General Information

This privacy policy applies to Element22 Group LLC (Element22) products, services, research panels and any offering operated by Element22 and/or its affiliates, subsidiaries and/or divisions. Element22 strives to conform its privacy practices, policies and/or procedures with any and all applicable international, country specific, US federal, state and/or local laws, codes and regulations. Element22 is committed to protecting the security and integrity of all personal information collected by or disclosed to Element22. Element22 will not use any personal information for direct marketing or advertising purposes. This privacy policy identifies the personal information that Element22 collects; how such personal information will be used and protected; and your rights.

Information Collection and Use


We store information that we collect through user input, cookies, log files, and user surveys to create a ‘profile’ of preferences. This profile information includes each of the following categories:

Registration Information: username, password, first name, last name, email address, phone (optional)
Preferences: profile information that categorizes how the software is utilized

Details of the user profile are used to contact the user (see ‘Communication from the Site’). Profile information may be updated at any time by clicking on the ‘settings’ link while the user is logged into their administrative account. Administrative accounts are setup for all organizations that are clients. If you are an end user, please contact your organization admin for support.

Uses of Information

No data is used for any other purpose than to satisfy a contract to which the data subject is a party and no data is shared with any third party except as stated in “Information Sharing and Disclosure”. Clients and individual users of Pellustro® may review extract and request deletion of their personal information.

Pellustro® is a web-based service for conducting assessments and evaluations. Any information shared with Element22 LLC during the creation of an assessments is owned solely by the Client or the Publisher of that assessment. By the nature of how our service works, assessments need to be shared via a URL on the Internet. Email addresses uploaded to the system for the purpose of sending assessment invitations and email communication are owned solely by the Client or the assessment Publisher. Data collected through assessments is owned solely by the Client or the assessment Publisher. By default, the data is only accessible by providing a username and password and logging into the site.

Communications from the Site

Ongoing Communication and Product Updates

If you have an administrative or publisher account, we will occasionally send you information on product enhancements, new services, and additional instruction on utilizing our services. These communications are designed to educate our users on the services offered. Out of respect for your privacy, we present the option not to receive these types of communications. Please see ‘Choice and Opt- out’ in ‘Information Sharing and Disclosure.’

Service-related Announcements

If you have an administrative or publisher account, we will send you strictly service-related announcements when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Service-related emails are also sent confirming billing transactions, account upgrades, and account cancellations. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to cancel your account.

Customer Service

Based upon the personally identifiable information you provide to us, we will send you a welcoming email to verify your username and password as well account manager contact information. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account.

Information Sharing and Disclosure

Personally Identifiable Information Sharing with Partners

We do not share any personally identifiable information with any third parties except as indicated below. If a user specifically requests a service from one of our partnering companies, their personally identifying information will be shared. The partnering company may contact them directly regarding their inquiry. Any requests of partnering companies are initiated solely by the user and it will be clearly indicated that a partnering company offers the requested service. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process.


If you no longer wish to receive our product updates, you may opt-out of receiving them by following the instructions included in each product update email.

Web Analytics

We use a third-party tracking service called Google Analytics that uses cookies to track non-personally identifiable information about visitors to our site in aggregate form. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. IP addresses are tied to personally identifiable information to identify the country of origin of the user. This information is used to facilitate the use of the service.


A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site and validate that you have logged into your administrative account. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s ‘help’ file. If you reject cookies, the site will not function properly after logging in to your administrative account.

Clear Gifs

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications. If you would like to opt-out of these emails, please see ‘Choice and Opt-out’ in ‘Information Sharing and Disclosure.’

Access to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may update or cancel your account at any time by logging into the system and clicking on the ‘admin settings’ link. Options for updating your profile and account cancellations are available with administrative UI. If you are an end user with account through your organization, you should contact your organization administrator for any changes to the account usage.


The security of your personal information is important to us. When you enter sensitive information we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Changes in this Privacy Statement

If we decide to change our privacy policy, we will post those changes to this privacy statement and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our homepage.

Contact Us

Element22 LLC is committed to working with individuals to obtain a fair resolution to any complaints or disputes about privacy and personal information. Element22 LLC’s commitment to privacy is demonstrated and documented by our internal Privacy Compliance Officer and by our adherence to the applicable laws and codes.

If you have any complaints or concerns about this privacy policy you can contact:


Ed Hawthorne

Privacy Compliance Officer

Element22 LLC

300 Park Avenue, 2nd floor, New York, NY 10022