Level 10 Leaders Privacy Policy

1. Who we are and what this policy covers

The Breakthrough US, Inc., a Delaware corporation doing business as Level 10 Leaders, operates this website. It is a subsidiary of The Breakthrough Company Limited, a New Zealand company that also does business as Level 10 Leaders. In this policy, Level 10 Leaders, we, us and our mean The Breakthrough US, Inc., except where section 11 says The Breakthrough Company Limited is responsible for information about its New Zealand clients.

This policy covers level10leaders.com and its subdomains, the short links we use in marketing including lvl10.us, our online assessments and questionnaires, our learning management system at learn.level10leaders.com, our email communications, and the events and sales conversations that follow from them.

It does not cover the AMOS platform. If your employer has licensed AMOS, the information you enter there is governed by our agreement with your employer and by the separate AMOS platform notice, not by this policy.

We previously operated as The Breakthrough Co at thebreakthrough.co. The legal entity has not changed. Information collected under the earlier policy is now handled under this one, and the old privacy page at thebreakthrough.co redirects here.

2. Information we collect

Information you give us

• Contact and business details: name, business email address, phone number, employer, job title, city and state or province.
• Assessment responses: your answers to any online assessment or questionnaire we offer, any free-text comments you add, and the scores generated from them.
• Professional information: company size, industry, number of managers, reporting structure, and similar details you share in a form or a conversation.
• Communications: emails, form messages, and notes from calls and meetings. Where we record a call we tell you first and ask for your agreement.
• Registrations for webinars, workshops and events.
• Learning records: your enrolments, course progress, completions and any work you submit in our learning management system.

We do not ask for government identifiers, payment card numbers, health information, precise location or biometric data, and we ask that you do not send them to us.

Information we collect automatically

• IP address and the approximate city derived from it, browser and device type, operating system, referring page, pages viewed, links clicked, and the date and time of access.
• Information from cookies, pixels and similar technologies. See section 5.

Information from other sources

• Business contact and company data from commercial data providers and public sources such as company websites, press coverage and professional networks. We use this to confirm job titles and company details and to decide which businesses to approach.
• Referrals from clients, partners and event hosts.
• Aggregate reporting from our advertising and analytics platforms.

3. How we use information

• Score and return your results from any assessment or questionnaire you complete.
• Answer your questions and carry on conversations about our programs.
• Deliver our programs and track your progress through our learning management system.
• Send you email about our research, events and programs, which you can stop at any time.
• Operate, secure and improve the website.
• Measure which advertising and content brings people to us.
• Produce aggregated, de-identified benchmarks and research. Nothing we publish this way identifies you or your employer.
• Meet legal obligations, enforce our terms, and prevent fraud and abuse.

We do not use your assessment responses or your communications with us to train publicly available artificial intelligence models.

4. How we share information

Service providers. We use vendors to run the business: customer relationship management and marketing automation, email delivery, website hosting and content delivery, scheduling, analytics, advertising platforms, and artificial intelligence and productivity tools. Under contract, they may only use your information to provide services to us.

Our parent company. The Breakthrough Company Limited, which does business as Level 10 Leaders in New Zealand, owns The Breakthrough US, Inc. A small number of its people have limited, role-based access to our systems to deliver and support our work. Your information is held on secure cloud servers in the United States, not on local systems in New Zealand.

Legal and safety. We may disclose information where we believe in good faith that it is necessary to comply with law or legal process, to enforce our terms, or to protect the rights, property or safety of any person.

Business transfers. If we are involved in a merger, acquisition or sale of assets, your information may be transferred as part of that transaction. We will give notice before your information becomes subject to a different privacy policy.

We do not sell your personal information for money. Section 5 explains how advertising cookies are treated under state law.

5. Cookies, pixels and advertising

We use three kinds of cookies and similar technologies.

• Strictly necessary. Required for the site to work. These cannot be switched off.
• Analytics. Tell us which pages are read and where visitors come from.
• Advertising. Let us measure advertising performance and show ads to people who have visited the site.

We use the Meta Pixel for measurement and retargeting. We do not upload contact lists, assessment responses or any other customer or prospect data to advertising platforms.

What this means under state law. Using advertising cookies in this way is treated as selling or sharing personal information for targeted advertising under the privacy laws of California, Colorado, Connecticut, Texas and other states, even though no money changes hands and no list is uploaded. You can opt out.

How to opt out:

• Use the Cookie Preferences link in the subfooter of every page.
• Turn on Global Privacy Control in your browser. We recognise it and similar browser signals and treat them as a valid opt-out request.
• Change your advertising settings directly with Meta, or use the industry opt-outs at optout.aboutads.info and optout.networkadvertising.org.
• Block or delete cookies in your browser settings. Parts of the site may stop working.

6. How long we keep information

• Assessment responses and prospect records: three years from your last interaction with us, after which we delete or de-identify them.
• Marketing contacts: until you unsubscribe. We then keep a minimal suppression record so that we do not contact you again.
• Website and advertising cookies: for the periods set out in our cookie notice.
• Contracts, invoices and records we are required to keep: for the period the law requires.

7. How we protect information

We encrypt information in transit and at rest, limit access to the people and vendors who need it for their role, require multi-factor authentication on our core systems, and review our vendors before and during an engagement. No system is completely secure, and we cannot guarantee that information will never be accessed without authorisation.

8. Your choices

• Marketing email. Use the unsubscribe link in any message, or write to privacy@level10leaders.com. We may still send administrative messages such as notice of a change to this policy.
• Cookies and advertising. See section 5.
• Access, correction and deletion. Ask us at privacy@level10leaders.com whether or not a law gives you the right. We will act on it unless we have a legal reason not to, and we will tell you if that is the case.

9. United States state privacy rights

Depending on where you live, you may have the following rights.

• Know what personal information we hold about you, how we use it and who we disclose it to, and receive a copy in a portable format.
• Correct information that is inaccurate.
• Delete the information we hold about you.
• Opt out of targeted advertising and of the sale or sharing of your personal information.
• Opt out of profiling that produces legal or similarly significant effects. We do not carry out that kind of profiling.
• Exercise any of these rights without being treated differently as a result. We do not offer financial incentives in exchange for personal information.

California

In the past twelve months we have collected these categories of personal information: identifiers; commercial information; internet and network activity; professional and employment information; and inferences drawn from them. The purposes are set out in section 3 and the recipients in section 4.

We do not collect sensitive personal information as California defines it. We have not sold personal information for money. We do share personal information for cross-context behavioural advertising through the advertising cookies described in section 5, and you can opt out there. We do not knowingly sell or share the personal information of anyone under sixteen.

How to exercise these rights

Email privacy@level10leaders.com or use the contact form at level10leaders.com/contact. We will ask for enough information to confirm the request is yours. An authorised agent may act for you with your written permission. We respond within forty-five days and may extend once where the law allows, with notice to you.

Appeals

If we decline your request and you live in Colorado, Connecticut, Virginia, Texas, Oregon, Montana or another state with an appeal right, write to privacy@level10leaders.com with Privacy Appeal in the subject line. We will respond within the period your state's law sets. If we decline the appeal, you may complain to your state attorney general.

10. Canada

We handle personal information about people in Canada under the Personal Information Protection and Electronic Documents Act.

Consent. We rely on your consent to collect and use your personal information: express consent where the law requires it, and implied consent where the purpose is obvious and the information is business contact information. You may withdraw consent at any time, subject to legal and contractual limits, by writing to our Privacy Officer.

Access and correction. You may ask what personal information we hold about you, how we have used it and who we have disclosed it to, and ask us to correct anything inaccurate. We respond within thirty days.

Information held outside Canada. Your personal information is stored and processed in the United States on cloud infrastructure located there, and a small number of people at our New Zealand parent company have limited access to it. While your information is in those countries it is subject to their laws, and may be accessible to their courts, law enforcement and national security authorities under lawful process.

Commercial electronic messages. We send marketing email in line with Canada's Anti-Spam Legislation. We identify ourselves in every message and include a working unsubscribe mechanism, which we action within ten business days.

Privacy Officer. Dr. Mike Ashby, President, privacy@level10leaders.com, 4450 Arapahoe Avenue, Suite 100, Boulder, Colorado 80303. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca.

11. New Zealand

We handle personal information about people in New Zealand under the Privacy Act 2020 and its information privacy principles.

How we collect it. We collect personal information directly from you wherever we can, for the purposes set out in section 3. Providing it is voluntary. If you choose not to, we may not be able to answer your question, return your assessment results, or deliver a program you have enrolled in.

Access and correction. You have the right to ask for the personal information we hold about you and to ask us to correct it. Write to our Privacy Officer. We respond within twenty working days. If we decline a request we will tell you why, and you may complain to the Privacy Commissioner. If we do not make a correction you have asked for, you may ask us to attach a statement of the correction sought, and we will attach it.

Sending information overseas. Our systems are hosted in the United States, so personal information we collect in New Zealand is disclosed to service providers outside New Zealand. Before we do that, principle 12 requires us to be satisfied that the recipient is subject to privacy safeguards comparable to those in the Privacy Act. We rely on binding contractual terms with each provider.

Privacy breaches. If a privacy breach occurs and it is likely to cause serious harm, we will notify the Office of the Privacy Commissioner and the people affected as soon as practicable.

Marketing email. We send commercial electronic messages in line with the Unsolicited Electronic Messages Act 2007. Every message identifies us and carries a working unsubscribe facility, which we action within five working days.

Privacy Officer. Dr. Mike Ashby, President, privacy@level10leaders.com. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner at privacy.org.nz or on 0800 803 909.

Which entity holds your information. Clients in New Zealand contract with The Breakthrough Company Limited, which does business as Level 10 Leaders in New Zealand and is the parent company of The Breakthrough US, Inc. That company is the agency responsible for their personal information under the Privacy Act, and this policy describes how it handles it.

12. Where your information is stored

Our systems, including our learning management system, are hosted on secure cloud servers in the United States. If you are in Canada or anywhere else outside the United States, using this site or sending us information means your information is transferred to and processed in the United States, where privacy law differs from the law where you live. Sections 10 and 11 set out what this means for people in Canada and New Zealand.

13. Children

This is a business service intended for people aged eighteen and over. We do not direct the site to children and we do not knowingly collect personal information from anyone under sixteen. If you believe a child has given us personal information, write to privacy@level10leaders.com and we will delete it.

14. Other websites

The site links to websites and services we do not control, and we are not responsible for their privacy practices. Read their policies before you use them. If you reach our content through a third-party platform, that platform's policy governs what it collects about you.

15. Changes to this policy

We may update this policy. The current version is always posted here with its date at the top. Where a change materially affects how we handle information we already hold, we will give notice by email or by a prominent notice on the site at least thirty days before it takes effect. Clarifications and minor corrections take effect when posted.

16. Contact us

The Breakthrough US, Inc., doing business as Level 10 Leaders. 4450 Arapahoe Avenue, Suite 100, Boulder, Colorado 80303. privacy@level10leaders.com.

Privacy questions, rights requests and appeals all go to the same address. Our Privacy Officer for the United States, Canada and New Zealand is Dr. Mike Ashby, President.

Last updated 13 October 2026