising and analytics cookies may, however, constitute “sharing” for cross-context behavioral advertising or a “sale” as those terms are broadly defined under some U.S. state privacy laws. Section 12 explains how to opt out.

5. Legal Basis for Processing Under the GDPR

If you are in the European Economic Area (EEA) or the United Kingdom, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data concerned and the specific context in which we collect it. We may process your Personal Data because:

  • We need to perform a contract with you, or take steps at your request before entering into one
  • You have given us consent to do so, which you may withdraw at any time
  • The processing is in our legitimate interests and those interests are not overridden by your rights
  • We need to process payments
  • We need to comply with the law

6. Retention of Data

We retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

In general, we keep client engagement records for the duration of the engagement and for seven years afterward for tax, insurance, and professional-record purposes; we keep marketing contact records until you unsubscribe or ask us to delete them; and we retain Usage Data for a shorter period, except where that data is used to strengthen security or improve functionality, or where we are legally obligated to retain it longer.

7. Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those of your jurisdiction.

We are based in the United States, and our service providers process data in the United States. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Where personal data is transferred from the EEA or the United Kingdom, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses, or the EU-U.S. Data Privacy Framework where our service provider participates in it. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

8. Disclosure of Data

Business transaction

If CultureSafe Consulting, LLC is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

Disclosure for law enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities, such as a court or a government agency.

Legal requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of CultureSafe Consulting, LLC
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of users of the Service or the public
  • Protect against legal liability

9. Security of Data

The security of your data is important to us, but no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10. Do Not Track and Global Privacy Control Signals

Do Not Track (“DNT”) is a preference you can set in your web browser to inform websites that you do not want to be tracked. There is no common industry standard for how DNT signals should be honored, and our Service does not respond to DNT signals.

We do recognize the Global Privacy Control (GPC) signal. Where your browser or extension transmits a GPC signal, we treat it as a request to opt out of the sale or sharing of your personal data for targeted advertising for that browser, as required by California, Connecticut, and other state privacy laws. Because this signal is tied to the browser and device you are using, you will need to enable it on each browser and device.

11. Your Data Protection Rights Under the GDPR

If you are a resident of the European Economic Area or the United Kingdom, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you, or you want it removed from our systems, please contact us using the details in Section 17.

In certain circumstances, you have the following rights:

  • The right to access, update, or delete the information we hold on you. Where possible, you can access, update, or request deletion of your Personal Data directly within your account settings. If you cannot perform these actions yourself, contact us and we will assist you.
  • The right of rectification. You have the right to have your information corrected if it is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we hold on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. Where we rely on your consent to process your personal information, you may withdraw that consent at any time.

Please note that we may ask you to verify your identity before responding to such requests. You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, contact your local data protection authority in the EEA, or the Information Commissioner’s Office in the United Kingdom.

12. Your Rights Under U.S. State Privacy Laws

Several U.S. states, including California, Connecticut, Colorado, Virginia, Texas, and others, give residents rights over their personal data. Whether or not we meet the size thresholds that make a particular state law apply to us, we extend the following rights to all U.S. residents who contact us:

Right

What it means

Know and access

Confirm whether we process your personal data and obtain a copy of it, including the categories collected, the sources, the purposes, and the categories of third parties we disclose it to.

Correct

Ask us to fix inaccurate personal data we hold about you.

Delete

Ask us to delete the personal data we hold about you, subject to legal exceptions.

Portability

Receive your data in a portable, readily usable format where technically feasible.

Opt out

Opt out of targeted advertising, the sale or sharing of your personal data, and profiling in furtherance of decisions producing legal or similarly significant effects.

Limit sensitive data

Limit our use and disclosure of sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted without a limitation right.

Non-discrimination

Exercise these rights without receiving discriminatory treatment, denial of service, or different pricing.

Appeal

Appeal a decision we make about your request. We will respond to an appeal in writing within the period your state’s law allows, and will tell you how to contact your state attorney general if we deny it.

To exercise any of these rights, email us at [email protected] with the subject line “Privacy Rights Request.” We will verify your identity before acting on your request, and we will respond within 45 days, or tell you if we need the extension your state’s law allows. An authorized agent may submit a request on your behalf with written proof of authorization.

California “Shine the Light.” California residents may request information about disclosures of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Artificial intelligence. We do not sell personal data to, or share it with, third parties for the purpose of training large language models or other artificial intelligence systems.

13. Service Providers

We employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

Website and course platform

Kajabi. Kajabi hosts this website, our email marketing and CRM functions, and access to our digital products. Their privacy policy can be viewed at https://kajabi.com/policies/privacy.

Analytics

Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service, and this data may be shared with other Google services.

You can opt out of having your activity on the Service made available to Google Analytics by installing the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. The add-on prevents the Google Analytics JavaScript from sharing information about your visit with Google Analytics. For more information on Google’s privacy practices, visit https://policies.google.com/privacy.

Advertising and behavioral remarketing

We use remarketing services to advertise to you on third-party websites after you have visited our Service. We, and our third-party vendors, use cookies and pixels to inform, optimize, and serve ads based on your past visits to our Service.

Google Ads. You can opt out of Google’s personalized advertising and customize Google Display Network ads at https://adssettings.google.com.

Meta (Facebook and Instagram). You can learn more about interest-based advertising from Meta at https://www.facebook.com/help/164968693837950 and opt out at https://www.facebook.com/help/568137493302217. Meta’s privacy policy is available at https://www.facebook.com/privacy/policy.

LinkedIn. LinkedIn’s Insight Tag may be used to measure and target our advertising. You can manage your LinkedIn advertising preferences at https://www.linkedin.com/psettings/advertising, and read LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy.

You can also opt out of interest-based advertising from many participating companies at once through the Digital Advertising Alliance at https://optout.aboutads.info, the Digital Advertising Alliance of Canada at https://youradchoices.ca, or the European Interactive Digital Advertising Alliance at https://www.youronlinechoices.eu, or by using your mobile device settings.

Payments

We provide paid products and services within the Service. We use third-party payment processors to handle these transactions. We do not store or collect your payment card details; that information is provided directly to our payment processors, whose use of your personal information is governed by their own privacy policies. These processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, a joint effort of brands including Visa, Mastercard, American Express, and Discover.

The payment processors we work with are:

  • Stripe — https://stripe.com/privacy
  • PayPal — https://www.paypal.com/us/legalhub/privacy-full

14. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

15. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers.

16. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Updated” date at the top.

Where the changes are material, we will let you know by email or by a prominent notice on our Service before the change becomes effective. You are advised to review this Privacy Policy periodically. Changes are effective when they are posted on this page.

17. Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of the rights described above, please contact us:

  • By email: [email protected]
  • By mail: Attn: Privacy, CultureSafe Consulting, LLC, 30 Woodruff Avenue, PO Box XX, Watertown, CT, 06795, United States