Leadership Mosaic 360 — Terms of Service
1. Description of Service
The Leadership Mosaic 360 (the “Mosaic”) is a self-service multi-rater leadership feedback survey provided by gothamCulture LLC (“gothamCulture,” “we,” or “us”). Upon completion, the participant receives a personalized PDF report summarizing aggregated feedback from self, peers, supervisors, and direct reports. The Mosaic is provided “as is” and “as available.”
2. Eligibility
Use of the Mosaic is limited to working professionals aged 18 and older. The Mosaic is not directed to children, and we do not knowingly collect personal information from anyone under 18.
3. Promotional Codes
Promotional codes (such as MOSAIC360) waive the standard fee for use of the Mosaic during the applicable promotion window. Promotional codes have no cash value, may not be combined with other offers, and may be modified or terminated at gothamCulture’s sole discretion. gothamCulture may disqualify users who attempt to abuse the promotion. Users who have completed enrollment before any modification or termination will receive the Service in accordance with the terms in effect at the time of their enrollment.
4. Acceptable Use
You agree to use the Mosaic only for legitimate leadership-development purposes, to provide accurate information, and not to interfere with the operation of the Service or attempt to access data of other users.
5. Data lifecycle
Your responses are processed in two phases:
5.1 — Phase 1: Identifiable processing (60 days). For the sixty days following your submission of survey responses, your data is processed in identifiable form for the purpose of generating and delivering your Leadership Mosaic 360 report. During this phase, the full range of data protection rights applies, including the right to access, rectify, erase, restrict, object to, or port your data. To exercise any of these rights, contact privacy@gothamculture.com.
5.2 — Phase 2: De-identified research database. After the sixty-day identifiable-processing window, and subject to your opt-in or opt-out consent (whichever applies in your jurisdiction), your responses may be included, in de-identified form, in gothamCulture’s leadership research database. We maintain this database for the purposes of scientific research, statistical analysis, and product improvement of the Leadership Mosaic instrument.
5.3 — Legal basis. Inclusion in the research database is processed under GDPR Article 6(1)(f) (legitimate interests in scientific research and product improvement) and benefits from the research-purposes safeguards of Articles 17(3)(d) and 89. We apply specific safeguards including pseudonymization (no name or email attached to records), restricted access, minimum aggregation thresholds for query outputs, and exclusion of open-text rater comments.
5.4 — Retention. Records in the research database are retained for five (5) years from the date of transformation, with periodic review of the continued need for retention. At the end of five years, records are deleted unless a documented continuing research need is established.
5.5 — Data subject rights against the research database. You retain the right to request access, rectification, erasure, and restriction of your records in the research database for as long as records remain identifiable to you through any means (which, as a practical matter, may include matching against a copy of your own Mosaic report). To exercise these rights against the database, contact privacy@gothamculture.com. We will assess each request: erasure may be limited where it would seriously impair the research purposes of the database, but access and rectification rights are not so limited.
5.6 — Opt-out / objection to inclusion. You may object to inclusion of your responses in the research database at any time during the Phase 1 identifiable window by contacting privacy@gothamculture.com. Objection is permanent and applies to all subsequent processing for research purposes.
6. Rater Data
When you invite raters to provide feedback, you confirm that you have a legitimate basis for inviting them. Raters provide their feedback under a separate privacy notice and consent flow. Identifying details about individual raters are not disclosed to you in the report. Where fewer than three raters in a relationship category respond, that category is not broken out individually in your report.
7. Marketing Communications
With your separate, opt-in consent, gothamCulture may contact you about the Mosaic and related services. You can unsubscribe at any time using the link in any marketing email. Marketing consent is independent of, and not required for, completing the Mosaic.
8. No Warranty / Limitation of Liability
The Mosaic provides developmental feedback. It is not a clinical instrument, employment-screening tool, or substitute for professional judgment. To the fullest extent permitted by law, gothamCulture disclaims warranties of merchantability and fitness for a particular purpose. gothamCulture’s aggregate liability arising out of or related to the Mosaic is limited to the amount actually paid by you for the Service (or, for promotional users, $300 — the standard list price).
9. Geographic Restrictions
The Mosaic is not offered in jurisdictions where its provision would be unlawful or where the compliance burden is not feasible for a free promotional offering. The Mosaic is not currently available to users located in Cuba, Iran, North Korea, mainland China, or the Russian-occupied regions of Ukraine (Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson). Access attempts from these jurisdictions are blocked.
10. Modifications
gothamCulture may modify these Terms at any time; material changes will be communicated to active users with at least thirty (30) days’ notice. Continued use after notice constitutes acceptance. The currently effective version is always shown at checkout and at this page.
11. Contact
Questions or to exercise data rights: privacy@gothamculture.com. General inquiries: info@gothamculture.com.
gothamCulture LLC, 115 Broadway, 5th Floor, New York, NY 10006.
EU/UK representative (and Swiss representative under FADP Article 14): DataRep (Data Protection Representative Limited, trading as DataRep). Data subjects may exercise rights via email at datarequest@datarep.com (subject line: gothamCulture LLC), via webform at https://www.datarep.com/data-request, or by post to DataRep at any of its 31 EU/EEA/UK/Swiss contact locations (primary EU office: 77 Camden Street Lower, Dublin, D02 XE80, Ireland; UK: 107-111 Fleet Street, London, EC4A 2AB, United Kingdom; Switzerland: Leutschenbachstrasse 95, 8050 Zurich, Switzerland). Postal correspondence MUST be addressed to “DataRep” — not gothamCulture LLC — to reach the representative.
gothamCulture LLC’s appointed Data Protection Representative for the EU/EEA, UK, and Switzerland: