Privacy Policy

Isozaki Coaching LLC ("we," "us," or "our") provides ILCI-21, including its Leadership & Culture Assessment. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access the service. Please read this policy carefully. If you do not agree with its terms, please discontinue use of the service.

This policy applies to all users of ILCI-21, including super administrators, organizational administrators, team leaders, and individual participants. It does not apply to third-party websites or services that may be linked from the Platform.

2a. Information You Provide

• Account information: name, email address, and role, provided through your authentication provider (Clerk)
• Profile information: job title, department, and biographical details you choose to complete during first-login profile setup
• Organizational information: organization name, team assignments, and hierarchy data configured by your administrator
• Assessment responses: your answers to the 21 ILCI-21 assessment items (ratings on a 1–7 agreement scale) across three domains (Self, Structure, Systems) and nine subdomains
• Leader notes: written observations or developmental notes recorded by team leaders within the Platform
• Consent records: a timestamped log of your agreement to our Terms, Privacy Policy, and Assessment Participation Consent

2b. Automatically Collected Information

• Session data and authentication tokens necessary for secure login
• Usage logs (pages visited, features accessed) for service improvement and security monitoring
• IP address and browser/device type for security and fraud prevention

2c. Information We Do Not Collect

We do not collect payment information, payment card data, or billing details. ILCI-21 does not process payments or subscriptions of any kind. We also do not collect sensitive personal characteristics such as race, ethnicity, religion, health information, biometric data, or clinical psychological profiles.

We use the information we collect to:

• Deliver and maintain ILCI-21 and its assessment services
• Compute individual, team, and organizational culture scores across three domains (Self, Structure, Systems) and nine subdomains, and generate reports interpreted through the five-band system (Flourishing, Growing, Emerging, Withering, Uprooted)
• Enable organizational administrators and team leaders to access role-appropriate dashboards, reports, and coaching recommendations
• Surface possible Isozaki Coaching service pathways based on assessment results
• Communicate service-related notices (account confirmations, policy changes)
• Detect, investigate, and prevent fraudulent or unauthorized activity
• Improve the reliability, security, and features of the Platform
• Comply with applicable legal obligations

We do not use your data for behavioral advertising, sell it to third-party data brokers, or use assessment results for any purpose outside the delivery of services to your organization.

Individual assessment responses are kept confidential. When generating team and organizational reports, responses are aggregated and, where possible, anonymized to prevent identification of any individual participant. We may also use de-identified, aggregated data for research, benchmarking, and service improvement purposes. Any such use will not allow identification of individual participants or organizations.

To protect participant anonymity, team-level reports are suppressed or deferred when fewer than three respondents have completed the assessment.

We do not sell or rent your personal information. We may share your information only in the following limited circumstances:

• Within your organization: Administrators and team leaders may access aggregated reports and dashboards within the scope of their organizational role as configured by the account administrator.
• Service providers: We use trusted third-party service providers (including cloud hosting, database, and authentication services) who process data on our behalf under confidentiality obligations consistent with this policy.
• Legal compliance: We may disclose information when required by law, court order, or governmental authority, or when we believe disclosure is necessary to protect our rights or the safety of users.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets, your information may be transferred to the successor entity subject to equivalent privacy protections.

Account and profile data is retained while your account is active. A verified account deletion request starts a 30-day grace period during which you may cancel the request. When an approved request becomes due, we erase account data, assessment responses and results, personal reports, leader notes, memberships, and authentication records linked to you.

Expired or revoked invitations are deleted after 90 days. Consent and audit/security evidence is retained for up to seven years; when account data is erased, retained audit actor identifiers are pseudonymized. Active legal holds pause deletion for the affected user or organization. Irreversibly de-identified aggregate statistics may be retained because they can no longer be linked to a person or organization.

Authenticated users can download a machine-readable copy of their data and submit or cancel an account deletion request through the Platform. Organization administrators remain responsible for organization-scoped retention decisions. For assistance, contact curtis@isozakicoaching.com.

We implement appropriate technical and organizational security measures to protect your information, including:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Role-based access controls limiting data visibility to authorized personnel
• Secure session management with short-lived authenticated tokens
• Regular security reviews and monitoring of access logs

No method of electronic transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you and your organization administrator as required by applicable law.

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal and contractual obligations
• Portability: Request your data in a portable, machine-readable format
• Objection: Object to certain processing activities, including use of your data for analytical purposes
• Withdrawal of consent: Withdraw your consent to assessment participation at any time (this does not affect the lawfulness of processing before withdrawal)

Authenticated users may export their data, record a consent withdrawal, and submit or cancel a deletion request through the Platform. Requests are reviewed before deletion, may be paused by a legal hold or other legal obligation, and do not remove previously created irreversibly de-identified aggregate statistics. You may also contact your organization's account administrator or reach out directly to curtis@isozakicoaching.com.

The Platform uses session cookies strictly necessary for authentication and maintaining your logged-in state. We do not use third-party advertising cookies, tracking pixels, or behavioral analytics tools. Session cookies are deleted when you log out or close your browser.

ILCI-21 is intended for use by working professionals within organizational contexts. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly.

ILCI-21 surfaces references to coaching frameworks and methodologies (e.g., MBTI, Enneagram, CliftonStrengths, Working Genius, LEGO® Serious Play®, OCAI) as contextual references within service recommendations. Isozaki Coaching LLC does not administer, reproduce, or replace these third-party instruments. No third-party framework data is collected or processed through this Platform. See our Trademark & IP Disclaimer for the complete list of referenced frameworks and non-affiliation statements.

We may update this Privacy Policy from time to time. Material changes will be communicated via email to the organization's account administrator and/or through a notice on the Platform at least 14 days before the effective date. Your continued use of the Platform after the effective date of the revised policy constitutes acceptance of the changes.

For privacy inquiries, data subject requests, or questions about this policy, please contact: