Persona 28 MicroSim Privacy Policy

1. Who we are

Persona 28 LLC, an Indiana limited liability company ("Persona 28", "we", "us"), provides executive and leadership development experiences. The Persona 28 MicroSim is a short simulated leadership conversation that produces a personalized Leadership Snapshot.

In this policy, "Persona 28" means Persona 28 LLC.

2. What this policy covers

This policy covers the Persona 28 MicroSim: the simulation experience itself, the Leadership Snapshot prepared from it, and the communications we use to deliver that snapshot to you.

It does not cover other Persona 28 products or websites, or the practices of any third party whose site you reach through a link from ours.

The MicroSim is currently offered as a pilot. This policy describes how it works today. If we change what we collect or how we use it, we will update this policy and its version identifier.

3. Information you provide

The MicroSim asks for very little, and asks for it at the end rather than the beginning:

• Your name, requested after the simulation. We use it to personalize your

Leadership Snapshot — it appears on the report as "Prepared for". We store the name you provide, subject to basic formatting and validation. We do not derive your name from your email address.

• Your email address, requested at the same time. We use it to send you your

Leadership Snapshot and to reach you about it if needed.

• What you write during the simulation. Your messages are the substance of the

experience and are saved.

We do not ask for your company, job title, phone number, date of birth, or any other profile information, and the MicroSim has no field to enter them. There is no account and no password.

4. Information generated when you use the MicroSim

Using the MicroSim also generates:

• Session records — when your session started, ended, or expired, how far you

got, and which version of the simulation you saw.

• Analysis records — information produced when we analyze your responses, as

described in section 5.

• Your Leadership Snapshot, in the form shown to you on the web and in the PDF.
• Delivery records — whether your snapshot email was sent, when, and what our

email provider reported back.

• Access records — information used to control and, if needed, revoke access

to your personal result link.

• Service-protection information, described in section 8.

5. How your responses are analyzed

After you finish the simulation, Persona 28 analyzes your responses using AI systems and its leadership framework to identify behaviors demonstrated in the simulation and generate your Leadership Snapshot.

Three things about that analysis are worth stating plainly:

• Short quotations of your own words may appear in your snapshot, presented as

things you said during the simulation.

• We may retain information generated during this analysis to operate the

service and to evaluate the quality, consistency, reliability, and performance of the MicroSim.

• Analysis records stay associated with your session, and your session carries

your name and email address. Participant-level records are not anonymous or de-identified, and we do not describe them as though they were. See section 7.

6. How AI is used

Persona 28 uses AI systems to operate the simulated interaction, analyze responses, and help generate leadership-development feedback.

In practice that means:

• The executive you speak with is AI. There is no person on the other side of

the conversation. We tell you this before you begin.

• Your responses are processed by AI systems as part of preparing your

Leadership Snapshot.

• AI-assisted analysis contributes to the content of your snapshot.

AI-generated analysis has limitations and may not capture every aspect of your behavior or interpret every response the same way a human reviewer would.

What your Leadership Snapshot is: an informational leadership-development snapshot describing behavior observed in one short simulated conversation.

What it is not: it is not a comprehensive assessment of your leadership; it is not a psychological, clinical, or diagnostic evaluation; it is not a prediction of your future performance; and it is not an automated hiring, promotion, or other employment decision. Persona 28 does not make employment decisions about you through the MicroSim. Our Terms of Use say more about appropriate use.

7. How we use information

We use the information described above to:

• provide the MicroSim and keep your session working;
• analyze your responses and generate your Leadership Snapshot;
• personalize the snapshot with your name;
• deliver the snapshot to you and give you a personal link to view and download it;
• keep the service working and diagnose problems;
• protect the service and our participants from abuse and misuse;
• meet our legal and regulatory obligations.

Internal use of participant-level information. We may use participant responses and information generated from the simulation internally to operate, evaluate, test, validate, secure, research, and improve the MicroSim and related Persona 28 leadership-development and assessment technology.

Those internal purposes include:

• providing and operating the MicroSim;
• quality assurance, including reviewing the quality of the reports we produce;
• troubleshooting, and detecting and diagnosing technical failures;
• evaluating the consistency and reliability of our analysis;
• validation, research, and evaluation work;
• safety and security;
• developing and improving the MicroSim and related Persona 28

leadership-development and assessment technology.

For those purposes, this may include internal review of your simulation responses, the results of the analysis, the information supporting an observation, the content of the report prepared for you, and the technical and quality information associated with your session.

This work uses participant-level information, including information that identifies you, where that is necessary for the purpose. We describe it plainly here rather than implying that we only ever look at anonymized data.

Aggregate and de-identified information. We may also create and use aggregate or de-identified information for research, analysis, validation, evaluating and improving the product, assessing its reliability and performance, and describing how the product performs or is used.

These are two different things, and we want to be precise about the difference: the underlying participant-level records described in sections 3, 4, and 5 are not de-identified simply because aggregate or de-identified outputs can be derived from them.

What we do not do. We do not sell your personal information. We do not use it for advertising or share it with advertisers. We do not use it for purposes unrelated to those described in this policy.

8. Service protection

The MicroSim processes limited network information in order to protect the service from automated abuse and excessive use.

We do not use that information for advertising, for cross-site tracking, or to build a profile of you, and the application does not store your raw network address in your participant record.

The MicroSim does not use advertising cookies, tracking pixels, third-party analytics, or session-replay tools. It sets one cookie of its own, which exists to keep your session working while you use it.

Our service providers keep their own operational records, which may include network information, under their own practices. See section 9.

9. Service providers

We use a small number of service providers to operate the MicroSim. They receive only what they need to perform their function, and only for that purpose.

Your name and email address are collected after the simulation and are not sent to our AI processing provider.

10. Security and access to your result

We take reasonable measures to protect information in our care.

Access to your Leadership Snapshot is controlled by a personal link that is designed to restrict access to the person it was issued to, and that expires. We can revoke a link if needed.

Your email address is a delivery destination, not a credential. Knowing an email address does not give anyone access to a result.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. How long we keep information

We retain information for as long as reasonably necessary for the purposes described in this policy, including operating and improving the MicroSim, meeting our legitimate business and operational needs, resolving disputes, and complying with applicable legal requirements. Retention periods may vary depending on the type of information and the purpose for which it is held.

We have not set a fixed retention period specific to the MicroSim pilot.

Where we no longer have a need to retain information, we take steps to delete it or render it no longer associated with you.

12. Your choices

• Taking part is voluntary.
• You choose what you write. Please do not include information you would not

want analyzed and stored — including confidential information belonging to your employer or others, or sensitive personal information about yourself or anyone else. The simulation does not ask for any of it and does not need it.

• Your name and email are requested after the simulation, and are used to

prepare and send your snapshot.

• Result links expire, and we can revoke one on request.

13. Privacy rights and requests

Depending on where you live, you may have rights regarding your personal information — such as the right to request access to it, correction of it, or deletion of it. Where such rights apply to you, you may contact us at privacy@persona28.com and we will respond as required by applicable law. We may need to verify your identity before acting on a request, and some information may be retained where we are permitted or required to retain it.

What is operationally supportable today: our systems allow the information relating to a participant's session — including the responses, the analysis records, the snapshot, the name, the email address, and the delivery record — to be deleted together. We have not published a request process or a response time, and this draft does not promise either.

14. Who can take part

The MicroSim is intended for working professionals age 18 or older, and is not directed to children. We do not knowingly collect information from anyone under 18.

15. Where the MicroSim is offered

The current MicroSim pilot is offered to participants in the United States.

If we later offer the MicroSim in other countries, we will update this policy and any disclosures that apply.

16. Changes and contact

We may update this policy. When we do, we will change the effective date at the top and the version identifier below. Where a change is material, we will take reasonable steps to bring it to the attention of participants.

Privacy questions and requests. For anything about this policy, about how your information is handled, or to make a privacy request where one applies to you, contact Persona 28 LLC at privacy@persona28.com.

For anything else, the general Persona 28 contact page is at https://www.persona28.com/contact.

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