Privacy Policy

Jonathan D. Reynolds is the sole owner of the HOLD framework, The Inner Ceiling intellectual property, and the Platform at innerceiling.com. Questions about this Privacy Policy may be directed to: jonathan@mail.innerceiling.com.

2.1 Information you provide directly

• Name: used to personalize your dashboard and any communications with you.
• Email address: used to create and access your account, send your magic link to sign in, and optionally send annual retake reminders.
• Self-assessment responses: your answers to the forty HOLD self-assessment questions (twenty Insight questions and twenty Action questions), answered on a scale of 1 to 5. These are stored privately and associated with your account.
• Purpose statement and growth edge statement: the two written statements you complete before sharing your trusted circle code. These are stored in your account and included in the invitation message you choose to send.
• Optional context fields: during onboarding, you may choose to provide your approximate team size, industry or sector, and years in your current leadership role. These fields are entirely optional and are used only for aggregate, anonymized research described in Section 5.

2.2 Trusted circle response data

When someone completes the twenty-question observed assessment using your unique code, we collect their responses and, if they choose to provide it, their name and selected relationship category (current leader or mentor, peer, current direct report, former direct report, or prefer not to say). The following applies to this data without exception:

• Individual trusted circle responses are never shared with you in their individual, identifiable form. You see only aggregate scores.
• Relationship category breakdowns on your dashboard are only displayed when at least two people within the same category have responded. This minimum threshold protects individual respondents from being identified by their category alone.
• Your scores are never shared with the people who rated you. They cannot see your results.

2.3 Optional research survey data

After submitting their observed assessment, trusted circle respondents are offered five optional questions framed as an anonymous research contribution. These questions are not about the leader being rated and are entirely voluntary. If a respondent chooses to answer them, their responses are stored in a completely separate data table with no connection to any identifiable leader or respondent record. This data is used only in anonymized aggregate form for research purposes. It is never surfaced on any user-facing dashboard and is never used to make decisions about individual leaders or respondents.

2.4 Technical and usage data

When you use the Platform, we automatically collect limited technical information including your IP address, browser type, device information, and pages visited. This information is used solely to maintain and improve the Platform's security and functionality. It is not used for advertising or sold to any third party.

We use the information we collect for the following purposes only:

1. 1.To create and maintain your account and allow you to return to your dashboard.
2. 2.To calculate and display your assessment scores and the gap measures between them.
3. 3.To generate an AI-assisted draft of your growth edge statement, using only your own lowest-scoring action responses as input. This call is made to the Anthropic API and no identifiable information is transmitted except the anonymous question text and scores.
4. 4.To match trusted circle responses to your unique code and display aggregate results on your dashboard.
5. 5.To send you transactional emails: your sign-in link and, if you have opted in, an optional annual retake reminder.
6. 6.To conduct anonymized aggregate research that may inform future versions of the HOLD framework, future publications, and the development of the certified practitioner program. No individual is ever identifiable in any research output or publication.
7. 7.To maintain the security and performance of the Platform.

We want to be explicit about practices that this Platform will never engage in:

• We will never sell, rent, or license your personal information or assessment data to any third party.
• We will never share your individual scores, responses, or statements with any employer, organization, coach, or third party without your explicit written consent.
• We will never use your assessment data for advertising targeting, behavioral profiling, or any commercial purpose other than providing you with the Platform's core services.
• We will never share your data with any certified practitioner of the HOLD framework without your explicit written consent.
• We will never combine your assessment data with publicly available information to build profiles about you without your consent.
• We will never make your data available to any artificial intelligence training pipeline without your explicit, specific consent.

Jonathan D. Reynolds is building a research foundation for the HOLD framework using data generated by Platform users in aggregate. All research outputs and publications will contain only anonymized, aggregate information. No individual leader, respondent, or organization will be identifiable in any research output. The research may produce findings about how different groups of leaders score across the HOLD elements, how gaps between self-reported and observed scores vary across relationship types or industries, and how scores change over time with annual retakes.

Participating in the Platform constitutes consent to the use of your anonymized, de-identified data for these research purposes. If you wish to opt out of research data use entirely while continuing to use the Platform, please contact us at jonathan@mail.innerceiling.com and we will remove your data from the research pipeline.

We use a small number of trusted third-party service providers to operate the Platform. Each provider is contractually bound to use your data only as necessary to provide their services to us and not for any independent commercial purpose:

• Supabase: provides the database and authentication infrastructure. Your data is stored in Supabase's secure cloud environment.
• Lovable: provides the hosting and content delivery infrastructure for the Platform.
• Resend: provides transactional email delivery for sign-in links and optional reminders.
• Anthropic: provides the AI model used to generate the optional growth edge statement draft. Only anonymous question text and scores are transmitted to generate this draft. No name, email, or account information is included in the transmission.

We do not use any advertising networks, social media tracking pixels, or behavioral analytics tools on the Platform.

The Platform uses only essential cookies necessary to maintain your authenticated session. We do not use advertising cookies, behavioral tracking cookies, or third-party analytics cookies. You may disable cookies in your browser settings, but doing so may prevent you from staying signed in to your account.

We implement industry-standard security practices to protect your information, including encrypted data transmission (HTTPS), row-level security rules that prevent any user from accessing another user's data, and secure authentication through magic link sign-in. We do not store passwords. Despite these measures, no digital system is entirely immune from breach, and we cannot guarantee absolute security. We will notify affected users promptly in the event of a security incident involving their personal data.

We retain your account data, assessment responses, and scores for as long as your account remains active or until you request deletion. Trusted circle responses are retained for the same period as the associated leader account. Anonymous research survey data is retained indefinitely in aggregate, anonymized form. If you delete your account, all identifiable data associated with your account will be permanently deleted within 30 days. Anonymous research data derived from your responses will remain in the aggregate research dataset in de-identified form.

You have the following rights with respect to your personal information:

To exercise any of these rights, contact us at jonathan@mail.innerceiling.com. We will respond to all requests within 30 days. We will never discriminate against you for exercising your privacy rights.

The Platform is intended for adults in leadership roles and is not directed at children under the age of 16. We do not knowingly collect personal information from anyone under 16. If we become aware that we have collected data from a user under 16, we will delete it promptly.

The Platform is operated from the United States. If you are accessing it from the European Union, United Kingdom, Canada, Australia, or any other jurisdiction with data protection laws, please be aware that your information will be transferred to and processed in the United States. We process this data in accordance with the practices described in this Privacy Policy. If you are an EU or UK user, you may also have rights under the General Data Protection Regulation (GDPR) or UK GDPR including the rights described in Section 10 above. Our lawful basis for processing your data is your consent, given when you create an account and use the Platform.

We may update this Privacy Policy as the Platform evolves. We will notify you of material changes by email and by posting the updated policy on the Platform with a new effective date. Continued use of the Platform after notification of changes constitutes acceptance of the updated policy.

Questions, requests, or concerns about this Privacy Policy should be directed to: jonathan@mail.innerceiling.com. We are committed to responding within 30 days of receiving any privacy-related inquiry.

This Privacy Policy was drafted specifically for innerceiling.com and the HOLD Assessment. It has been reviewed for alignment with applicable US privacy laws including the California Consumer Privacy Act (CCPA) and international frameworks including GDPR. Jonathan D. Reynolds recommends that users in jurisdictions with specific local privacy requirements consult the applicable regulatory guidance for their region.