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Privacy Policy

Effective date: 2026-06-17  ·  Version: 2026-06-17

This policy explains how Vertical Motion LLC ("we," "us," or "our") collects, uses, and protects personal information when you use the ELT Risk Scorecard, the LDNA Assessment, or any other tool or page on this website.

1. Who we are

Data controller: Vertical Motion LLC
Contact for privacy matters: support@vmleader.com
Postal address: 1500 N Grant St., Suite R, Denver, CO 80203, United States
Website: eltscale.com

If you are in the European Economic Area or the United Kingdom and you believe a privacy concern has not been adequately addressed, you have the right to lodge a complaint with your local supervisory authority.

2. What we collect

When you use the ELT Risk Scorecard or contact us, we may collect:

• Identification data: your full name and email address.
• Professional context: your role or title, company name, and annual revenue range.
• Assessment responses: your answers to the 20-question ELT Risk Scorecard across five dimensions (Composition and Fit, Coverage and Complementarity, Bench Load and Durability, Decision and Alignment, and Trust and Conflict).
• Contact form data: your leadership challenge description, whether you have completed the scorecard, and any other information you choose to share in the contact form.
• Consent record: the date and time you granted consent, and your opt-in choices for follow-up communications.
• Technical metadata: the date and time of submission. We do not use tracking cookies, behavioral advertising pixels, or session recording tools on this site.

We do not collect: health information, government identifiers, payment information, geolocation, device identifiers, or any special categories of sensitive personal data.

3. Why we collect it and our legal basis

Purpose	Legal basis
Generating and delivering your ELT Risk Scorecard results	Performance of a contract with you (delivering the assessment) and your consent
Sending your results and risk snapshot to your email	Performance of a contract with you
Responding to contact form inquiries	Performance of a contract with you (pre-contractual steps)
Sending follow-up communications you opted in to	Your explicit consent
Keeping a record of your consent	Legal obligation (GDPR Article 7(1) and applicable US state law)
Improving the ELT Risk Scorecard using aggregated, anonymous data	Legitimate interest in improving the quality of our tools

4. Who can see your data

Your data is processed by Vertical Motion LLC and a small number of contracted service providers acting as our data processors:

• Cloud storage and email delivery platform — used to store your responses and send your results. All data is encrypted in transit and at rest.
• CRM or contact management platform — used to manage follow-up communication you have opted into.

We do not sell your personal information. We do not share it for cross-context behavioral advertising as defined under the California Consumer Privacy Act, as amended, or the Colorado Privacy Act.

We may disclose data if required to comply with a valid legal process, to protect our rights, or to investigate suspected fraud — only to the minimum extent necessary.

5. International transfers

We are based in the United States. If you access this site from the EEA or UK, your data will be transferred to and processed in the United States. Where required, we rely on appropriate safeguards under our service providers' data processing agreements, including Standard Contractual Clauses or eyuivalent mechanisms.

6. How long we keep it

• Assessment responses and result data: retained for up to 24 months after your most recent interaction, after which personally identifying fields are deleted or anonymized.
• Consent records: retained for 6 years after the consent is given or withdrawn, to comply with our legal obligation to demonstrate the basis of processing.
• Contact form submissions: retained for as long as necessary to complete any active conversation, and no longer than 24 months thereafter.
• Marketing opt-in data: retained until you opt out or until we cease the relevant communications.

7. Your rights

Depending on where you live, you have the following rights regarding your personal data. We will respond to verified requests within the timeframes required by applicable law (30 days under GDPR; 45 days under CCPA/CPRA and the Colorado Privacy Act).

• Right to know / access — request a copy of the personal data we hold about you.
• Right to rectification — correct any data that is inaccurate or incomplete.
• Right to erasure — ask us to delete your personal data, subject to legal retention requirements.
• Right to restriction of processing — ask us to pause processing while a dispute is resolved.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interests.
• Right to withdraw consent — withdraw any consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
• Colorado Privacy Act (CPA) rights — Colorado residents have the right to opt out of the sale of personal data (we do not sell data), the right to opt out of targeted advertising (we do not conduct targeted advertising), and the right to appeal a denial of any of the above rights.
• California-specific rights — California residents additionally have the right to opt out of any "sale" or "sharing" of personal information, the right to limit use of sensitive personal information, and the right to non-discrimination for exercising any of these rights.

To exercise any of these rights, email support@vmleader.com from the email address you used to take the assessment. We may ask for additional information to verify your identity.

8. Automated decision-making

The ELT Risk Scorecard uses your responses to generate a scored risk snapshot across five dimensions. The scoring is rule-based and automated. All interpretation, recommendations, and follow-up conversations involve human review. We do not use assessment results to make decisions that produce legal or similarly significant effects on you without human involvement.

If you believe your scorecard results are incorrect or were misapplied, contact us and we will review them.

9. Children's data

The ELT Risk Scorecard and related tools are intended for business professionals. We do not knowingly collect data from anyone under the age of 16. If you believe a minor has submitted data to us, contact us and we will delete it promptly.

10. Security

We use industry-standard administrative and technical safeguards to protect your data, including encryption in transit (HTTPS) and at rest, access controls limited to authorized personnel, and multi-factor authentication on administrative accounts. No method of transmission over the internet is 100% secure, but we maintain protections appropriate to the sensitivity of the data we process.

11. Changes to this policy

We may update this policy from time to time. When we do, we will update the effective date and version at the top of this page. For material changes, we will make a reasonable effort to notify you by email if we hold your address and, where required, seek fresh consent.

12. Contact

For any questions about this policy or your data:

Vertical Motion LLC
1500 N Grant St., Suite R
Denver, CO 80203
United States
support@vmleader.com
eltscale.com