Last Revised: December 24, 2019
Summary of Key Points
|Collection||As a business to business (“B2B“) organization, we collect name, contact details, and other Personal Data related to our commercial relationships. Click here to learn more.|
|Use||We use Personal Data to provide our services and respond to inquiries, to manage accounts and maintain business operations, including the processing of applications, to provide relevant marketing, and to fulfill other business and compliance purposes. Click here to learn more.|
|Sharing||We share Personal Data as necessary to provide our services and respond to requests, and to fulfill other business and compliance purposes. Click here to learn more.|
|Marketing choices||You have control over how we use Personal Data for direct marketing. Click here to learn more.|
|Data subject rights||You have certain rights to request access, rectification, deletion, or other actions regarding Personal Data where required by applicable law. Click here to learn more.|
|Data security||We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction. Click here to learn more.|
|Cross-border data transfers||We provide appropriate protections for cross-border transfers where specified by law. Click here to learn more.|
|Contact us||Please contact us as detailed below with any questions. Click here to learn more.|
Collection of Personal Data
We collect the following categories of Personal Data:
Basic Data: Name, title, company, office location, job responsibilities, phone number, mailing address, and email address.
Registration Data: Whitepaper/newsletter/brochure requests, service preferences, company-hosted or sponsored event attendance, downloads, and username/passwords.
Marketing Data: Data about individual participation in trade shows and conferences, credentials, associations, services you are interested in, and preferences.
Job Applicant Data: Data provided by job applicants or others on our Site or offline means in connection with employment opportunities.
Device Data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Site and communications. Note, however, we do not consider Device Data to be Personal Data except where we link it to you as an individual or where applicable law requires.
Use of Personal Data
We use the above categories of Personal Data for the following purposes:
|Purpose of Use||Categories of Personal Data|
|Provide the services you requested and respond to your inquiries||Basic Data, Registration Data, Transaction Data, and Device Data|
|Manage your accounts and maintain our business operations||Basic Data, Registration Data, Transaction Data, and Device Data|
|Make our Site more personal, intuitive and easy to use, including preferred language, and tailored advertising||Device Data|
|Protect the security and effective functioning of our Site and information technology systems||Basic Data, Registration Data, Transaction Data, and Device Data|
|Provide relevant marketing about our or our affiliates’ services or promotions that we are developing, and opportunities that may be available to you||Basic Data, Registration Data, Transaction Data, Device Data, and Marketing Data|
|Address our compliance and legal obligations and exercise our legal rights||Basic Data, Registration Data, Transaction Data, and Device Data|
|Consider individuals for employment and contractor opportunities and manage on-boarding procedures||Job Applicant Data|
Sharing of Personal Data
We share Personal Data with the following categories of recipients:
- Affiliates: We share Personal Data within the NTT DATA group of affiliated companies as necessary for the purposes described above. The list of affiliates within the NTT DATA group is provided here.
- Service providers: We share Personal Data with service providers to perform functions on our behalf and under our instructions in order to carry out the purposes identified above, such as marketing or web hosting. We require service providers to provide reasonable and appropriate security for Personal Data and to use and process such Personal Data only on our behalf.
- Auditors and advisors: We share Personal Data with auditors for the performance of audit functions, and with advisors for the provision of legal and other advice.
- Business Reorganization: We share Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of NTT DATA.
- Mandatory disclosures and legal rights: We share Personal Data in order to comply with any subpoena, court order or other legal process, or as otherwise required by applicable law. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
If you have questions about the parties with which we share Personal Data, please contact us as specified below.
You have control regarding our use of your Personal Data for directing marketing. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as detailed below.
What are cookies?
Cookies are small amounts of data that are stored on your browser, device, communication, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at www.allaboutcookies.org.
Cookies on our Site are generally divided into the following categories:
- Strictly Necessary Cookies: These are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased when you close your browser.
- Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Site and understand how such users navigate through our Site. This helps to improve how our Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
- Functional Cookies: These improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Site. You can delete these cookies via your browser settings.
- Targeting Cookies: These record your visit to our Site, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Site and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Site. You can delete these cookies via your browser settings or our cookie management tool. See below for further details on how you can control third party targeting cookies. We may rely on these cookies, clickthroughs, and how you otherwise interact with our communications (lead scoring) in order to tailor future communications to you, which you can opt out from at any time by using direct links to unsubscribe included at the bottom of any email or by contacting us below.
What are your options if you do not want cookies?
You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.
To learn more about certain cookies used for interest based advertising by third parties, and to exercise certain choices regarding such cookies, please visit our cookie management tool.
Data Subject Rights
Where required by applicable law, you have the right to obtain confirmation that we maintain certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us at privacy@NTTDATA.com. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. Contact us below for more details. Please note that we need to retain certain Personal Data as required or permitted by applicable law.
California Privacy Rights
If you are a California resident, please note the following about how we collect, use and disclose your Personal Data, including additional rights you may have to your Personal Data:
- CA Personal Data. Consistent with the “Collection of Personal Data” section above, we may collect the following categories of information about California residents:
- Identifiers: name, title, company, title, job responsibilities, mailing address, phone number, email address, job responsibilities, IP address, username, password, and information collected via Cookies;
- Commercial Information: communications request, service preferences, event attendance history, search preferences, transaction history, demographic information; and
- Internet or Other Electronic Network Activity: browser, operating system, application version, device ID, pages shown.
- CA Job Applicant Personal Data. In addition to the categories above, and consistent with the “Collection of Personal Data” section above, we may collect the following categories of information about California resident job applicants:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Job applicants may provide a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Protected classification characteristics under California or federal law. Job applicants may provide age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Professional or employment-related information. Job applicants may provide current or past job history or performance evaluations.
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Job applicants may provide Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Inferences drawn from other personal information. Job applicants may provide profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sources of CA Personal Data. Consistent with the “Collection of Personal Data ” section above, we may collect Personal Data directly from you, including automatically when you visit the Site or provide information to us at in-person events.
- Use of CA Personal Data. Consistent with the “Use of Personal Data” section above, we may use your Personal Data collected through the Site for the following business or commercial purposes:
|Categories of Personal Data||Business or Commercial Purposes||Sources of Personal Data||Categories of Third Parties Personal Data is Shared With|
|Identifiers; Commercial Information; Internet or other Electronic Network Activity||Provide the services you requested and respond to your inquiries||Consumers||N/A|
|Identifiers; Commercial Information; Internet or other Electronic Network Activity;||Manage your accounts and maintain our business operations||Consumers||N/A|
|Identifiers; Internet or other Electronic Network Activity||Tailor your experience on the Site, as well as for analytics and interest-based advertising||Consumers||Ad Tech Providers|
|Identifiers; Commercial Information; Internet or other Electronic Network Activity||Protect the security of the Site||Consumers||N/A|
|Identifiers; Commercial Information; Internet or other Electronic Network Activity||Send you email marketing about relevant services or promotions||Consumers||N/A|
|Identifiers; Commercial Information; Internet or other Electronic Network Activity||Exercise rights or satisfy obligations under applicable law||Consumers||N/A|
|Other Information||Consider individuals for employment and contractor opportunities||Consumers||N/A|
- CA Personal Data Sold or Disclosed for Business Purposes.
- Sharing Personal Data for Business Purposes (as defined under CCPA): We may share the following categories of Personal Data for business purposes: Identifiers, Commercial Information, Internet or other Electronic Network Activity with Service Providers (as defined under CCPA)
- Sale of Personal Data: We may sell (as defined under CCPA) the following categories of Personal Data: Internet or other Electronic Network Activity.
- California Privacy Rights. As a California resident, subject to certain exceptions, you may have the right to access, correct (rectification), and/or delete your Personal Data. You also have the right to request information about the Personal Data we have “sold” or disclosed for business purposes, by contacting us at privacy@NTTDATA.com or via our toll-free phone number at 800.745.3263.
To protect your privacy and security, we will verify your identify before responding to a such request, and may request you provide us your name and email or additional proof where necessary. You will not be penalized for exercising your rights to your Personal Data.
- “Do Not Sell My Personal Information.” You also have the right to opt-out of NTTDS “selling” your Personal Data as defined under CCPA. To exercise this right, please visit our “Do Not Sell My Data” or email us at privacy@NTTDATA.com. If you make this request on behalf of someone else, we may request that you provide proof that you are authorized to exercise the right on behalf of the consumer. If we know that you are under the age of 16, we will not sell your Personal Data without proper consent.
- Access Notice in Alternative Formats. Consumers who need assistance accessing the notice in an alternative format can do so by contacting the Privacy office at 800.745.3263 or privacy@NTTDATA.com.
We will not discriminate against you for exercising any of your California privacy rights. Your exercise of your California privacy rights will never cause us to:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Although California law allows us to offer financial incentives that can result in different prices, rates, or quality levels, we do not presently engage in this practice.
We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction. However, no security measure can guarantee against compromise. You also have an important role in protecting your Personal Data. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.
Cross-Border Data Transfers
We transfer Personal Data to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area (“EEA“), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.
1) What is the legal basis of processing?
Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (i) as necessary to perform a transaction (such as in order to provide the services you requested); (ii) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (iii) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (iv) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site). With respect to legitimate interests, given that we are a B2B company, we typically collect and process limited Personal Data about customer contacts and other individuals acting in their business capacities, as part of our overall effort to reduce the privacy impact on individuals.
2) What are the consequences of not providing Personal Data?
3) Do we engage in automated decision-making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
4) Does the Site honor do not track (“DNT”) signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.
5) How long do we retain Personal Data?
7) How does NTT DATA handle employee and contractor privacy issues?
Mail: Database c/o Corp Marketing
100 City Square
Boston, MA 02129
You may also have a right to lodge a complaint with a data protection supervisory authority.