Privacy Policy

Privacy Policy and Personal Data Processing Policy

Website: longwardleadership.com
Effective Date: September 11, 2026

LONGWARD respects the privacy of the people who visit our Website, contact us, engage with our content, or do business with us.

This Privacy Policy explains how personal information is collected, used, disclosed, protected, and otherwise processed in connection with longwardleadership.com and related business interactions.

LONGWARD is currently operated by Fractal Design SAS, a company organized under the laws of Colombia.

For purposes of applicable data-protection laws, Fractal Design SAS may act as the entity responsible for determining the purposes and means of processing personal information in connection with the Website and its own business activities.

Responsible Entity: Fractal Design SAS
Brand: LONGWARD
Country: Colombia
NIT: 900.909.539-5
Registered Address: CR 22 16 04 CA 32
Telephone: +57 3108372946
Email: [email protected]
Website: https://longwardleadership.com

1. Scope

This Policy applies to personal information collected through:

  • longwardleadership.com;

  • Website forms and inquiries;

  • business communications with LONGWARD;

  • marketing and commercial interactions;

  • requests for information about LONGWARD products and services;

  • commercial transactions and relationships where LONGWARD acts as the relevant business or service provider; and

  • information received from authorized commercial representatives, partners, service providers, or other legitimate sources.

Certain LONGWARD assessments, diagnostics, or professional services — including services involving candidates, employees, leaders, or other assessment participants — may involve additional personal information and different processing relationships.

Those activities may be governed by a separate assessment or participant privacy notice, client agreement, data-processing agreement, consent, or other applicable terms. Where a specific notice or agreement applies, it will govern the processing covered by that document.

2. Personal Information We May Collect

Depending on how you interact with LONGWARD, we may collect the following categories of information.

Information You Provide

This may include:

  • name;

  • business email address;

  • telephone number;

  • company or organization;

  • job title or professional role;

  • country or location;

  • information contained in messages, inquiries, or forms;

  • information you provide when requesting or purchasing a service;

  • communications and correspondence with LONGWARD; and

  • other information you voluntarily provide.

Please do not submit highly sensitive personal information, regulated health information, privileged information, financial credentials, passwords, or other information requiring special protection through a general Website contact form unless LONGWARD has specifically requested it through an appropriate process.

Information Collected Automatically

When you visit the Website, certain information may be collected automatically through cookies and similar technologies, including:

  • IP address;

  • browser and device information;

  • operating system;

  • pages viewed;

  • approximate geographic information derived from IP address;

  • referring or exit pages;

  • date and time of access;

  • Website interactions;

  • cookie or device identifiers; and

  • analytics or advertising information where permitted by your choices and applicable law.

Information From Business and Commercial Sources

LONGWARD may also receive information from:

  • clients;

  • prospective clients;

  • authorized commercial representatives;

  • collection or payment agents;

  • professional contacts;

  • referral sources;

  • business partners;

  • vendors;

  • publicly available professional sources; and

  • other persons or organizations with a lawful basis to provide the information.

3. How We Use Personal Information

We may use personal information to:

  • respond to inquiries and requests;

  • communicate with prospective and existing clients;

  • provide information about LONGWARD and its services;

  • evaluate and develop potential business relationships;

  • prepare proposals, orders, agreements, or commercial communications;

  • provide contracted services;

  • manage client and business relationships;

  • coordinate with authorized commercial representatives;

  • process, document, reconcile, or administer transactions and payments;

  • provide customer support;

  • operate, maintain, secure, troubleshoot, and improve the Website;

  • understand how visitors use the Website;

  • measure the effectiveness of content, communications, or marketing;

  • protect against fraud, abuse, security incidents, and unauthorized activity;

  • maintain business, accounting, legal, and compliance records;

  • establish, exercise, or defend legal rights;

  • comply with applicable legal or regulatory obligations; and

  • pursue other purposes disclosed at the time information is collected or authorized by the individual.

Where required by applicable law, we rely on an appropriate legal basis for processing, which may include consent, performance of a contract, steps requested before entering into a contract, compliance with legal obligations, or legitimate business interests that are not overridden by applicable privacy rights.

4. Cookies and Similar Technologies

LONGWARD uses cookies and similar technologies to operate the Website and, subject to applicable requirements and your choices, to understand Website usage, measure performance, and support marketing activities.

Cookies may include:

  • Essential cookies, required for core Website functions and security;

  • Functional cookies, which support additional Website functionality;

  • Analytics cookies, which help us understand Website usage and performance; and

  • Advertising or marketing technologies, where used, which may help measure or improve marketing campaigns.

Where consent is required, optional technologies are controlled through our cookie-consent system.

You may accept, reject, or modify available cookie categories through the Cookie Settings controls on the Website.

LONGWARD may use Google Consent Mode or similar technologies to communicate consent choices to integrated services. Consent Mode does not replace this Privacy Policy or your ability to manage available cookie choices.

For additional details about cookies currently used on the Website, please refer to the Website’s cookie settings or Cookie Policy, where available.

5. Commercial Representatives and Collection Agents

LONGWARD may use independent commercial representatives, business partners, or collection agents to support activities such as:

  • identifying prospective clients;

  • communicating with prospective clients;

  • presenting LONGWARD services;

  • supporting commercial negotiations;

  • coordinating purchases;

  • maintaining client relationships; and

  • collecting or facilitating payments on behalf of LONGWARD.

These parties may receive or process personal information reasonably necessary to perform their authorized functions.

The use of an authorized commercial representative or collection agent does not, by itself, transfer ownership of LONGWARD products, methodologies, intellectual property, or client services to that representative.

The contractual identity of the service provider and other relevant commercial terms will be identified in the applicable proposal, order form, agreement, invoice, or other transaction documentation.

6. How We Disclose Personal Information

LONGWARD may disclose personal information to the following categories of recipients when reasonably necessary:

Service Providers

Companies or individuals that support functions such as:

  • Website hosting;

  • Website administration;

  • cloud storage;

  • email;

  • communications;

  • customer relationship management;

  • analytics;

  • cybersecurity;

  • information technology;

  • payment processing;

  • accounting;

  • legal or professional services; and

  • other business operations.

Commercial Representatives and Business Partners

Authorized independent representatives, referral partners, commercial partners, or collection agents may receive information necessary to support an existing or prospective commercial relationship.

Clients and Organizations

Where a person participates in a LONGWARD service sponsored, requested, or purchased by an organization, information relating to that service may be provided to the relevant organization as described in the applicable assessment notice, agreement, authorization, or service terms.

Legal and Protective Disclosures

Information may be disclosed when reasonably necessary to:

  • comply with applicable law, regulation, legal process, or governmental request;

  • enforce agreements or protect legal rights;

  • detect or prevent fraud or security incidents;

  • protect LONGWARD, its clients, users, personnel, or others; or

  • establish, exercise, or defend legal claims.

Corporate Transactions

Information may be transferred in connection with a merger, acquisition, financing, restructuring, sale of assets, creation of a successor LONGWARD entity, or other legitimate corporate transaction, subject to applicable law.

7. Sale, Sharing, and Targeted Advertising

LONGWARD does not sell personal information for monetary consideration as part of its ordinary business model.

Certain analytics or advertising technologies, if used, may involve disclosures that some U.S. privacy laws characterize as a “sale,” “sharing,” or use for targeted advertising even when no money is exchanged for the information.

Where applicable law provides an opt-out right for such processing, LONGWARD will provide an appropriate mechanism to exercise that right.

Website visitors may also control available optional analytics and advertising technologies through our Cookie Settings.

8. Payments

Payments may be processed or collected by third-party payment providers, financial institutions, or authorized collection agents.

LONGWARD generally does not need to receive or store complete payment-card credentials when those credentials are processed directly by an authorized payment provider.

LONGWARD may nevertheless receive transaction-related information such as:

  • client identity;

  • amount;

  • date;

  • invoice or transaction reference;

  • payment status; and

  • other information necessary for accounting, reconciliation, compliance, or administration.

Payment providers and financial institutions may process information under their own privacy policies and legal obligations.

9. International Processing and Transfers

LONGWARD operates internationally.

Personal information may therefore be processed in Colombia, the United States, or other countries where LONGWARD, its commercial representatives, clients, or service providers operate.

Privacy and data-protection laws may differ between jurisdictions.

Where applicable law requires specific protections for international transfers or transmissions of personal information, LONGWARD will take reasonable steps to implement the legally required safeguards or contractual arrangements.

10. Data Security

LONGWARD uses reasonable administrative, organizational, contractual, and technical measures designed to protect personal information against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

No Internet transmission, electronic system, or method of storage can be guaranteed to be completely secure.

Accordingly, LONGWARD cannot guarantee absolute security, but seeks to apply safeguards appropriate to the nature of the information and the circumstances of the processing.

11. Data Retention

LONGWARD retains personal information for no longer than reasonably necessary for the purposes for which it was collected, including as necessary to:

  • maintain business relationships;

  • perform services;

  • respond to requests;

  • maintain appropriate business and transaction records;

  • comply with contractual obligations;

  • satisfy legal, accounting, tax, regulatory, or reporting requirements;

  • resolve disputes;

  • enforce agreements; and

  • protect legitimate business and legal interests.

Different categories of information may be subject to different retention periods.

When information is no longer reasonably required, LONGWARD may delete, anonymize, aggregate, or securely archive it as permitted or required by applicable law.

12. Marketing Communications

LONGWARD may send professional or commercial communications where legally permitted.

You may request to stop receiving marketing emails by using any unsubscribe mechanism provided in the communication or by contacting us at:

[email protected]

Stopping marketing communications does not prevent LONGWARD from sending non-promotional communications that are reasonably necessary in connection with an existing transaction, service, contractual relationship, legal matter, or request.

13. Your Privacy Rights

Depending on your jurisdiction and the circumstances of the processing, you may have rights concerning your personal information.

These may include the right to:

  • request access to personal information;

  • know what information is being processed;

  • request correction or updating of inaccurate information;

  • request deletion or suppression where legally available;

  • withdraw or revoke consent where processing depends on consent;

  • object to or restrict certain processing;

  • request portability of certain information;

  • opt out of certain targeted advertising, sale, sharing, or profiling activities where applicable;

  • obtain information about categories of recipients;

  • submit a complaint to an appropriate supervisory or regulatory authority; and

  • exercise legally protected privacy rights without unlawful discrimination.

These rights are not absolute and may be subject to legal exceptions, verification requirements, contractual obligations, or retention requirements.

To submit a privacy request, contact:

[email protected]

Please include enough information for LONGWARD to understand and reasonably verify the request.

We may request additional information where reasonably necessary to verify identity or authority before responding.

14. Rights Under Colombian Data-Protection Law

Where Colombian data-protection law applies, including Law 1581 of 2012 and its implementing regulations, data subjects may have the right to:

  • know, update, and rectify their personal information;

  • request evidence of authorization where authorization is legally required;

  • be informed about the use made of their personal information;

  • submit complaints to the Superintendencia de Industria y Comercio after satisfying applicable procedural requirements;

  • revoke authorization and/or request deletion where legally permitted; and

  • access their personal information free of charge in the circumstances provided by law.

Consultations

Requests to consult personal information may be submitted to:

[email protected]

Where Colombian law applies, qualifying consultations will be handled within the periods established by applicable law, generally within ten (10) business days from receipt, subject to any legally permitted extension.

Claims, Corrections, Updates, or Deletion Requests

A request concerning correction, updating, deletion, revocation of authorization, or an alleged breach should include, as applicable:

  • identification of the data subject;

  • a description of the request or circumstances giving rise to the claim;

  • contact information for the response; and

  • supporting documents, if relevant.

Where Colombian law applies, qualifying claims will be handled within the legally prescribed period, generally fifteen (15) business days from the applicable starting point, subject to legally permitted extensions.

Where required under Colombian law, a complaint before the Superintendencia de Industria y Comercio may be submitted after the applicable consultation or claim procedure before LONGWARD has been completed.

15. Sensitive Personal Information

LONGWARD does not request sensitive personal information through its general Website contact forms unless there is a specific and legitimate reason to do so through an appropriate process.

Where LONGWARD needs to process information considered sensitive under applicable law, additional disclosures, authorization, contractual protections, or safeguards may apply.

Specific assessments or professional services may require a separate privacy notice explaining the information involved and the purposes for which it will be processed.

16. Assessment and Candidate Information

LONGWARD offers assessment, diagnostic, leadership, and organizational services that may involve information about candidates, employees, leaders, or other participants.

The handling of such information depends on the particular service, the sponsoring client, the role of LONGWARD, the purpose of the assessment, and applicable law.

Accordingly:

  • this general Website Privacy Policy does not replace any specific assessment or participant privacy notice;

  • LONGWARD may act in different legal capacities depending on the service and jurisdiction;

  • clients may have separate responsibilities regarding notices, lawful bases, employment decisions, recordkeeping, and individual rights; and

  • specific information-sharing, retention, and use rules may be established in the applicable service documentation.

LONGWARD does not authorize the use of personal information obtained through an assessment for purposes unrelated to the legitimate purpose for which the assessment was conducted, except where permitted by applicable law or appropriately authorized.

17. Children

The Website and LONGWARD’s business services are intended for professional and business audiences and are not directed to children under 13.

LONGWARD does not knowingly seek to collect personal information online directly from children under 13 through the general Website.

If we learn that personal information has been collected through the Website from a child in circumstances requiring parental consent under applicable law, we will take appropriate steps to address the information.

18. Third-Party Websites and Services

The Website may contain links to websites, services, publications, platforms, or other resources operated by third parties.

LONGWARD does not control the privacy or security practices of those third parties.

Information provided directly to a third party is governed by that third party’s privacy practices and terms.

19. Changes to This Privacy Policy

LONGWARD may update this Privacy Policy from time to time to reflect changes in:

  • our business;

  • technology;

  • Website functionality;

  • service providers;

  • data practices;

  • organizational structure; or

  • applicable legal requirements.

The Effective Date at the beginning of this Policy will be updated when changes are made.

Where applicable law requires additional notice or consent for a material change, LONGWARD will take appropriate steps before applying that change.

20. Contact and Privacy Requests

Questions, consultations, claims, or requests concerning this Privacy Policy or LONGWARD’s processing of personal information may be directed to:

LONGWARD
Operated by Fractal Design SAS
NIT: 900.909.539-5
Address: CR 22 16 04 CA 32
Colombia
Telephone: +57 3108372946
Email: [email protected]
Website: longwardleadership.com

The person or function responsible for receiving privacy and personal-data requests may be contacted through the email address above.

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