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Privacy Policy
Version 1.1 · Last Updated: August 2026 Fellowship Intelligence LLC
Version 1.1 · Last Updated: August 2026 Fellowship Intelligence LLC
Privacy Policy Fellowship Intelligence LLC
Version: v1.1 | Last Updated: August 2026
Fellowship Intelligence LLC ("Fellowship Intelligence," "we," "us," or "our") respects the privacy of individuals who interact with our website, services, and programs. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information obtained through our website, services, and client engagements.
This Privacy Policy applies to information collected through our website, online forms and contact submissions, scheduling and booking tools, email communications and newsletters, and client engagements and diagnostic programs.
By using our website or services, you acknowledge the practices described in this Privacy Policy.
Information that identifies or could reasonably identify an individual, including: name, email address, phone number, company name, job title, and contact information submitted through forms.
Information about organizations interacting with our services, including: company operational information, business processes or workflows voluntarily shared during engagements, diagnostic responses, and governance or operational documentation submitted by clients.
Information automatically collected when interacting with our website or systems, including: IP address, device and browser information, pages visited, referring website, and interaction timestamps.
We may use cookies, analytics tools, and related technologies to understand website performance and visitor behavior. See Section 3 for details on cookie consent.
We collect personal information from the following categories of sources:
Our website and services may use cookies, tracking pixels, analytics tags, and similar technologies to collect usage information. These technologies help us understand website traffic and visitor behavior, improve website performance and usability, measure the effectiveness of marketing or outreach activities, and maintain security and prevent abuse.
We also use a small first-party cookie to support checkout. When a visitor completes the free Decision Ownership Check, we set a signed cookie (fi_gate) recording that completion, so our checkout process can confirm it before a DIY Starter purchase goes through. This cookie contains no personal information, no name, email, or identifying data — it consists of a timestamp, a country code, and a cryptographic signature (HMAC) of those two values, and it is scoped to our domain and persists for up to 180 days.
Visitors from the European Union, United Kingdom, or other jurisdictions subject to applicable cookie consent laws will be presented with a cookie preference mechanism upon first visiting the website. Non-essential cookies, including analytics and marketing cookies, will not be set without your consent. Essential cookies required for basic website functionality may be set without consent. To withdraw consent previously granted, you may clear cookies in your browser settings or contact us directly.
Fellowship Intelligence may offer newsletters, updates, and informational communications, including publications such as The Wrong Default. If you voluntarily subscribe to a newsletter or mailing list, we may use your contact information to send periodic communications related to insights, company updates, or services. Recipients may unsubscribe at any time by using the unsubscribe link in any email or by contacting us directly.
The Wrong Default is hosted and delivered through Substack, Inc. If you take out a paid subscription, your payment information is collected and processed by Substack and its payment processor; Fellowship Intelligence does not receive or store your payment card information. Substack, as the platform operator, also collects and processes your email address and subscription status. Substack's own privacy policy governs its handling of that information.
We may use collected information for the following purposes:
Where applicable law requires a legal basis for processing personal data, Fellowship Intelligence relies on one or more of the following bases: consent provided by the user, performance of a contract or service request, legitimate business interests, and compliance with legal obligations.
Fellowship Intelligence does not sell personal information. We may share information with trusted third-party providers who assist with operating our services, including cloud hosting providers, email and communication platforms, analytics providers, artificial intelligence system providers, and payment processors. These providers process information solely for service delivery purposes and are subject to reasonable confidentiality and data protection obligations.
The specific providers we use are named in Section 17 (Subprocessors and Service Providers) below.
We may also disclose information when required to comply with law, legal process, or regulatory obligations, or when necessary to protect the rights, property, or safety of Fellowship Intelligence or others.
Information may be stored on secure servers or cloud platforms operated by third-party providers. Fellowship Intelligence implements reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, use, or disclosure. However, no method of transmission or storage can be guaranteed to be completely secure.
Some Fellowship Intelligence services rely on artificial intelligence systems or third-party software platforms to analyze information, generate outputs, or assist in service delivery. Fellowship Intelligence does not use client-submitted information to train proprietary AI models. Third-party AI systems used in service delivery are governed by their own data handling and privacy policies and, where applicable, by data processing agreements executed with those providers.
The third-party AI providers we use are named in Section 17 (Subprocessors and Service Providers) below and are described in more detail in our Responsible AI and AI Transparency Policy, which is updated as our service infrastructure evolves. Users should avoid submitting sensitive personal information unless it is appropriate and necessary for the intended service engagement.
Fellowship Intelligence may retain information for as long as reasonably necessary to provide services, maintain business records, comply with legal obligations, resolve disputes, and enforce agreements. When information is no longer required for these purposes, we will take reasonable steps to delete or de-identify it.
Our internal retention periods are set out in the Fellowship Intelligence Data Retention and Deletion Policy. Where a client agreement or addendum sets a shorter maximum retention period for a category of information, that shorter period controls. Personal information we process on behalf of a client is returned or deleted within 30 days of the end of the engagement or of the client's request, subject only to legal hold, an identified statutory retention requirement, and encrypted backup media pending routine rotation.
For the DIY Starter Kit and other self-service tools, retention follows fixed, published windows rather than case-by-case review. Workbook responses you submit through the kit portal are retained for up to 7 days after you export them, after which the response content is cleared; your completion status and export date are kept as a record. Self-Score Sheet results and other self-service activity data are retained for up to 180 days from your last activity, after which they are deleted.
Depending on your jurisdiction, you may have rights related to your personal information, including: access to data we hold about you, correction of inaccurate or incomplete data, deletion of personal data, restriction of processing, and objection to processing based on legitimate interests. Requests may be submitted to privacy@fellowshipintelligence.com. We may request reasonable verification of identity before processing certain requests.
We will acknowledge your request promptly and respond within 45 calendar days of receiving a verifiable request, with a single extension of up to 45 additional days where reasonably necessary. If we take the extension, we will tell you within the first 45 days and explain why.
Where we hold your personal information because a client engaged us to process it on that client's behalf, we act as a processor or service provider and not as the controller or business. In that case we will not act on your request ourselves. We will acknowledge your request, direct you to the client, and forward your request to the client promptly.
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), in addition to the general rights described in Section 11.
• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, business purposes, and categories of third parties with whom we share it.
• Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions permitted by law.
• Right to Opt-Out of Sale or Sharing: Fellowship Intelligence does not sell personal information and does not share personal information for cross-context behavioral advertising purposes. No opt-out action is required.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA/CPRA rights.
Contact us at privacy@fellowshipintelligence.com with the subject line "California Privacy Request." We will respond within 45 calendar days, with an extension of up to 45 additional days if reasonably necessary.
Fellowship Intelligence does not share personal information with third parties for direct marketing purposes.
Still in Charge is an independent initiative founded by Thomas Tornatore. It is not owned, operated, or controlled by Fellowship Intelligence LLC, and Fellowship Intelligence does not process, store, or have access to any data collected in connection with Still in Charge. Still in Charge maintains its own separate Privacy Policy, available on the Still in Charge website, which is the authoritative document for all data practices related to that program. Privacy inquiries related to Still in Charge should be directed to the contact listed on the Still in Charge website, not to Fellowship Intelligence.
Fellowship Intelligence operates in the United States. Information submitted to the services may be processed and stored in the United States or other jurisdictions where our service providers operate. If you are located outside the United States, including the European Economic Area or United Kingdom, your information may be transferred to and processed in jurisdictions with different data protection standards. We rely on available lawful transfer mechanisms when transferring personal data internationally.
Our website or communications may contain links to third-party websites or services. Fellowship Intelligence is not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party services you access.
Fellowship Intelligence may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. Updates will be posted on this page with a revised "Last Updated" date. Continued use of our website or services after a policy update constitutes acceptance of the updated terms.
Fellowship Intelligence has no employees; we engage independent contractors. We operate on third-party platforms rather than on infrastructure of our own. The following subprocessors process personal information or client information on our behalf. This list is current as of the Last Updated date above and is the authoritative subprocessor list referenced in our Data Processing Addendum and GLBA Service Provider Addendum.
The providers below are described in more detail, including the scope of their use and the data protection arrangements in place, in our Responsible AI and AI Transparency Policy.
We will update this section at least 30 days before adding or replacing a subprocessor that processes client personal information. Clients with an executed Data Processing Addendum, HIPAA Business Associate Agreement, or GLBA Service Provider Addendum may also request written notice of such changes by emailing privacy@fellowshipintelligence.com with the subject line "Subprocessor Notice." We will send that notice to the contact the client designates. A client may object to a new subprocessor on reasonable data protection grounds on the terms set out in its addendum.
We do not use client information to train any artificial intelligence model of our own, and we do not permit our subprocessors to use client information to train their models.
Fellowship Intelligence maintains a written breach response protocol. We use one trigger and one clock. The trigger is discovery, meaning the point at which we first become aware of facts indicating that an incident has occurred. The clock does not wait for us to confirm the incident or to finish investigating it.
If we discover a security incident affecting personal information we hold on behalf of a client, we notify that client without unreasonable delay and in any event within 72 hours of discovery. That 72-hour standard applies uniformly to general commercial engagements, to engagements governed by a HIPAA Business Associate Agreement, and to engagements governed by a GLBA Service Provider Addendum. The notification states the nature of the incident, the categories of information affected, the steps taken to contain it, and our remediation plan, to the extent known at the time, and is followed by a written incident report within five business days.
Where we are the controller of the affected personal information, for example information you submit to us directly through this website, we will notify affected individuals and any regulator as required by applicable law, in the most expedient time possible and without unreasonable delay. Where the EU or UK General Data Protection Regulation applies and the breach is notifiable, we will notify the competent supervisory authority within 72 hours of becoming aware of it, and affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.
Where we act as a business associate under HIPAA, our notification duty runs to the covered entity under 45 CFR 164.410. Notice to individuals, notice to the Secretary of Health and Human Services, and the annual log of breaches affecting fewer than 500 individuals are the covered entity's obligations under 45 CFR 164.404 through 164.408, not ours.
Questions about a security incident may be directed to privacy@fellowshipintelligence.com.
Questions, concerns, or requests regarding this Privacy Policy may be directed to:
Fellowship Intelligence LLC
Email: privacy@fellowshipintelligence.com
General: contact@fellowshipintelligence.com
Website: https://www.fellowshipintelligence.com
Fellowship Intelligence LLC | contact@fellowshipintelligence.com | www.fellowshipintelligence.com
