Privacy Policy

This Privacy Policy covers ITT Publishing Inc.'s websites, including ittpublishing.com and ittmedia.ai, and its hosted Experiences and related services, subject to any more specific notice presented at collection. ITT Publishing Inc. ("ITT Publishing," "we," "us," or "our") is committed to protecting your privacy. This policy explains how we collect, use, disclose, and safeguard your information when you visit our websites and use our digital reading platform, hosted Experiences, and related services (collectively, the "Service"). Please read it carefully. If you do not agree with its terms, please discontinue use of the Service.

Our principal place of business is:
ITT Publishing Inc.
425 Huehl Road #11B
Northbrook, IL 60062
United States

Our Privacy Promises

1. Information We Collect

a. Information You Provide Directly

• Account registration information (name, email address, password)
• Billing and payment information (processed securely by third-party payment processors; we do not store full card numbers)
• Communications you send us (contact form submissions, support inquiries, writer submissions)
• Profile preferences and reading settings

b. Voluntary Reflections and Experience Responses

When you participate in an Experience, you may voluntarily submit reflections, Carry It Forward™ responses, group conversation summaries, and follow-up survey answers. These responses are provided at your discretion. Because reflections may naturally reference your thoughts, feelings, health, beliefs, or other personal matters, they may incidentally include sensitive or "special category" personal data. We process such data only to produce the reflection summaries and aggregated organizational reports you have requested, and we do not use it to profile or make automated decisions about you. Where sensitive data is processed on the basis of consent under GDPR, you may withdraw that consent at any time without affecting the lawfulness of processing already carried out.

c. Information Collected Automatically

• Log data (IP address, browser type, pages visited, time spent, referring URLs)
• Device information (operating system, device type, screen resolution)
• Reading activity (stories opened, pages read, language preference)
• Cookies and similar tracking technologies (see Section 7)

d. Information from Third Parties

We may receive information from payment processors, authentication providers, and analytics services in connection with your use of the Service.

2. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the Service
• Process transactions and send related information, including purchase confirmations and invoices
• Manage your account and personalize your reading experience
• Generate reflection summaries and aggregate organizational reports from Experience responses
• Send administrative communications (security alerts, service updates, policy changes)
• Send Carry It Forward™ reminders and follow-up surveys where you have requested them
• Send marketing and promotional communications (you may opt out at any time)
• Respond to inquiries and provide customer support
• Monitor and analyze usage trends to improve the Service
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Comply with legal obligations under the laws of the State of Illinois and applicable federal law

3. Legal Bases for Processing (GDPR)

To the extent the EU/UK General Data Protection Regulation (GDPR) applies, we rely on the following legal bases for processing your personal information:

• Contract: processing necessary to provide the Service you requested, including account management, reading, and Experience participation.
• Legitimate interests: processing for fraud prevention, security, service improvement, and aggregate reporting, where those interests are not overridden by your rights.
• Consent: processing of voluntary reflections that include sensitive personal data, marketing communications, and certain cookies, where you have given consent. You may withdraw consent at any time.
• Legal obligation: processing to comply with applicable law, such as tax and recordkeeping requirements.

Controllers and representatives

For personal data we collect and control directly (for example, account, billing, and direct communications), ITT Publishing Inc. is the controller. For personal data collected within a hosted Experience that a sponsoring organization configures and directs (for example, the organization's participant roster, group configuration, and the organizational reports it receives), the sponsoring organization may act as a separate controller for those purposes, and ITT Publishing acts as a processor on its behalf. Where a sponsoring organization is a controller, you should direct privacy requests about that data to the organization, as described in Section 8.

Our controller contact is privacy@ittpublishing.com. Where GDPR requires an EU/UK representative, we will provide its contact details here once appointed; until then, EU/UK residents may contact us directly at the address above.

4. How We Share Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information with:

• Sponsoring organizations (aggregated only): We provide sponsoring organizations with aggregate, group-level reports from Experience responses. We do not provide participant contact details to sponsoring organizations for their independent use, and our reporting is designed to avoid identifying individuals.
• Service providers and subprocessors: Third-party vendors who assist us in operating the Service (e.g., payment processors, email and SMS delivery, cloud hosting, analytics, AI summarization). These parties are bound by confidentiality and data-processing obligations and may only process personal data on our instructions. Categories of subprocessors are described in Section 5.
• Legal requirements: When required by law, subpoena, or other legal process, or when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud or abuse.
• Business transfers: In connection with a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as a business asset.
• With your consent: We may share your information for any other purpose with your explicit consent.

5. International Transfers and Processors

The Service is hosted in the United States. When we process personal data of individuals outside the United States, that data may be transferred to, stored in, or processed in the United States and other countries where our service providers operate. We take steps to ensure appropriate safeguards are in place for such transfers, including contractual data-protection terms with our subprocessors.

We have not verified, and do not claim, that any particular transfer relies on an adequacy decision, executed Standard Contractual Clauses, or a specific certification. We will provide further detail on the applicable transfer safeguards on request and will update this section as our arrangements are confirmed.

Categories of subprocessors

• Cloud hosting and infrastructure (United States)
• Payment processing
• Email and SMS delivery for reminders and follow-ups
• Analytics and usage measurement
• AI-based summarization for reflection and report generation
• Authentication providers

A current list of named subprocessors is available on request.

6. Organizational Reports and Anonymization

We generate several categories of organizational reports from Experience responses, including:

• Aggregate engagement metrics (participation counts, completion rates, engagement scores)
• Group-level reflection summaries and themes
• Carry It Forward™ aggregate follow-up summaries
• Conference and event impact summaries

These reports are designed to present group-level insights rather than identify individuals, and we apply minimum group-size thresholds and suppression controls to reduce reidentification risk. We do not represent that any reporting technique is irreversible or guarantees anonymity, and we have not completed technical reidentification testing of every report type. Where a disclosure is legally required or necessary to protect safety or investigate abuse, individually identifiable information may be disclosed as described in this policy.

7. Cookies, Analytics, and Tracking Technologies

We use cookies and similar technologies to enhance your experience, remember preferences, analyze usage, and deliver relevant content. You may control cookie settings through your browser. Note that disabling cookies may affect the functionality of the Service. We do not currently respond to "Do Not Track" signals.

For visitors in the EU and UK, non-essential analytics and marketing cookies require your consent before they are set. Where a consent mechanism is not yet presented, we rely only on strictly necessary cookies and otherwise limit tracking to what is essential for the Service to function. We are reviewing our analytics and cookie-consent implementation for EU/UK visitors and will update this notice once that review is complete.

8. Data Retention

We retain personal information only as long as necessary for the purposes described in this policy, subject to legal exceptions. Retention varies by category:

• Account information: retained while your account is active and for a limited period after closure to allow recovery, respond to disputes, and meet legal obligations.
• Raw reflections and Experience responses: retained for the life of the associated Experience and a defined period thereafter to support reporting, follow-up, and legal holds, then deleted or anonymized.
• Aggregate organizational reports: retained according to the sponsoring organization's instructions and applicable contract terms.
• System logs: retained for a limited operational period for security, troubleshooting, and abuse prevention.
• Backups: retained according to our backup schedule; data deleted from the live Service may persist in backups for a limited time before being overwritten.
• Payment and billing records: retained as required by tax, accounting, and financial-records laws.

When you delete your account, we will delete or anonymize your personal data according to the schedule above, except where retention is required by law or to establish, exercise, or defend legal claims. This replaces any prior statement of an unconditional deletion period.

9. Your Rights and Choices

Depending on your location, you may have the right to:

• Access a copy of your personal information
• Correct inaccurate personal information
• Delete your personal information, subject to legal exceptions
• Object to or restrict certain processing of your data
• Withdraw consent where processing is based on consent
• Receive a portable copy of your data in a structured, commonly used format
• Opt out of marketing emails by clicking "unsubscribe" in any email or contacting us directly

To exercise these rights, contact us at privacy@ittpublishing.com. We will respond within the period required by applicable law. Where your personal data is processed by ITT on behalf of a sponsoring organization (for example, Experience participant data the organization controls), some requests, including access, deletion, correction, objection, and portability, may need to be directed to that organization rather than to us; we will inform you when this applies and help you identify the appropriate contact where we can.

10. Security

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information. However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security and encourage you to use a strong, unique password for your account.

Breach response and notification

We maintain internal breach-response procedures to identify, contain, and assess security incidents. Where a personal-data breach is likely to result in a risk to your rights and freedoms, we will document the incident and notify the competent supervisory authority and, where required, affected individuals, in accordance with applicable statutory notification timelines.

11. Children's and Minors' Privacy

The Service is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

Some organizational Experiences may include participants who are minors, such as students or youth program members. We are reviewing whether age 13 is the appropriate threshold for such programs. Where a participant is a minor, we rely on parental or guardian consent, or consent from the participating institution or organization that is authorized to provide it, before collecting reflections or other personal data. If you believe a minor's data has been collected without appropriate consent, please contact us and we will take steps to address it.

12. Third-Party Links

The Service may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their respective privacy policies.

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of Illinois, USA, without regard to its conflict of law provisions, except where EU/UK mandatory data-protection law requires otherwise.

14. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. We will notify you of material changes by posting the new policy on this page with an updated effective date and, where appropriate, by sending you an email notification. Your continued use of the Service after changes become effective constitutes your acceptance of the revised policy.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

ITT Publishing Inc.
425 Huehl Road #11B
Northbrook, IL 60062
Email: privacy@ittpublishing.com