Privacy Policy

CLP Ventures, LLC, doing business as ThriveAxis® (formerly Carol Parker Walsh Consulting Group) ("Company," "we," or "us") is committed to safeguarding your privacy and maintaining the confidentiality of the information you share with us. This Privacy Policy explains how we collect, use, protect, and manage your personal data when you engage with our services, attend our programs, or use our digital platforms and AI-enhanced tools.

This Privacy Policy governs your access to and use of www.thriveaxisgroup.com, including any content, functionality, and services offered on or through the Website, whether as a guest or a registered user.

By accessing or using our services, you agree to the terms outlined in this Privacy Policy.

1. Purpose and Scope

This Privacy Policy provides transparency into:

The personal data we collect about you and how we obtain it
How we use, share, and protect your data
Your rights concerning your personal information
How we incorporate AI and other technologies responsibly into our services

This Policy applies to all services offered by CLP Ventures, LLC, including leadership coaching, executive development programs, AI-enhanced assessments and tools, and consulting services, as well as all interactions through our websites, applications, or other digital platforms (collectively, the "Services").

2. Children Under the Age of 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from individuals under the age of 13.

If you are under 13, do not:

Use or provide any information on this Website
Register on the Website or make any purchases
Use any interactive or public comment features
Provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name

If we learn that we have collected or received personal information from a child under 13 without verifying parental consent, we will delete that information. If you believe we may have any information about or from a child under 13, please contact us at support@thriveaxisgroup.com.

3. Personal Data We Collect

We collect and process personal data to provide and enhance our Services. The information we collect falls into several categories:

Information You Provide:

Contact Information: Name, email address, phone number, and mailing address
Professional Information: Job title, company name, industry, and role
Coaching and Program Data: Goals, challenges, progress notes, assessment results, and insights shared during coaching sessions, workshops, or leadership development programs
Payment Data: Credit card details, billing addresses, and transaction history (processed securely through third-party payment processors)
Communication Data: Content of your email messages, contact form submissions, and other correspondence with us
Registration Information: Data provided when registering for webinars, events, programs, or downloading resources

Automatically Collected Data:

Usage Data: Pages viewed, features accessed, time spent on the Website, frequency of use, and interaction patterns with our digital tools
Device Information: Device type, browser type, IP address, operating system, and referring/exit pages
Location Data: General geographic location based on IP address
Analytics Data: Traffic patterns, click-through rates, and other statistical information collected through tools like Google Analytics

AI-Processed Insights:

Behavioral Trends: Patterns identified through AI-enhanced assessment tools
Development Recommendations: Personalized insights generated by AI systems to support your leadership development journey
Learning Analytics: Progress tracking and recommendation algorithms within our learning platforms

All AI-generated insights are reviewed by certified coaches and facilitators to ensure relevance, accuracy, and alignment with your specific goals and context.

4. How We Use Your Data

We use your personal information for the following purposes:

Service Delivery:

Provide personalized coaching experiences and leadership development programs
Deliver the products, services, or content you request
Facilitate your participation in programs, webinars, and events
Process payments and maintain transaction records
Communicate with you about your programs, subscriptions, and services

Service Improvement:

Improve and refine our coaching methods, programs, and digital tools
Develop new services and offerings
Analyze usage patterns to enhance user experience
Conduct research and analysis to better serve our clients

Communication:

Send program updates, resources, and educational content
Provide customer service and respond to your inquiries
Share newsletters, promotional materials, and information about services (with your consent)
Notify you of important changes to our Services or policies

AI Integration:

Our AI-enhanced tools may analyze coaching session data, assessment responses, and interaction patterns to generate actionable insights, development recommendations, and personalized learning paths. These AI outputs are:

Always reviewed by your coach or program facilitator to ensure quality and relevance
Designed to augment, not replace, human expertise and personalized guidance
Used to support your specific development goals and organizational context

Legal and Business Operations:

Carry out contracts between you and the Company
Administer our business activities and maintain business records
Comply with legal obligations and protect our legal rights
Ensure the safety, security, and functionality of our platforms

5. Sharing Your Information

As a general rule, we do not sell, rent, lease, or otherwise transfer your personal information to third parties for their marketing purposes.

We may share your personal data only under these circumstances:

Service Providers:

We may share information with trusted third-party vendors who provide services on our behalf, including:

Payment processors
Email service providers
Cloud storage and hosting services
Analytics platforms
Learning management system providers
CRM and marketing automation platforms

All service providers are bound by strict data protection agreements and are prohibited from using your information for any purpose other than providing services to us.

Professional Partners:

When you participate in co-facilitated programs or joint offerings, we may share relevant information with our professional partners who are directly involved in delivering services to you.

Legal Compliance and Protection:

We may disclose your personal information when:

Required by law, regulation, or legal process
Necessary to comply with a court order or other governmental request
Necessary to enforce our Terms of Use or other agreements
Necessary to protect our legal rights or the safety of our users or others
Part of a business transfer in case of merger, acquisition, or sale of assets (with notification provided)

6. International Data Transfers

Your information, including Personal Information, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer this information, including Personal Information, to the United States for processing. We utilize safeguards, such as standard contractual clauses, to ensure that your data remains protected during international transfers.

Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.

7. Email Communications and Opt-Out Rights

Email Policies:

We are committed to keeping your email address confidential and will not sell, rent, or lease our subscription lists to third parties.

Enrollment Practices:

If you are outside the European Union: When you download resources, register for programs or webinars, or make purchases, we will automatically enroll you to receive our promotional email communications, including our newsletter. You can unsubscribe at any time.

If you are in the European Union, we will only enroll you to receive promotional email communications if you affirmatively consent to it. You can withdraw your consent and unsubscribe at any time.

CAN-SPAM Act Compliance:

All emails sent from our organization will:

Clearly state who the email is from
Provide clear information on how to contact us
Include concise information on how to unsubscribe
Include an "unsubscribe" link at the bottom of every email

How to Unsubscribe:

You can opt out of receiving promotional communications from us at any time by:

Clicking the unsubscribe link at the bottom of any email
Emailing us at support@thriveaxisgroup.com with your unsubscribe request

Please note that even if you opt out of promotional emails, we may still send you transactional or administrative messages related to services you have purchased or programs you are enrolled in.

8. Cookies and Tracking Technologies

Our Website uses cookies and similar technologies to enhance user experience, analyze usage patterns, and deliver personalized content.

What Are Cookies?

A cookie is a small text file stored on your device that contains an anonymous unique identifier. When you visit a website, that site asks your browser for permission to store this file in a part of your device designated for cookies. Each website can send its own cookie to your browser if your browser's settings allow it, but your browser only permits a website to access the cookies it has already sent, not those sent by other sites.

How We Use Cookies:

We use cookies and similar technologies to:

Remember your preferences and settings
Understand how you interact with our Services
Analyze traffic patterns and usage statistics
Deliver personalized content and recommendations
Measure the effectiveness of our marketing campaigns
Enable certain features and functionality

Types of Cookies We Use:

Essential Cookies: Necessary for the Website to function properly
Analytics Cookies: Help us understand how visitors use our Website (including Google Analytics)
Functional Cookies: Remember your preferences and personalize your experience
Marketing Cookies: Track your activity to deliver relevant advertisements

Social Media Pixels:

We may use social media pixels and similar technologies that allow social media platforms to track visitors to our Website and tailor advertising messages. We use these pixels in compliance with the policies of the relevant social media platforms.

Third-Party Cookies:

Some content or applications on the Website, including advertisements, are served by third parties such as advertisers, ad networks, content providers, and application providers. These third parties may use cookies alone or with web beacons or other tracking technologies to collect information about you when you use our Website. We do not control the tracking technologies used by these third parties. If you have questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Managing Cookies:

You can manage or disable cookies through your browser settings. Please note that disabling cookies may limit the functionality of our Services and affect your user experience.

9. Data Security and Protection

The security of your Personal Information is important to us. We implement industry-standard security measures to protect your data, including:

Technical Safeguards:

Encryption of data in transit and at rest
Secure servers and cloud storage
Firewalls and intrusion detection systems
Regular security assessments and updates
Access controls and authentication requirements

Organizational Safeguards:

Staff training on data protection and privacy
Confidentiality agreements with employees and contractors
Policies and procedures for secure data handling
Incident response and breach notification procedures

Important Security Notice:

While we strive to implement and maintain reasonable, commercially acceptable security procedures and practices, please be aware that no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of the Personal Information we have collected from you.

Email Security: Email is not a secure medium of communication. For this reason, we ask that you refrain from sending private or sensitive information to us via email. If you choose to do so, it is at your own risk. Credit card information and other sensitive information should never be transmitted via email.

10. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Policy or to comply with legal obligations.

General Retention Periods:

Coaching and Program Data: Retained for up to 12 months after the end of your coaching relationship or program completion, unless you request earlier deletion
Payment and Financial Data: Retained for the period required by applicable financial recordkeeping laws (typically 7 years)
Marketing Communications: Retained until you unsubscribe or request deletion
Account Information: Retained while your account is active or as needed to provide services

You may request deletion of your data at any time by contacting us at support@thriveaxisgroup.com, subject to legal retention requirements.

11. Your Data Rights

You have important rights regarding your personal information:

Right to Access: Request access to the personal data we hold about you and receive a copy of that information.
Right to Correction: Request correction of inaccurate or incomplete data.
Right to Deletion: Request deletion of your personal data, subject to legal retention requirements and legitimate business needs.
Right to Object: Object to data processing for specific purposes, such as direct marketing.
Right to Restriction: Request that we restrict the processing of your data under certain circumstances.
Right to Data Portability: Request that we provide your data in a structured, commonly used format that can be transferred to another service provider.
Right to Withdraw Consent: If you provided consent for data processing, you may withdraw that consent at any time, without affecting the lawfulness of processing that occurred before your withdrawal.

How to Exercise Your Rights:

To exercise any of these rights, please email us at support@thriveaxisgroup.com. We will respond to your request within 30 days.

12. GDPR Rights for EU Residents

If you are within the European Union, you have additional rights under the General Data Protection Regulation (GDPR):

Your GDPR Rights Include:

The right to request access to the data we store
The right to rectify or erase your personal data
The right to seek restrictions on the processing of your data
The right to object to the processing of your data
The right to data portability
The right to lodge a complaint with a supervisory authority in your jurisdiction

Data Processing Basis:

We process your data based on:

Your consent (which you may withdraw at any time)
Performance of a contract with you
Compliance with legal obligations
Our legitimate business interests (balanced against your rights)

Minimal Data Collection:

We require only the information that is reasonably necessary to enter into a contract with you or provide our services. We will not require you to provide consent for any unnecessary processing as a condition of engaging with us.

To exercise your GDPR rights, please email us at support@thriveaxisgroup.com.

13. California Privacy Rights

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA):

The right to know what personal information we collect, use, and disclose
The right to request access to and a copy of your personal information
The right to request correction of inaccurate personal information
The right to request deletion of your personal information, subject to legal exceptions
The right to opt out of the sale or sharing of your personal information
The right not to receive discriminatory treatment for exercising your privacy rights

We do not sell your personal information, and we do not share it for cross-context behavioral advertising in exchange for payment. To exercise your California privacy rights, please email us at support@thriveaxisgroup.com. We will respond within the timeframe required by law.

14. Washington Consumer Health Data

We do not knowingly collect, use, or sell "consumer health data" as defined by the Washington My Health My Data Act. Our Services focus on leadership, professional, and personal development and are not designed to collect health, medical, or biometric information. If you have questions about the information we collect in connection with our Services, please contact us at support@thriveaxisgroup.com.

15. Responsible AI Use

We provide details on our use of AI in our AI Usage Policy. We are committed to the ethical and responsible use of artificial intelligence technologies in our services:

Transparency:

You will be informed when AI tools are used to process your data
We explain how AI-generated insights are created and used
We are clear about the limitations of AI systems

Human Oversight:

All AI-generated insights, recommendations, and assessments are reviewed by certified coaches and trained professionals
AI is designed to augment, not replace, human expertise and judgment
Your coach maintains final decision-making authority on all development recommendations

Accountability:

We ensure AI outputs align with your specific goals and context
We monitor AI systems for accuracy, fairness, and potential bias
We continuously evaluate and improve our AI tools based on outcomes and feedback

Privacy by Design:

AI systems are built with safeguards to support data privacy and security
We limit AI access to only the data necessary for generating insights
We do not use your data to train general AI models without your explicit consent

Your Control:

You can opt out of AI-enhanced features if you prefer traditional coaching approaches
You can request a human review of any AI-generated recommendation
You maintain control over how your data is used in AI systems

16. Links to Other Sites

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

17. Policy Changes and Updates

We reserve the right to update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other relevant factors.

When we make changes, we will update the "Last Updated" date at the bottom of this page and post the revised Policy on our Website. Any changes become effective when the updated Policy is posted.

You are responsible for periodically reviewing this Privacy Policy for any changes. Your continued use of our Services after changes are posted indicates your acceptance of the updated Privacy Policy.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, or if you would like to exercise your data rights, please contact us:

CLP Ventures, LLC dba ThriveAxis®

16420 SE McGillivray Blvd., Ste. 103/912 Vancouver, WA 98683

Email: support@thriveaxisgroup.com Website: www.thriveaxisgroup.com

Effective Date: August 2018

Last Updated: July 1, 2026