Privacy Policy

Effective Date: April 10, 2025

Overview

Performio is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of all individuals who interact with us as well as those whose personal data has been shared with us by third parties.

We have therefore developed this Global Privacy Notice (Privacy Notice) to describe how we, PerformanceCentre, Inc. and the Performio group companies (referred to as “Performio,” “we,” “our,” or “us”), collect, use, share or otherwise process your personal information. This Privacy Notice applies to information that we collect and use when you visit our websites, (each a “Site”), when you interact with the features of our Site, when you interact with us through our email, advertising, or social media campaigns or when you use our services (“Services”).

This Privacy Notice is global, meaning it applies to all Performio Services. We highlight where information is specific to a jurisdiction and may provide additional or supplemental privacy information for certain products or services. For example, we provide specific privacy notices to employees or job applicants when they apply to work with us.

Performio determines the purposes and means of the processing of your personal information as described in this Privacy Notice and is therefore defined as a data controller (or equivalent terms under applicable data privacy laws) for personal information in scope of this notice.

The Privacy Notice does not apply to personal information processed, stored or hosted by our customers using Performio Services. Individuals should refer to our customers’ privacy notices (sometimes referred to as a “Privacy Policy” or “Privacy Statement”) in such instances. We enter into data processing agreements with our customers which identify how we manage personal information on their behalf.

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal information from individuals under 16. If we learn that we have collected personal information from individuals under the age of 16, we will delete that information.

If you have any questions about how Performio processes your personal information, please see the Contact Us section below.

This notice is intended to help you understand:

How We Collect Personal Information

What Personal Information We Collect

How We Use Personal Information

How We Share Personal Information

Where We Process Personal Information

Additional Jurisdiction Specific Information

How We Protect Personal Information

How Long We Retain Personal Information

Your Choices

Changes to This Notice

Contact Us

2.0 How We Collect Personal Information

We collect personal information as follows:

• Information that is collected automatically: about your interaction with the Site or Service through automatic tracking technologies (e.g., cookies) that may or may not personally identify you (this information may be combined with information that does personally identify you). This includes information like IP address, Internet connection, network activity, the device or equipment you use, geolocation, your activity or interaction with the Site or Service, our social media accounts, email marketing campaigns, or marketing materials; 
• Information that you provide us: when you fill out forms or questionnaires, respond to surveys, provide comments, respond to our emails, or interact with our marketing campaigns;
• Information from third parties: like third party marketing and analytics tools. This may include name, email address, profile picture, demographic data, or other unique identifiers as well as information relating to your interaction with the third-party website or service

Like many websites, we use “cookies,” pixels, or other automatic tracking technologies to collect information. Cookies are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your computer’s hard drive. Through cookies or similar tracking technologies, we collect usage information like activity data, IP address, the website you came from before visiting the Site or Services, browser type and setting, time/date, language preferences, and device information (device ID, unique device identifiers, crash data).You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being set. Most Internet browsers will allow you to block cookies from being stored on your computer and to delete cookies stored on your computer, and we will honor these browser settings. However, if you choose to eliminate cookies, the functionality of the Site or Services may be impaired.

3.0 What Personal Information We Collect

We only collect, or otherwise receive, personal information that we know we will genuinely use and can justify processing under applicable data privacy laws.

The types of personal information we collect will further depend on your interactions with us, your account configurations, and the choices you make. The way we process your personal information may depend on the Services you use and applicable data privacy laws. 

We may collect the following types of data:

• Identifiers: This could include name(s), email address, unique identifier, online identifier, transaction identifiers, device ID, advertising ID, and IP address
• Commercial Information: Business contact information (such as job title, employer name, email address, mailing address, phone number), products or services purchased or considered, and other purchasing or consuming histories
• Communications Data: The content of any communications you have with us, which could include your experiences, opinions, feedback, complaints or reviews on our products and services, as well as any audio or video recordings
• Geolocation: Course IP address
• Transaction Information: Information collected about the transactions you make (such as transaction date, payment information, credit card or debit card number and zip code)
• Online Activity: Browsing history, search history, and information regarding a consumer’s interaction with website, application, or advertisement.

Where possible, we prohibit our customers from inputting sensitive information into our Services, however, our customers ultimately determine the personal information that is processed by our Services.

In most instances, you are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we will often require elements of the information above in order to provide our services to you in an efficient and effective manner.

3.1 Targeted Advertising

We display content, offers, or advertisements that may be of interest to our users on the Site, or other digital properties or applications. We use inferences, identifiers, and demographic data to identify segments of similar users. We will provide content or advertising that may interest individuals we identify to be similar to that segment based on our Inferences. Advertisements are targeted based on information that we collect directly or that we receive from third parties (like ad networks, ad servers, or through third party affiliate marketing programs, we call these “Advertising Partners”). If we match you to a particular segment, we may provide offers, deals, content, or advertising that may be of interest to that segment, including you, and we may allow our advertising partners to better target their advertisements to that segment, including you (“Cross-Contextual Behavioral Advertising”). We, the third-party businesses we interact with, and our third-party service providers use the information we collect for the purposes disclosed above, but primarily to identify you and to serve relevant advertising or content to you, to analyze performance of advertisements and content, to analyze usage trends, and to target offers, promotions, deals, or content to you on the Site and elsewhere online.

We and our Advertising Partners use Automatic Tracking Technology to collect information from you and to identify you. We will receive your information from third parties when you click through an advertisement or promotion on the Site, or when you click on an affiliate link in our content or purchase a product from an affiliate link. If you purchase product or service from an affiliate, we do not receive credit card information, or the specific items purchased.

We are not responsible for the privacy practices of any of our Advertising Partners, and we encourage you to read their privacy policies so that you understand how they process information about you.

4.0 How We Use Personal Information

We may use your personal information in accordance with the table below. The lawful basis column may vary depending on your jurisdiction.

4.1 Anonymized data

In addition, we may create anonymous or aggregated data from your personal information and other individuals whose personal information we collect. We do this by excluding information that makes the data personally identifiable to you and use that anonymous data for analytical and research purposes.

5.0 How We Share Personal Information

We may share personal information with the following categories of third parties, subject to written agreements:

• Service Providers: With service providers (e.g., data analytics, marketing, cloud storage, software development, infrastructure, information security, support, billing, or other service providers);
• Business Partners: With business partners for business purposes, such as referral partners and reseller partners;
• Social Media and Marketing Service Providers: With third parties like analytics providers (e.g., Google Tag Manager and Google Analytics) or social media for marketing and promotional purposes;
• Analytics and Advertising Partners: With third party marketing tools, like email campaign providers or social media platform providers.
• Professional Service Providers: With legal, accounting, and other professional service providers;
• Affiliated Entities: With our affiliated entities;
• Legal Authorities: With legal authorities or third parties if we deem necessary to enforce our rights, or the rights of third parties (including in connection with your breach of this Privacy Notice or any other agreement between us), or when required by any applicable law, rule regulation, subpoena, or other legal process, or in order to prevent illegal, harmful, fraudulent, or damaging activities;
• Corporate Transactions: In connection with the negotiation or execution of a merger or sale of our business; or

• Other Parties: We may share your information with certain, specified third parties with your consent.

Where such parties are deemed “processors” (or equivalent under applicable privacy laws), we only share your personal information in instances where they have provided sufficient guarantees that they will process your data securely and in accordance with applicable privacy laws. Such service providers are not legally permitted to do anything with your personal information unless we have instructed them to do it. We have written agreements/terms in place to ensure that they will not share your personal information with any organization apart from us or further sub-processors, which must process your personal information to the same high standards.

6.0 Where We Process Personal Information

If you use our Services outside of the United States, we may collect, process, and store your information in the United States and other countries where Performio or its affiliates, subsidiaries, or service providers operate facilities in accordance with what is permitted by applicable laws and regulations.

While some of these countries may have data protection laws that are different from the laws of your jurisdiction (and, in some cases, may not be as protective), when we transfer, store or process personal information outside of your jurisdiction (including to or in the US), we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Notice and applicable law.

Some of these recipients of your personal information are located in countries for which the EU, Swiss and UK regulators have issued adequacy decisions, which means that these countries are recognized as providing an adequate level of data protection under applicable laws.

Where recipients of your personal information are located in countries outside the EEA and/or the UK that are not the subject of an adequacy decision, but where EU/UK/Swiss law applies, we will use the Standard Contractual Clauses approved by the European Commission and/or, the International Data Transfer Agreement/UK addendum approved by the UK regulator, to help ensure your personal information is protected. For more information on the transfer safeguards we rely on, please contact us by using privacy@performio.co.

7.0 Additional Jurisdiction Specific Information

This Privacy Notice has been written to apply to all jurisdictions in which Performio operates, however, in this section, we provide additional information to outline compliance in certain jurisdictions.

7.1 Australia

Performio AUS Pty Ltd

Level 40
80 Market Street
South Melbourne,
Victoria,
3205.
Australia

If you are a resident of Australia, you may have the following rights and choices:

• Update your privacy settings or preferences. Should you have an account with us, you may update your privacy settings by visiting your account settings. Alternatively you can contact us using the details in this notice
• Manage marketing communications from us. To update your marketing communication preferences, you can edit your subscriptions by following the relevant links included in each of our communications. Alternatively you can contact us using the details in this notice.
• Access, Correction or Deletion. You may request to access, to correct or to delete your personal information. You can edit and correct your personal information at any time by changing it directly in our products and services. To make a request for access or deletion of your personal information, contact us using the details in this notice.
• Objection and Restriction. You may object to our processing of your personal information, including for marketing purposes, or ask us to restrict processing of your personal information. If you request that we stop processing some or all of your personal information or you withdraw (where applicable) your consent for our use or disclosure of your personal information for purposes set out in this privacy notice, we might not be able to provide you all of the Services and customer support offered to our users and authorized under this Privacy Notice.

For its entity and operations in Australia, Performio must abide by the Privacy Act and the Australian Privacy Principles (APP) as summarized below.

7.2 EEA, UK and Switzerland Data Privacy Rights

If you are a resident of the EEA, the UK, or Switzerland, you are entitled to certain rights. These rights include:

• Right of access and/or portability: You have the right to access any personal information that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
• Right of erasure: In certain circumstances, you have the right to the erasure of personal information that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal information, and/or stop sending you marketing communications.
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal information.
• Right to restrict processing: You have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).
• Right to complain: You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information. You can find EEA data protection regulators here, the UK regulator here and the Swiss regulator here.

To submit a request to exercise your rights, please contact us at privacy@performio.co. If you submit a request related to the Services, we will direct you to submit a request to exercise your rights directly with our customer. We may have a reason under the law why we do not have to comply with your request or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

We process personal information, or “Personal Data” as that term is defined in the EU General Data Protection Regulation, on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; (3) as necessary for our legitimate interests where those interests do not override your fundamental rights and freedom related to data privacy; and (4) as necessary for compliance with our legal obligations.

Please see section 12.1 and 12.2 for details on how to contact our UK/EU representatives.

7.3 India

Performio India Pty Ltd

7/1 Halasuru Rd
Halasuru
Hermit Colony,
Sivanchetti Gardens,
Bengaluru,
Karnataka 560042,
India

Where data of Indian individuals are involved, the “reasonable security practices and procedures” under section 43A Explanation (ii) of the Information Technology Act, 2000 means this Performio Global Privacy Notice and such data security procedures that Performio may implement from time to time and which may, in Performio’s discretion, be informed to you from time to time.

Should Indian Data Protection Legislation apply to the processing of your personal information, the lawful bases for processing your data will be consent, except where:

• We process your information for the specified purposes for which you voluntarily provide the information, and you have not indicated denial of consent for such processing;
• We need to process you information to comply with orders or judgments, either under any Indian law, or under any foreign law when relating to claims of a contractual or civil nature;

If you are a resident of India, you may have the following rights and choices:

• Update your privacy settings or preferences. Should you have an account with us, you may update your privacy settings by visiting your account settings. Alternatively you can contact us using the details in this notice.
• Manage marketing communications from us. To update your marketing communication preferences, you can edit your subscriptions by following the relevant links included in each of our communications. Alternatively you can contact us using the details in this notice.
• Correct your personal information. You can edit and correct your personal information at any time by changing it directly in our products and services. Alternatively you can contact us using the details in this notice.

7.4 US

PerformanceCentre, Inc. 

8605 Santa Monica Blvd
PMB 52242
West Hollywood, California 90069-4109 US

If you are a resident of California, Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, or any other state that has passed data protection legislation, you may have additional rights regarding our use of your personal information. The rights outlined in this section do not apply to information exempted under applicable state privacy law. Further, the rights described in this Section are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. 

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at privacy@performio.co.

To the extent you are provided additional privacy rights in the state you reside, you have the following rights with respect to the information that we collect (in each case, subject to applicable law):

• Right to Know: To know the categories and specific personal information we have collected, the categories and sources from which we collected the personal information, the categories of third parties with whom we share personal information, and the business or commercial purpose for collecting or selling (if applicable) personal information, and the right to request information about and opt out of automated decision making (if applicable).
• Right to Access: To request a copy of the personal information that we have collected about you during the past 12 months.
• Right to Opt-Out of Sales or Sharing: To opt out of sales of personal information (if applicable) or sharing personal information for Cross-Contextual Behavioral Advertising.
• Right to Delete: To request that we delete the personal information that we have collected from you.
• Right to Correct: To correct inaccurate information that we maintain about you.
• Right to Limit Disclosure of Sensitive Information: To limit the disclosure of sensitive personal information, if we use or disclose sensitive personal information.
• Freedom from Discrimination: To exercise the rights described above free from discrimination or retaliation as prohibited under applicable law.

7.4.1 Right to Opt-Out of the Sale or Sharing of Personal Information to Third Parties

We share personal information with third party marketing tools, which may be considered a sale of information in some jurisdictions. You have the right to opt out of our sale of your personal information or our sharing your personal information for behavioral advertising purposes. We use third-party analytics tools on our website, please refer to the How We Collect Personal Information section above for more information. To exercise your right to opt out of the sale of your personal information, please use the cookie settings to decline all non-essential cookies . If you have additional questions, please contact us using the information provided in the Contact Us section below.

7.4.2 Exercising Your State Privacy Rights

If you reside in a state that provides specific data privacy rights, you may contact us using the Contact Us section below.

Your rights may only be exercised by you or by your designated agent. You may submit a request to know twice within a 12-month period unless applicable data privacy law grants you additional rights.

Your request must include enough information to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include: (1) verifying your account information if you have an account with us; or (2) requesting two forms of identification that are reliable for verification purposes, unless the request includes sensitive information and, in which case, we may require three forms of verification and a signed declaration. The information included in your request must allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. If we cannot verify your identity or authority, we will not fulfill your request. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

You may submit a request through a designated agent. You must instruct that agent that they will need to state that they are acting on your behalf when making the request, have reasonably necessary documentation, and be prepared to provide the necessary personal information to properly verify your request.

We will acknowledge receipt of your request. We will provide a substantive response within 45 calendar days or inform you of the reason and extension period (up to a total of 90 days) in writing.

You may appeal our decision with respect to a request you have submitted by contacting us via the Contact Us section below.

7.4.3 Special Information for Nevada Residents

Residents of the State of Nevada have the right to opt-out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, Performio does not engage in such sales. If you are a Nevada resident and would like more information about our data-sharing practices, please email privacy@performio.co.

7.4.4 California Shine the Light

Residents of the State of California have the right to request information from Performio regarding other companies to whom the company has disclosed certain categories of information during the preceding year for those companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email privacy@performio.co or write to us at: Performio Privacy, 8605 Santa Monica Blvd PMB 52242, West Hollywood, California 90069-4109 US.

8.0 How We Protect Personal Information

We take reasonable steps to protect your personal data from loss, misuse, or unauthorized access, disclosure, alteration, or destruction, taking into due account the risks involved in the processing and the nature of the information. However, no website, application, Internet, or email transmission is ever fully secure or error free, and we do not guarantee the security of any information.

9.0 How Long We Retain Personal Information

We retain your personal information for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

The criteria used to determine appropriate retention period for personal information include:

• The amount, nature, and sensitivity of the personal information.
• The purpose(s) for which the personal information was collected and used.
• Whether we have a legal obligation to retain personal information or whether retaining personal information is necessary to resolve disputes, including the establishment, exercise, or defense of legal claims.

10.0 Your Choices Regarding Your Information

We offer the following choices for updating your information or opting out of other uses of your personal information:

• Customer Information: If you are an authorized user of our Services, you can sign into your account to update your contact information and payment method.
• Our Emails: If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email, or email us at privacy@performio.co and we will promptly remove you from all correspondence.
• Web Brower Settings: Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the other companies who conduct tracking through our Services.
• Google Analytics: You may manage the information that Google Analytics receives by downloading and installing the browser plugin available here.
• Tracking Technologies: You can adjust your cookie preferences, including opting out of all cookies except those that are Strictly Necessary by clicking “Cookie Settings” button at the bottom of the page.

11.0 Changes to This Notice

We may make changes to this Privacy Notice from time to time. We will post any changes here, and such changes will become effective when they are posted.

12.0 Contact Us

For questions about our privacy practices, contact us via:

Mail:

• Performio Privacy
• 8605 Santa Monica Blvd PMB 52242
• West Hollywood, California 90069-4109 US

Email: privacy@performio.co

Phone Number: +1 (833) 817-7084

12.1 Data Protection Officer

We have appointed a Data Protection Officer (DPO) to help us monitor internal compliance, inform, and advise on data protection obligations, and act as a point of contact for individuals and regulators. Our DPO is The DPO Centre Ltd and can be contacted via the privacy email address above.

12.2 EU/UK Representatives

We have appointed both an EU and UK Representative to help facilitate queries and the exercising of privacy rights by individuals located within the European Union and United Kingdom respectively.

Our EU Representative can be contacted as follows:

Postal Address: The DPO Centre Europe Ltd, Vijzelstraat 68-78, Amsterdam, 1017 HL, The Netherlands
Phone number: +31 2020 91510

Email: eurep@performio.co

Our UK Representative can be contacted as follows:

Postal Address: The DPO Centre Ltd, 50 Liverpool Street, London, EC2M 7PR

Phone number: +44 (0) 203 797 1289

Email: ukrep@performio.co

Our demos, like our commission software, are customized for you and your business.