NPSx℠ Privacy Policy

This Privacy Policy applies to the NPSx platform (the "Platform") provided by Bain & Company Inc., a company headquartered in Boston, Massachusetts, USA, and/or the other companies of the Bain group ("Bain", “we”, “us”) who act as data controllers with respect to the personal data you share with Bain under this Policy. The data controller is the person or company that, together or jointly with others, determines the purposes (why) and means (how) of the processing of personal data.

Please note that this Privacy Policy does not apply to any Bain platforms or website other than the NPSx platform.

Bain knows that your privacy is important to you and takes user privacy very seriously. We are committed to protecting your personal data (i.e. any information you provide to us from which you can be identified) in accordance with this Privacy Policy.

Bain reserves the right, at its sole discretion, to alter and update this Privacy Policy from time to time. We therefore invite you to review the current version of the Privacy Policy each time you return to our Platform.

Information we collect and how we use it

Bain might collect personal data from you such as your name, contact details, occupation, industry, region/country, IP address, which videos you view, which exercises and tasks you complete, which live sessions you attend, and which courses you take on the Platform, your interaction with experts and peers on the Platform, and any other information you choose to share through the Platform. By using the Platform or sending us information, you explicitly consent to Bain processing your personal data in accordance with this Privacy Policy.

Bain will use your personal data to administer your access to the Platform, to track your user activity, to provide feedback to your employer on your performance on the Platform (solely if your subscription is purchased for you by your employer), and to analyse and improve the user experience of the Platform.

By using our Platform and submitting your information to us, you explicitly agree to Bain using your personal data for the purposes and in the manner described in this Privacy Policy. Please do not send us any information you do not wish Bain to use.

You do not have to provide us with any personal data. However, if you do not, we may be unable to provide you with access to the Platform.

Bain will keep your personal data for as long as needed to administer your access to the Platform or for as long as we have a relationship with you.

Please note that Bain is not responsible for any information you may disclose publicly in any chat rooms, message boards, or similar web pages, including those hosted on or linked to our Platform. You should keep in mind that, whenever you publicly disclose information about yourself online (for example, via message boards or chat rooms), such information could be collected and used by people whom you do not know. In addition, certain message boards and similar user forums may display IP addresses along with the message poster's name and message. Bain bears no responsibility for any action or policies of any third parties who collect any information users may disclose on the message boards, chat areas or other user forums, if any, on the Platform.

Use of cookies on the Platform

Our Platform may use cookies or other technology (“cookies”) to obtain certain types of information about you when you browse our Platform. Cookies are small text files that are stored by your browser on your computer's hard drive. Cookies can be placed on your computer directly by our Platform (first party cookies) or by another website (third party cookies). You can disable or delete cookies by going to the Help section of your browser but certain functionalities of our Platform might not work properly if you do so.

We may use cookies to keep track of your visit to our Platform, speed up navigation and improve your experience of the site, (for instance by remembering some of your preferences or choices, the last pages you visited or searches you carried out or by keeping you logged in).

Our Platform may use cookies such as Google Analytics to carry out some analytics on and enhance our Platform. These cookies help us understand, for example, how you use our Platform, which pages are the most visited or where people visiting our Platform are located.

The "help" section of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, and how to disable or delete cookies altogether.

Who we share your personal data with

We may share your personal data with other companies of the Bain group as well as with other third parties that might be located in a different country than your country of residence. Bain will not share or sell your data to any third party for their own use.

We may share your personal data with others, such as:

· other offices in the Bain group – for a complete list of our offices, please refer to the Offices page of the bain.com website;

· if your subscription is purchased for you by your employer then we may share your personal data with your employer in order to give details on your use of the Platform;

· carefully selected third party service providers, IT systems providers, or data cleansing providers, so they can provide services to Bain, including but not limited to Squarespace, Inc. for website creation and hosting services, Stripe, Inc. for payment processing services, Hubspot, Inc. for client management services, Thought Industries, Inc. for learning management services, Parabola Labs, Inc. for system integration services, Google LLC for email and other application services, and Okta, Inc. for online security and identification services;

· individuals providing mentoring through the Platform;

· our advisors; and

· law enforcement authorities or other government bodies when we are required to do so.

Third parties, other than law enforcement authorities or government bodies, will only handle your personal data on behalf of Bain for the purposes described in this Policy. Bain will not sell or otherwise share your personal data with such third parties for their own use.

The companies of the Bain group and other third parties we share your information with may be located in other countries, including countries that do not offer the same protection to your personal data as the country in which you reside. Where that is the case, Bain ensures that your personal data is protected by using appropriate legal mechanisms. If you reside in the European Union, such mechanisms include using contracts or wording approved by the European Commission (called “Standard Contractual Clauses”). Standard Contractual Clauses are an agreement that can be entered into by companies for transfers of personal data outside of the European Union. They are a mechanism approved by the European Commission to ensure adequate safeguards to personal data when it is transferred outside of the European Union.

Links to other websites

Our Platform may contain links to third party websites that are governed by their own terms and privacy policies, including social network sites. Bain is not responsible for the privacy practices of such websites, which you should review before browsing or submitting information to them. Bain does not bear any liability and responsibility for the content or your use of these websites.

A link to a third party website does not mean that Bain endorses or accepts any responsibility for the content or the use of such website.

Security of your personal data

Bain has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction. Such measures include anonymizing (transforming data in such a way that it is no longer identifiable) or pseudonymizing (transforming data in such a way that it is no longer identifiable without the use of additional information) data where possible. Authorized Bain personnel and third parties mentioned above will only have access to your personal data to the extent they need it to do their job or provide their services. Despite these precautions, however, Bain cannot guarantee that unauthorized persons will not obtain access to your information.

Your Rights

Depending on where you reside you might have the right to request access to, rectification or erasure of your personal data and to object to or ask for the restriction of the processing of your personal data. You might also have the right to request that we correct incorrect, inaccurate or out-of-date information about you or to withdraw your consent and request that we stop processing or delete your personal data.

If you receive marketing communications from Bain, you can opt out of receiving future emails from Bain or unsubscribe from participating in our programs through the "preferences" page, which is accessible in every marketing email you receive from Bain.

If you wish to make a request about your personal data, please contact us at [email protected]. Please note that we will take reasonable steps to check your identity before handling your request.

If you think we are handling your information unlawfully, we encourage you to get in touch with us at [email protected]. You may also have the right to lodge a complaint with your national supervisory authority.

Children

Our Platform is not directed at children 16 years of age or younger. Bain will not intentionally collect information about anyone under the age of 16, and requests that no such information be submitted to us.

Contact

If you have any questions about this Privacy Policy or how Bain handles your personal data, please contact Bain’s Global Data Protection Officer:

Email: [email protected]

Post: Bain & Company, Inc. United Kingdom, 40 Strand, London WC2N 5RW, United Kingdom.

Last updated: April 4, 2022.