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Kinetry Privacy Policy

Effective: July 20, 2026

This policy describes how Kalgren Consulting LLC, doing business as Kinetry ("Kinetry," "Company," "we," or "us"), collects, uses, discloses, retains, handles and protects personal information in connection with the Kinetry service. It is a companion to our Terms of Service. This Privacy Policy applies to visitors to the website, customers who use this Service, employees, contractors or other individuals who voluntarily participate in employer or work-related workplace development coaching type programs or any other visitor to this Site. This Privacy Policy works in conjunction with any master service agreement between Company and any employer or other customers.

The Services provide employers or other entities with behavior-based coaching, workplace culture assessments, workplace surveys, professional development insights, and related analytics. Through the Services, employees (or other authorized participants) may voluntarily provide information regarding workplace behaviors, preferences, experiences, skills, goals, and professional development opportunities. We use technology, including artificial intelligence ("AI") tools, to analyze submitted information and generate coaching insights, skill-gap analyses, and recommendations designed to support workplace development.

1. The two roles we play

  • For Customer workspace data (rosters, assessment responses, scores, notes): the Customer organization decides whether to offer this Service, which workers may participate, what surveys, assessments, or coaching activities are offered and what related data is collected and why; Kinetry processes it on the Customer's behalf to provide the Service. Individuals should direct questions about their organization's use of Kinetry — including access or deletion requests about assessment data — to their employer or entity with whom they work. The Customer acts as the business, controller or other similar decision-making entity under applicable privacy laws with regard to participant provided information and what to do with such information. Kinetry is the service provider, and processes such information according to the Customer's instructions and applicable agreements.
  • For account and site data (sign-in email, acceptance records, support messages, service logs): Kinetry determines the purposes and is responsible directly.

2. What we collect

Customers may provide to Company information about participants such as: your organization (name, work email, role, manager); business contact information; department or team information; job related duties or other job related information; participation status; administrative information necessary to operate the Services; any assessment responses and notes submitted by raters; computed scores and AI-generated coaching content; sign-in and usage records (timestamps, IP address, device/browser type); Terms-acceptance records (who accepted which version, when); and support communications.

Further, employee or participant participation is at the direction of the Customer and is voluntary unless otherwise directed by the Customer. Before participating, the Customer should provide to participants:

  • The purpose of the survey or assessment;
  • The type of information sought;
  • How the responses may be analyzed;
  • Whether individual, identifiable information may be available within the Customer organization and to whom;
  • How AI technology is to be or could be used;
  • Any privacy rights available to participants.

Before participating, participants must acknowledge and agree that:

  • their responses will be processed through the Services;
  • AI-based analysis is an integral component of the Services;
  • submitted information may be analyzed to generate coaching insights and recommendations;
  • the Customer may have access to individual-level results depending on the Customer configuration and applicable agreements.

Participants who do not wish to have their information processed through the Services must decline participation or discontinue participation as permitted by the Customer's program configuration. Because AI analysis is an essential feature of the Services, participants who submit responses cannot separately opt out of AI processing while continuing to use the Services.

Participants may be asked to voluntarily provide information about their work and skill sets to allow Services to be completed. Such information may include:

  • survey responses;
  • workplace experiences;
  • behavioral preferences;
  • communication styles;
  • professional goals;
  • perceived strengths;
  • development opportunities;
  • skills assessments;
  • coaching inputs;
  • feedback responses.

Participants should avoid submitting information that is unrelated to the purpose of the Services, including sensitive personal information unless specifically requested and authorized by the employer or entity with whom they work. At no time should participants provide any financial account information, religious beliefs, political opinions, union membership or affiliations, or health related or health identifying information including disability information, genetic information, biometric information, or information concerning sexual orientation or sexual activity.

Kinetry, through its systems, may automatically collect information when individuals access or use the Services including:

  • IP address;
  • browser type;
  • device information;
  • operating system;
  • usage activity;
  • log information;
  • authentication information;
  • cookies and similar technologies.

Note: Kinetry does not collect payment card numbers (payments are processed by our payment provider) and does not intentionally collect data about minors.

3. Customer Access/Use of Information

What a Customer may access depends on its assessment mode, its configuration, and its agreements with Company.

  • In multi-rater (360) mode: Customers may access individual participant results (scores and participant-level coaching insights), aggregated organizational reports, benchmarking information, skill-gap analyses, and coaching recommendations. Customers do not have access to the individual assessment responses another rater submits: responses are confidential to the rater, results are computed from combined ratings, and statistical suppression hides results computed from fewer than the minimum number of raters, as described in our Terms of Service.
  • In advisor (single-assessor) mode: the Customer's designated advisor authors the assessments, so the advisor and the Customer's administrators may access individual assessment entries and observation notes together with the computed results, participant-level coaching insights, aggregated organizational reports, benchmarking information, skill-gap analyses, and coaching recommendations.

Customers are responsible for determining appropriate access controls, providing appropriate notices and consents to participants, establishing lawful purposes for processing and using participant information, determining who in their organization may appropriately access participant information, and creating and maintaining appropriate security safeguards and confidentiality to ensure that Customer use of participant information complies with applicable laws.

4. How Kinetry uses information

We use information collected to operate the Services (collect assessments, compute scores, generate coaching content, deliver reports); to secure it (authentication, abuse prevention, logging); to support you; to send service emails (sign-in links, cycle notifications, results — not marketing without consent); and to create aggregated, de-identified statistics that cannot reasonably identify any person or organization, which we use for cross-customer benchmarks, service improvement, and research, as permitted by our Terms of Service. We do not use identifiable participant information for any purpose other than to provide Services, nor do we use individual survey responses or other confidential information to train large language models or general-purpose AI models. We may use aggregated or appropriately de-identified information to improve the Services, develop analytic capabilities, improve system performance and enhance user experiences.

Should Company use third-party service providers to assist with operating, maintaining, securing or improving the Services, information may be disclosed to vendors who provide services such as:

  • cloud hosting;
  • database services;
  • cybersecurity services;
  • authentication services;
  • analytics services;
  • customer support services;
  • AI infrastructure services;
  • communications services.

Company requires vendors to agree to:

  • process information only for authorized purposes;
  • maintain appropriate confidentiality obligations;
  • implement reasonable security measures;
  • comply with applicable privacy requirements.

Company will not authorize service providers to sell personal information or use personal information for independent advertising purposes.

We may also be legally required to disclose personal information processed as a part of the Services to comply with applicable laws, in response to lawful governmental requests, to investigate fraud or other security incidents, or to protect individuals or the public from a reasonable threat. We may also use such information as a part of a corporate transaction, and any successor organization will be required to also maintain appropriate protections for such personal information.

5. What we don't do

We do not sell personal information. We do not use Customer workspace data to advertise to anyone. We do not make automated employment decisions — the Services are a development tool, and our Terms prohibit Customers from using it as the sole basis for employment decisions.

6. Who can see assessment data

Visibility follows the Customer's configuration and roles as they determine best (for example, managers see their team's results; executives see organization-level results). Your organization's administrators control these roles and org structure, may grant specific people broader visibility, and may temporarily view the service as one of their own Authorized Users (read-only) to provide support and verify access — a "view as" action is recorded. Statistical suppression hides scores computed from fewer than the minimum number of raters. Authorized Kinetry personnel — including Kinetry's principal consultant — can access workspace data to operate, support, and improve the service and to deliver contracted advisory services, under confidentiality obligations. Service providers (hosting, email delivery, payments) process data for us under contract. We disclose data if required by law, with notice to the Customer where lawful and practicable.

7. Security

Except as otherwise provided in this Policy, Company agrees to: encrypt data in transit; use single-use, expiring sign-in links (no passwords stored); enforce role- and tenant-scoped access on every data path; protect scoring internals server-side; and limit access to personnel who need it. No system is perfectly secure; we will notify affected Customers of a breach as required by law.

8. Retention and deletion

Workspace data is retained while the Customer's account is active and for the export window after termination described in the Terms, then deleted from production systems within a commercially reasonable period. Aggregated, de-identified data may be retained thereafter. Acceptance and billing records are kept as long as required for legal purposes.

How this works in practice:

  • Export. Workspace administrators can download the workspace's complete data and results at any time (Admin → Company settings → Export workspace data), and a per-person export for any individual (Admin → People → Export data). Exports respect the rater-confidentiality protections described in the Terms — in multi-rater mode they never include assessment responses authored by other raters, and a person's own raw self-assessment entries are included only when that person downloads the export themselves.
  • Person deletion. Workspace administrators can permanently erase a removed person and everything recorded about them (Admin → People → Erase permanently). Erasure is immediate in production systems and cannot be undone. Because re-scoring a past cycle from the remaining responses could expose individual assessors, past cycles in which the erased person assessed others are locked and their already-published results stand as-is; other results may later be recalculated without the erased person's data.
  • Workspace deletion. Customers can request deletion of their entire workspace by contacting privacy@kinetry.ai; we perform it after any active subscription is cancelled.
  • Residual copies. Erased data may persist briefly in encrypted database backups (which age out within about 30 days) and in our error-tracking service (up to 90 days). A minimal record that an erasure was performed — who was erased, when, and the terms-acceptance evidence noted above — is retained for legal purposes.

9. Your Choices; Do Not Sell or Share; How to Opt Out

We do not sell or share your personal information. Kinetry does not sell personal information for money or other valuable consideration, and does not share personal information for cross-context behavioral advertising (sometimes called "targeted advertising"), as those terms are used under the California Consumer Privacy Act (CCPA/CPRA) and similar state laws. We set no advertising or marketing trackers and use no third-party advertising cookies or ad pixels, so there is no sale or sharing of your personal information to opt out of. Because we do not sell or share, we do not display a "Do Not Sell or Share My Personal Information" opt-out link. If that ever changes, we will provide such a link and will honor opt-out preference signals — including the Global Privacy Control (GPC) browser signal — as required by applicable law.

Cookies and analytics. The Service uses only strictly necessary and diagnostic technologies, plus a single first-party analytics cookie that records how a visitor first reached our site (and, if enabled, privacy-friendly cookieless analytics). These are described in our Cookie Policy, and you can view, block, or delete cookies through your browser settings at any time.

Service and marketing email. We send transactional and service email (sign-in links, cycle and results notifications, billing receipts). We do not send marketing email without consent; any marketing email we do send includes an unsubscribe control you can use at any time.

Exercising your rights. Individuals: for questions or requests about assessment data held in your organization's workspace, contact your organization's administrator, because Kinetry processes that data on the Customer's behalf; for questions or requests about account or site data, contact us at privacy@kinetry.ai. Applicable state-law rights — such as access, correction, deletion, and, where applicable, opt-out of sale or sharing — will be honored as required by law, routed through the Customer where Kinetry acts on the Customer's behalf. We will not discriminate against you for exercising your privacy rights.

10. Children

The Services are not directed to children under the age of 16. Company does not knowingly collect, nor does it authorize the collection of, information of minors, and will work to delete any such information if it becomes aware of the same.

11. Cookies and Similar Technologies

Company uses cookies and similar technologies only to operate the Services:

  • a session cookie that keeps you signed in (authentication);
  • a cookie recording acceptance of the Terms;
  • an error-tracking service that receives technical error reports from the browser so failures can be found and fixed;
  • a bot-protection challenge on the signup page;
  • privacy-focused, cookieless page analytics, if enabled.

Company does not use advertising or marketing trackers, tracking pixels, or web beacons. Users may control cookies through browser settings or available preference tools; because sign-in relies on a session cookie, disabling cookies will affect core functionality.

12. California Privacy Rights

This section applies to California residents where applicable under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA").

Categories of Personal Information. Depending on how individuals interact with the Services, Company may collect categories including:

  • identifiers;
  • professional or employment-related information;
  • internet or network activity;
  • characteristics or preferences voluntarily provided through surveys;
  • professional development information;
  • inferences generated through analysis;
  • audio, electronic, or similar information where applicable.

Purposes of Collection. Company collects and uses personal information for:

  • providing Services;
  • processing Customer-sponsored assessments;
  • generating coaching insights;
  • maintaining security;
  • improving Services;
  • complying with legal obligations.

California residents may have the right to:

  • request access to personal information;
  • request correction;
  • request deletion;
  • request information about collection and disclosure;
  • opt out of sale or sharing of personal information;
  • limit certain uses of sensitive personal information.

Company does not sell personal information and does not share personal information for cross-context behavioral advertising.

13. Colorado Privacy Rights and Artificial Intelligence Notice

Company recognizes Colorado's heightened requirements concerning privacy, profiling, and artificial intelligence. The Services use AI technologies to analyze participant-provided information and generate coaching-related recommendations. Company does not use AI to make decisions producing legal or similarly significant effects concerning individuals.

AI-generated outputs:

  • are informational;
  • are subject to human judgment;
  • are not employment decisions;
  • are not intended to replace human decision-making.

Customers remain responsible for evaluating and appropriately using any insights generated through the Services.

14. Changes to This Privacy Policy

Company may update this Privacy Policy periodically. Changes may be made to reflect:

  • changes in Services;
  • legal requirements;
  • technology changes;
  • business practices.

Material changes will be communicated in-product, by email, or through other appropriate channels.

Contact: privacy@kinetry.ai · Kalgren Consulting LLC (d/b/a Kinetry), Minnesota, USA

Kinetry uses only essential and privacy-friendly cookies — no advertising or cross-site trackers — and does not sell or share your personal information. See our Cookie Policy and Privacy Policy.