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Privacy Policy

Last Updated: February 23, 2026 | Effective Date: February 23, 2026

1. Introduction

LEaDOn, LLC, a California limited liability company doing business as Thrive Leadership Co. (“Thrive,” “we,” “us,” or “our”) operates the Thrive Trait Inventory, a behavior-based pre-hire screening platform accessible at thrivetraitinventory.com (the “Platform”). This Privacy Policy (“Policy”) explains how we collect, use, share, and protect personal information in connection with the Platform and our related services (collectively, the “Services”).

This Policy applies to three categories of individuals:

  • Customers: Employers, hiring managers, and HR professionals who create accounts on the Platform and use the Services to screen candidates.
  • Candidates: Individuals who complete Assessments through the Platform at the direction of a Customer. Candidates do not create accounts; they access Assessments via unique survey links.
  • Website Visitors: Individuals who visit thrivetraitinventory.com or thriveleadershipco.com without creating an account.

By using the Services, creating an account, or completing an Assessment, you acknowledge and agree to the practices described in this Policy. If you do not agree, please discontinue use of the Services.

Our details:
LEaDOn, LLC d/b/a Thrive Leadership Co.
1991 Village Park Way, Ste. A
Encinitas, CA 92024
Email: hello@thriveleadershipco.com

2. Information We Collect

2.1 Information Provided by Customers

When Customers create an account and use the Services, we collect:

  • Account registration information: name, email address, phone number, company name, job title;
  • Billing information: invoicing details and, when applicable, payment information processed through our designated payment processor (such as Stripe). We do not store full payment card details;
  • Job and role configuration data: job descriptions, selected traits, and other parameters entered into the Platform;
  • Communications: support requests, feedback, and correspondence with Thrive.

2.2 Information Provided by Candidates

When a Candidate completes an Assessment, we collect:

  • Assessment responses: answers to trait-based, behavioral, and self-perception questions;
  • Identifying information: name and email address (as provided by the Customer or entered by the Candidate); and
  • Metadata: timestamps, completion duration, and device/browser information associated with the Assessment session.

Important for Candidates: Your Assessment is administered at the direction of your prospective employer (the Customer). The Customer, not Thrive, determines which Candidates are assessed, which roles are evaluated, and how Generated Reports are used in hiring decisions. If you have questions about how your prospective employer uses your Assessment data, please contact them directly.

2.3 Information Collected Automatically

When anyone interacts with the Platform or our websites, we automatically collect:

  • IP address and approximate geographic location;
  • Browser type, operating system, and device identifiers;
  • Pages visited, timestamps, and session duration;
  • Referring URLs and navigation paths; and
  • Error logs and performance data.

2.4 Information We Do Not Collect

Thrive does not intentionally collect sensitive personal information, including: Social Security numbers, government-issued identification numbers, financial account numbers, biometric identifiers, health or medical information, genetic data, precise geolocation, or information about race, ethnicity, religion, sexual orientation, or political affiliation. Customers and Candidates are instructed not to provide such information through the Platform.

3. Legal Basis for Processing

Thrive processes personal information on the following legal bases:

  • Contract Performance: To provide the Services to Customers, process Assessments, and generate reports as agreed under our Terms and Conditions.
  • Legitimate Interests: To secure the Platform, detect and prevent fraud, analyze usage patterns, and improve our Services, where these interests are not outweighed by individual privacy rights.
  • Consent: For marketing communications, non-essential cookies, and any processing that requires consent under applicable law. You may withdraw consent at any time.
  • Legal Obligations: To comply with applicable laws, regulations, court orders, or other legal requirements.

4. How We Use Information

We use the information we collect for the following purposes:

  • Service Delivery: To operate the Platform, process Assessments, generate reports, and provide related services to Customers.
  • Report Generation: To produce Generated Reports including trait scores, mindset-behavior gap analysis, Self-Perception Index results, interview questions, and Manager Insight recommendations.
  • AI-Assisted Features: To power the Trait Builder (which generates role-specific trait profiles from job descriptions) and Manager Insight (which generates onboarding recommendations). These features may use artificial intelligence, and inputs may be processed by AI systems to produce outputs.
  • Platform Improvement: To analyze usage patterns, improve scoring methodologies, develop new features, and enhance the accuracy and reliability of the Platform. Where feasible, such analysis is performed on anonymized or aggregated data.
  • Billing and Account Management: To process payments, manage subscriptions, and communicate about account-related matters.
  • Security and Fraud Prevention: To detect, prevent, and investigate unauthorized access, abuse, or security incidents.
  • Communications: To respond to inquiries, provide customer support, and send transactional and, with consent, marketing communications.
  • Legal Compliance: To comply with applicable laws, regulations, and legal processes.

5. How We Share Information

We do not sell personal information. We do not rent, sell, or trade personal information to third parties for their marketing purposes.

We may share personal information with the following categories of recipients:

  • Customers: Candidate Data and Generated Reports are shared with the Customer who initiated the Assessment. Thrive does not share Candidate Data with anyone other than the requesting Customer, except as required by law.
  • Service Providers: We engage third-party vendors who process personal information on our behalf to provide hosting, payment processing, analytics, customer support, and other operational services. These providers are contractually obligated to protect personal information and use it only for the purposes we specify.
  • AI Service Providers: Certain AI-assisted features may transmit data to third-party AI service providers for processing. Data transmitted to AI providers is used solely to generate outputs for the requesting Customer and is not used to train general-purpose AI models.
  • Legal and Compliance: We may disclose information if required by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
  • Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, personal information may be transferred as part of the transaction. We will provide notice before personal information becomes subject to a different privacy policy.

6. Data Roles and Responsibilities

6.1 Thrive as Service Provider

With respect to Candidate Data, Thrive acts as a service provider (or data processor, under applicable international law) to the Customer. Thrive processes Candidate Data on behalf of and at the direction of the Customer. The Customer, as the employer or prospective employer, is the data controller and is responsible for:

  • Providing appropriate notice to Candidates about the use of the Assessment;
  • Obtaining any required consent from Candidates;
  • Ensuring that the use of Assessment data complies with applicable employment and data protection laws; and
  • Responding to Candidate data subject requests regarding the Customer’s use of their data.

6.2 Thrive as Controller

With respect to Customer account information, website visitor data, and Usage Data, Thrive acts as the data controller and processes such information in accordance with this Policy.

7. International Data Transfers

Thrive is based in the United States. If you are accessing the Platform from outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.

For individuals in the European Economic Area (EEA), United Kingdom, or Switzerland, where required by law, Thrive will ensure appropriate safeguards are in place for international data transfers, including the use of Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms.

8. Data Security

Thrive implements commercially reasonable technical, administrative, and organizational measures designed to protect personal information from unauthorized access, disclosure, alteration, or destruction, including:

  • Encryption of data in transit and at rest;
  • Access controls and authentication requirements;
  • Regular security monitoring and incident response procedures; and
  • Contractual security obligations on third-party service providers.

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide personal information at your own risk. If you believe your account or data has been compromised, please contact us immediately at hello@thriveleadershipco.com.

9. Data Retention

We retain personal information only as long as necessary to fulfill the purposes described in this Policy or as required by applicable law:

  • Customer Account Data: Retained for the duration of the account relationship and for a reasonable period thereafter for legal compliance and dispute resolution purposes.
  • Candidate Data and Generated Reports: Retained for ninety (90) days following account termination or as otherwise agreed with the Customer. During this period, Customers may request export of their data.
  • Usage Data and Analytics: May be retained in anonymized and aggregated form indefinitely for platform improvement and research purposes.
  • Log Data: Retained for up to ninety (90) days unless required by law.

To request deletion of your data, contact us at hello@thriveleadershipco.com.

10. Your Privacy Rights

10.1 Rights for All Users

Depending on your jurisdiction, you may have the following rights regarding your personal information:

  • Right of Access: Request disclosure of the personal information we hold about you.
  • Right of Deletion: Request deletion of your personal information, subject to legal exceptions.
  • Right to Correct: Request correction of inaccurate personal information.
  • Right to Data Portability: Request a copy of your personal information in a structured, commonly used format.
  • Right to Object: Object to processing of your personal information based on legitimate interests or for direct marketing purposes.
  • Right to Restrict Processing: Request that we limit how we process your personal information in certain circumstances.
  • Right to Withdraw Consent: Where processing is based on consent, withdraw your consent at any time without affecting the lawfulness of prior processing.

10.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

  • Right to know what personal information is collected, used, and disclosed;
  • Right to delete personal information;
  • Right to opt-out of the sale or sharing of personal information (note: Thrive does not sell or share personal information as defined under CCPA/CPRA); and
  • Right to non-discrimination for exercising your privacy rights.

10.3 Rights for Candidates

If you are a Candidate who completed an Assessment, please note that Thrive processes your data on behalf of the Customer (your prospective employer). For questions about how your Assessment data is being used in hiring decisions, please contact the employer who directed you to the Assessment. For requests related to Thrive’s processing of your data (access, deletion, correction), you may contact us directly at hello@thriveleadershipco.com, and we will coordinate with the applicable Customer as appropriate.

10.4 Exercising Your Rights

To exercise any of these rights, please contact us at hello@thriveleadershipco.com. We will verify your identity before processing your request and will respond within thirty (30) days, or the period required by your local law. Thrive will not discriminate against you for exercising your privacy rights.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to operate, secure, and analyze the Platform and our websites. We use the following types of cookies:

  • Strictly Necessary Cookies: Required for core functionality such as authentication, session management, and security. These do not require consent.
  • Analytics Cookies: Used to understand how the Platform and websites are used, measure feature adoption, and improve performance. We use Google Analytics and may use other analytics tools. We obtain consent for these cookies where required by law.
  • Functional Cookies: Remember your preferences (such as language or display settings) to enhance your experience.

We do not use marketing or advertising cookies on the Platform. You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect core Platform functionality.

12. Children’s Data

The Services are not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from anyone under this age. If we discover that we have collected personal information from a minor, we will promptly delete that information. If you believe we may have collected such data, please contact us at hello@thriveleadershipco.com.

13. Changes to This Policy

Thrive may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Services. We will post any revised Policy at thrivetraitinventory.com and update the “Last Updated” date. For material changes that reduce your rights or expand our processing purposes, we will provide at least thirty (30) days’ advance notice by email or in-Platform notification. Your continued use of the Services after the revised Policy takes effect constitutes acceptance of the updated terms.

14. Governing Law

This Policy is governed by and construed in accordance with the laws of the State of California, without regard to its conflict-of-law principles. If you are located in a jurisdiction that grants you mandatory consumer protection or data protection rights under local law, those provisions will take precedence to the extent they conflict with this Policy.

15. Contact Us

If you have questions, concerns, or wish to exercise your privacy rights, please contact us:

LEaDOn, LLC d/b/a Thrive Leadership Co.
1991 Village Park Way, Ste. A
Encinitas, CA 92024
Email: hello@thriveleadershipco.com
Phone: (760) 487-8664

We aim to respond to verified requests within thirty (30) days. If you are not satisfied with our response, you may lodge a complaint with your local data protection authority.

© 2026 Thrive Leadership Co. (LEaDOn, LLC). All rights reserved.