Effective Date: July 1, 2019
How We Use Your Information
How We Disclose Your Information
Cookies and Other Tracking Mechanisms
Do Not Track Disclosure
Your California Privacy Rights
Information for EU Individuals
INFORMATION WE COLLECT
We collect information about you directly from you and automatically through your use of our Services. We may combine information collected from or about you from these various sources.
Information We Collect Directly from You. We will collect any information that you provide to us through our Services, such as your name, email address, company name, your marketing preferences, which NTT operator you work with, and the contents of any message that you submit through our Services.
Information We Collect Automatically Through Our Services. We automatically collect information about you through your use of our Services, including, without limitation, your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services. Please see our Cookies and Other Tracking Mechanisms section below for more information. We may combine information we collect automatically with information we collect directly from.
HOW WE DISCLOSE YOUR INFORMATION
We may disclose your information, including personal information, as described to you at the time of collection or disclosure or as follows:
Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to a service provider that helps us with our email newsletters and promotional materials.
Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
DO NOT TRACK DISCLOSURE
Our Site and Services may not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You may, however, disable certain tracking as discussed in the Cookies and Other Tracking Mechanisms section above (e.g., by disabling cookies).
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites.
We have taken steps to help protect the personal information we collect. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident then under Cal. Civ. Code § 1798.83 you may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the contact information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for your response.
Our Services are not targeted to children under thirteen (13) years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.
INFORMATION FOR EU INDIVIDUALS
The following disclosures apply only to NTT Research’s processing of personal data about EU residents.
The Data Controller of the information collect through the Site and Services is NTT Innovation Institute, Inc which is headquartered in the United States at 1950 University Ave #600, East Palo Alto, CA 94303. To exercise any rights that you may have with regard to your personal data, you may contact us using the following details:
The legal bases for using your personal Information. We collect your information as a Data Controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you. This applies to our processing activities described at 2A and 2B above.
Our use of your personal data is in our legitimate interest as a commercial organization to make improvements to our Site and to provide you with access to the Services as you request. This applies to our processing activities described at 2C (save where we need consent by local law) and 2D.
Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have in particular, where we are required to disclose personal information to a court or regulatory body in the event of an investigation. This applies to our processing activities described at 2E and 2F.
Our use of your personal information is in accordance with your consent. This applies to our processing activities described at 2C (where required by local law).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your Legal Rights. Subject to certain exemptions, and dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to personal information:
Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred. You also have the right to request that we correct any inaccuracies or delete your information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims.
Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data. We can continue to use your personal information following a request for restriction, where: (a) we have your consent; or (b) to establish, exercise or defend legal claims; or (c) to protect the rights of another natural or legal person.
Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send us a request to email@example.com. In your message, please indicate the right you would like to exercise and the information to which it relates.
We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Cross-border Transfer of Information. We maintain servers and systems in the United States hosted by third party service providers. As a result, where the personal information that we collect through or in connection with the Site or the Services is processed in the United States, we will take steps to ensure that the information receives the same level of protection as if it remained within the European Union. You may have a right receive details of any safeguards that we have where your data is transferred outside the European Union, (e.g. to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality).