Privacy Policy

Touchpoint Dashboard is a division of Strativity Group, LLC, which is a division of Kelton Research, LLC. This privacy policy applies to all personal data Touchpoint Dashboard (also referred to below as “we” “our” and “us”) collects from all users, including EU and Swiss citizens, in the course of conducting its business, including through its websites (collectively, the “Website”), and covers all the information that may have been loaded onto the Touchpoint Dashboard platform by a Touchpoint Dashboard client or stored on Touchpoint Dashboard’s network belonging to or relating to such persons. This policy does not apply to information which we might collect from our employees, job applicants, or independent contractors.

Touchpoint Dashboard is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website or should any personal data about you be loaded onto our platform by one of our clients, then you can be assured that it will only be used in accordance with this privacy statement.

This privacy policy was last updated on January 19, 2021.

Privacy Shield

As a division of Kelton Research, LLC (“Kelton”), Touchpoint Dashboard complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from the European Union and the United Kingdom and Switzerland to the United States, respectively. Kelton has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Kelton commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, British, or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Kelton at:

Kelton Research, LLC
1900 Avenue of the Stars, 16th Floor
Los Angeles, CA 90067

Kelton has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Investigatory and Enforcement Powers of the Federal Trade Commission
Kelton is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Personal Data That We Collect

We operate a customer journey mapping platform where our clients can track and map the evolution of their relationship with their various clients or customers.  We generally would collect personal data about an individual either where (i) an individual is, or works for, one of our clients and has provided his or her personal data to us in connection with administration of his or her Touchpoint Dashboard account or the administration of our own contractual relationship with the person or the person’s employer, or (ii) our client has inputted or loaded personal data relating to individuals working for its own clients or customers onto our platform in connection with our client’s use of our platform.

If you are a Touchpoint Dashboard client or work for a Touchpoint Dashboard client, we may collect some or all of the following information from you in the course of administering our relationship with you or your employer:

  • Name, job title, email address and other contact information
  • Demographic information such as ZIP/postal code, preferences and interests
  • Other information relevant to customer surveys and/or offers

In these cases, our legal basis for the collection and processing of the information is your consent, as well as our legitimate interest to perform our obligations under our contract with you or the company for which you work.

If you or your employer are not a Touchpoint Dashboard client and we have received your personal data by way of that information having been inputted into our platform by our client as part of the functionality of the platform, then our legal basis for the processing of the information is our legitimate interest to perform our obligations under our contract with the client loading the data onto our platform.

The Website also collects personal data from you that you specifically and voluntarily provide to us as you use the Website. Such information might include your name, company affiliation, job title, email address, country of residence as well as other types of information. You may choose to provide such information to us in order to request a demo or quote, subscribe for newsletters or to access other products or services provided by us and our business partners. If you choose to purchase any products or services through the Website, you may also be asked to provide us with your payment information as a condition to such purchase. If you contact us, for example by sending us an email, we may retain copies of your correspondence (including your email address). In these cases, our legal basis for collection and processing of your personal data is consent; we do not collect personal data without the affirmative consent of the research participant. Consent can be withdrawn at any time.

As you navigate through the Website, we may also collect standard internet log information, including your IP address, operating system, browser type, language, access times and referring website addresses through service providers such as Google Analytics and Google Advertising. We may collect this information to enhance the Website, facilitate improved navigation and personalize advertising, which includes remarketing, demographic and location targeting. For these purposes, we (or our services providers) may also obtain information about your general internet usage by using cookies.

A cookie is a small file stored on the hard drive of your computer. Use of cookies help us to improve the Website and to deliver a better and more personalized service. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you direct your browser to the Website. Google offers a Google Analytics Opt-out Browser Add-on and you may also opt out of Google Advertising’s use of cookies by visiting Google’s Ads Settings.

Pages of the Website may contain electronic images known as web beacons that permit us to count users who have visited those pages and for other related website statistics. Web beacons are not used to access your personal information on the Website and are only used to compile aggregated statistics concerning use of the Website. Currently, our systems do not respond to browser do-not-track signals, and we do not treat such do-not-track signals as “do not sell” signals under CCPA (as defined below).

How We Use Your Personal Data

Depending on how we obtain your personal data (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data.  If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.

If you are a client, client representative or employee, we use the information we collect from you for the following purposes:

  • Internal record keeping.
  • To present the Website and its contents in a suitable and effective manner.
  • To provide you with information, products or services that you request from us.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you or your employer and us, including for billing and collection.
  • To improve our products and services.
  • To notify you about changes to our service.
  • To allow you to participate in interactive features of our service or market research, when you choose to do so.
  • To periodically send communications on new products, special offers or other information.
  • In any other way we may describe when you provide the information.

If you are not our client, and your information has been provided to us by our client in connection with our client’s use of the Touchpoint Dashboard platform, then we solely process the information as directed by our client in the course of its use of the Touchpoint Dashboard platform.  We do not rent, sell or give this personal data to any third party for the purpose of directly marketing any products or services, or otherwise make any use of this data.  We do not “sell” personal data as defined under the California Consumer Privacy Act (“CCPA”), and have not done so in the preceding 12 months.  We also do not “sell” (as defined in CCPA) personal information of persons under 16 without affirmative authorization, or otherwise.

In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and the Swiss-US Privacy Shield, Kelton is potentially liable.

In all cases, we will take reasonable steps to ensure the personal data is accurate, complete, current and relevant and being used only for the intended purposes. We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.

Disclosure of Your Information

We may disclose personal data that we receive or collect about you (as described above) to contractors and service providers we use to support the mechanical execution of our business. In these cases, we require the third party to follow all of the same privacy protection regulations as followed by us.

In the event of a merger, acquisition, or any form of sale of some or all of Touchpoint Dashboard’s assets, personal data held by us about our clients will be among the assets transferred to the buyer.

We also may be required to disclose an individual’s personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal data to third parties to comply with any court order or other legal obligation or to enforce or apply our terms of use.


Category of consumer personal information collected (non-HR) Source from which collected Purposes for which collected Categories of third parties with whom shared
Name and contact information – website visitor Supplied by person himself/herself Marketing of our own services Technology infrastructure vendors
Username, name, and contact information – account holder Supplied by person himself/herself Administration of service Technology infrastructure vendors
Demographic and personal details – account holder Supplied by person himself/herself Administration of service Technology infrastructure vendors
Materials loaded to platform as part of journey mapping functionality Supplied by account holder Administration of service Technology infrastructure vendors
Name and contact information – client officer Supplied by person himself/herself Administration of business Technology infrastructure vendors
Systems details – visitors to Websites (IP/device ID, browser settings, similar) The computer or device of the person himself/herself Internal analytics; improvement of Website experience Technology infrastructure vendors

All information may also be shared among our affiliated group of companies solely for administrative and operations purposes.

Additional Rights as to Your Personal Data

You have certain rights by law to know certain details regarding our data handling practices generally; this information is described above and elsewhere in this Privacy Policy.  In addition, you have the right to request the following as to any personal data we have about you:  that we provide access to any personal data we hold about you; that we update any of your personal data which is out of date or incorrect; where our basis for processing your personal data is consent, that your consent to further processing be withdrawn; where we received your personal data from a third party, inquire where the data originated; that we delete any personal data which we are holding about you; restrict the way that we process your personal data (including that we not “sell” your personal data as such term is defined in the CCPA); prevent the processing of your personal data for direct-marketing purposes; that we provide, or not provide, your personal data to a third party provider of services; that we provide you with a copy of any personal data which we hold about you; that we consider any valid objections which you have to our use of your personal data; and that you not be discriminated against for exercising any of your privacy rights.  Under applicable law, certain personal data may be exempt from some of these requests in certain circumstances.

If you would like further information about these rights or would like to exercise any of them, including to opt out of the “sale” of your information as defined in the CCPA, please write to us at LRW Group, 1900 Ave of the Stars, 16th Floor, Los Angeles, CA 90067 USA, Attn:  Privacy Officer, email us at, call us at (800) 591-6538, or submit your question or request at

By law, as well as for your protection, if you request that we take certain actions as to personal data we have about you, we are required to take certain steps to verify your identity.  If we are not able to verify your identity, we may not be able to respond to your request.  To verify your identity, we request, at point of submission of your request, that you supply your basic contact information, as well as certain other non-personally identifiable information (e.g., information relating to your last interaction with us, such as subject matter and type of study), and we endeavor to match at least two pieces of this information with information in our possession.  In addition, as to those rights permitted by law to be exercisable by an authorized agent on your behalf, in addition to verifying your identity as described above, we require the agent to also supply written authorization from you to act on your behalf, except where restricted by law.

Note, some of these rights may not be applicable to information which we might collect or process from or about you in your capacity as our employee, job applicant, or independent contractor; there are other laws applicable to those relationships which are not addressed in this Privacy Policy.  If you have any questions, please contact the Legal Department. 

Children Under the Age of 13
The Website is not intended for children under 13 years of age. It is our policy not to knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

Retention of Personal Data

We keep personal data for no longer than necessary for the purposes for which the personal data is collected or processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Information Security

We maintain physical, electronic and procedural security measures to help safeguard client and personal data which are consistent with industry standards and practice and in compliance with applicable law. Third parties that provide us with support or services and that may also receive client or personal data are required by us to maintain security measures similar to ours with respect to such information. We will take reasonable precaution, consistent with industry standards and practice, to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Third Party Links

The Website contains several links to third-party websites. The privacy practices of the companies that operate those websites may differ from ours. We encourage you to read the privacy policy of each site before disclosing any personally identifiable information.

Changes to Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this website. If we make material changes to how we treat the personal data that falls within the scope of our Privacy Policy, we will notify you through a notice on the Touchpoint Dashboard website home page.

The date of the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this Privacy Policy to check for any changes.