Privacy policy

1. Who we are

EmpacITy is the learning and development brand of Human Performance Research, an international practice designing leadership, coaching and experiential learning programs for organizations. We operate from New York (headquarters), London, Vancouver and Bucharest. Using this website or contacting us means you accept the terms of this policy.

2. What we collect

We keep data collection to the minimum needed to answer you and run an engagement.

• →Enquiry data: name, work email, company, role, team size and the message you send through the contact form.
• →Engagement data: participant lists, scheduling details and program feedback provided by our client organizations.
• →Assessment and coaching notes created during a program.
• →Technical data: IP address, browser type, device and pages visited, collected in aggregate for site performance and security.

3. Why we use it

We process personal data to respond to enquiries, scope proposals, deliver and evaluate programs, meet contractual and legal obligations, keep the site secure, and send service updates to people who asked for them. We do not sell personal data and we do not run advertising or profiling trackers.

4. Confidentiality of coaching and assessment data

Individual coaching conversations and assessment results are confidential to the participant. Sponsors and HR receive aggregated themes and movement across a cohort — never attributed quotes or individual scores — unless the participant gives explicit written consent. Coaches work to ICF ethical standards.

5. Cookies and analytics

The site uses only the cookies required to serve pages securely, plus privacy-respecting, anonymised usage measurement. No advertising cookies are set, and no personal profile is built. You can block or delete cookies in your browser at any time without losing access to the site.

6. Embedded and third-party content

Some pages may embed third-party content such as video players or scheduling tools. Those providers can set their own cookies and collect usage data under their own policies once you interact with the embedded content. Links to third-party websites are provided for convenience; we do not control or audit their privacy practices.

7. Service providers

We share personal data only with vetted providers that help us operate: website hosting and content delivery, email delivery for form submissions, scheduling, and secure document storage. Each is bound by a data processing agreement and may use data only on our instructions. We never disclose your data to third parties for their own marketing.

8. International transfers

Because we operate across the United States, the United Kingdom, Canada and the European Union, personal data may be processed in any of those locations. Transfers are covered by appropriate safeguards, including standard contractual clauses where required.

9. How long we keep data

Enquiry data is kept for up to 24 months from the last contact. Engagement records are kept for the duration of the contract plus the retention period required by applicable law and professional standards. Coaching notes are destroyed within 12 months of the engagement closing unless the participant asks otherwise.

10. Security

The site is served over HTTPS. Access to client and participant data is limited to the people delivering the engagement, protected by strong authentication. If a breach affects your data, we act immediately to contain it and notify affected individuals and regulators as required.

11. Your rights

You can request access to, a copy of, correction of, or deletion of your personal data, restrict or object to processing, and withdraw consent at any time. Where GDPR, UK GDPR, PIPEDA or comparable state privacy laws apply, we honour those rights for everyone, wherever they live. Send requests through the contact form and we will respond within 30 days. You also have the right to complain to your local data protection authority.

12. Children

This is a business-to-business service. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us data, contact us and we will delete it.

13. Changes and contact

We update this policy when our practices or the law change; the date below reflects the current version. For any privacy question or request, use the contact form on this site and mark your message 'Privacy'.