Privacy Policy Grey Matter Diagnostic™

The Grey Matter Diagnostic™ is a proprietary nonprofit organizational assessment tool operated by Group1631, LLC under license from Michael Stevens IP Holdings, LLC. This Privacy Policy explains what information we collect when you use the tool, how we use it, and what rights you have. We do not collect more than we need, we do not sell data, and we do not use your data to train AI models.

1  What We Collect

We collect the following categories of information when you use the Grey Matter Diagnostic:

• Access log data. When you enter an access code and accept the Terms of Use, we log the date and time of acceptance, the access code used, and your browser's user-agent string. We may also receive your IP address as part of standard web traffic handling by Cloudflare (our hosting provider). This log constitutes our record of your click-wrap acceptance.
• Assessment inputs. The responses, ratings, and text you enter into the diagnostic tool. This data is processed in your browser and, when you export a report, transmitted to generate your Excel workbook or PDF output. We do not permanently store your assessment responses on our servers.
• Organization name. The name of the organization you are assessing, as entered at the start of the diagnostic. This appears in your report output and in the acceptance log.

We do not collect your name, email address, phone number, or payment information through this tool.

2  How We Use It

We use the information collected for the following purposes only:

• To operate the tool. Access codes gate the tool. Acceptance logs provide legal evidence of Terms of Use agreement.
• To deliver your report. Assessment inputs are used in-session to generate your Excel workbook and PDF output. They are not retained after your session ends.
• To improve our benchmarks. On an aggregated, anonymized basis, assessment data may inform the benchmark ranges used in the diagnostic. No individual organization's data is identifiable in this process. See our Terms of Use, Section 5, for additional detail.
• To enforce our Terms of Use. Acceptance logs may be used as evidence in a legal proceeding involving a breach of the Terms of Use or misappropriation of our proprietary content.

3  How We Store It

The Grey Matter Diagnostic runs primarily in your browser. Assessment inputs are held in memory during your session and are not transmitted to or stored on our servers except as part of report generation.

Acceptance log records (date, time, access code, user-agent, IP address) are stored in Cloudflare's infrastructure under our account. Cloudflare's data centers are located primarily in the United States. Cloudflare's own privacy policy governs their handling of infrastructure-level data.

We do not use cookies for tracking. We do not use advertising pixels or tracking scripts.

4  We Do Not Sell Data

We do not sell, rent, trade, or otherwise transfer your personal data or your organization's assessment data to any third party for commercial purposes. This includes data brokers, advertisers, and analytics platforms.

Group1631 products are ad-free. We are not compensated to promote any product or service within the diagnostic tool or its outputs.

5  Third-Party Services

We use the following third-party infrastructure services in operating the Grey Matter Diagnostic. Each service has its own privacy policy governing their data handling.

• Cloudflare Pages / Cloudflare Workers. Our hosting and routing infrastructure. Cloudflare receives web traffic metadata including IP addresses as part of normal CDN operation. See Cloudflare's Privacy Policy.

We do not use Google Analytics, Meta Pixel, or any other behavioral tracking service.

6  Colorado Privacy Rights

The Colorado Privacy Act (CPA), C.R.S. § 6-1-1301 et seq., provides Colorado residents with certain rights regarding their personal data. To the extent the CPA applies to your use of this tool, you have the right to:

• Know whether we process personal data about you;
• Access the personal data we hold about you;
• Correct inaccurate personal data;
• Delete personal data we have collected from you;
• Opt out of the processing of personal data for targeted advertising or sale (we do neither).

To exercise any of these rights, contact us using the information in Section 10. We will respond within 45 days as required by the CPA. There is no fee to submit a request.

7  International Users

The Grey Matter Diagnostic is designed for use by nonprofit and faith-based organizations based in the United States. It is operated under Colorado law. If you are located outside the United States, you access this tool at your own risk and acknowledge that US law — not the laws of your home jurisdiction — governs this Privacy Policy and any dispute arising from it.

We do not currently offer a GDPR-compliant version of this tool. If international deployment becomes part of our service model, this policy will be updated and an international data processing addendum will be added before any marketing or delivery outside the United States.

8  Children

The Grey Matter Diagnostic is a professional organizational assessment tool intended for use by adults in their capacity as organizational leaders, board members, consultants, or advisors. We do not knowingly collect personal information from individuals under the age of 18. If you believe a minor has submitted data through this tool, please contact us and we will delete it promptly.

9  Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected in an updated version number and effective date in the header of this page. If you continue to use the Grey Matter Diagnostic after a revised Privacy Policy is posted, you accept the revised terms.

Prior versions of this Privacy Policy are available upon request.

10  Contact

We aim to respond within 5 business days for general questions and within 45 days for formal CPA rights requests.