INTRODUCTION
Scope of Agreement
This Privacy Policy (the “Policy”) represents an agreement entered into as of the date of Account Registration (the “Effective Date”), by and between the Individual or Organization (“Accountholder”), and The Consultants Consortium, Inc. (dba TCC Software Solutions), the owner of the DevelopU Platform and an Indiana corporation with offices at 1022 E 52nd St. Indianapolis, IN 46205. The Accountholder and TCC may be referred individually as a “Party” or collectively as the “Parties.”
Before getting started as an Accountholder, please review each of the DevelopU User Terms and Conditions defined in the next sections.
Registering for an Account on the DevelopU Platform acknowledges and accepts the Privacy Policy terms set forth in this agreement. By agreeing to the Policy, you are also agreeing to the User Terms & Conditions. If you do not agree to the DevelopU Privacy Policy and User Terms & Conditions, please deactivate your DevelopU Account.
You further acknowledge that TCC can change the Privacy Policy and User Terms & Conditions at any time and without advance notice. Your ongoing use of DevelopU indicates that you accept any changes in the future and acknowledge your obligations to ensure compliance with such changes.
TCC is not responsible for any delay or failure in performance resulting directly or indirectly from causes beyond its reasonable control.
Privacy Overview
TCC, including its affiliates and partners, are committed to respecting your privacy and complying with applicable data protection and privacy laws. This Policy describes how we collect and use personal data where TCC is the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual.
We will give you additional privacy information that is specific to a product or service in Supplements to this Policy, as required. In cases of material difference between such Supplements and this Policy, the Supplement verbiage should be considered first.
Our Platform may contain links to, or may in the future be embedded within, other companies’ websites and services that have privacy policies of their own. In cases where DevelopU or its affiliates’ products or services are embedded in DevelopU Platform Services of partner organizations, we require our partners to provide necessary transparency to you. This might include linking to this Policy and the relevant Supplements, or providing the transparency in integrated and embedded notices which identify us as the service provider or controller.
If you do not agree with this Policy or Supplements to this Policy specific to distinct DevelopU Platform Service offerings, we request that you do not use any DevelopU Platform Services or provide TCC with your personal data.
What information do we collect?
We collect your personal data and other information primarily during the Account Registration and Purchase processes (whether the underlying intellectual property is wholly-owned by TCC or by a partner organization).
Use of Platform and Services
When you elect to utilize DevelopU Services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information.
The DevelopU Application may evaluate server and partner application records periodically for timely updates or to assess new online purchases and/or otherwise monitor service usage.
Account Registration
When you create an Account and/or Purchase Services, we may request requisite information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your browser, electronic device, age, gender, and language preference. Accessing the DevelopU Platform and its Services may require electronic activation, where your device and relevant technical details, as well as unique device, application, network and subscription identifiers are sent to TCC. A variation of these data collection methods occur at the time a User is created and added to a Team by an Account Administrator as well.
We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.
Comments
When visitors or authorized Accountholders leave comments on our solution website, we collect the data shown in the comments form, and may in some instances collect the IP address and browser user agent string to assist in spam detection. An anonymized string created from your email address (also called a hash) may be provided to an authorized third party application. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Locational Data
Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network related identifiers with TCC. Our DevelopU Platform Services may operate on multiple device platforms, applications and services which may also collect your location data. However, we do not use this information to identify or track you without prior authorization.
When you use our location based services and features on social media platforms, such as Facebook, Instagram, Youtube, Twitter, or Linkedin, when authorized, your location data may be disclosed to TCC for purposes of delivering contextually-relevant, location-based advertising.
Third-Party Disclosures
We obtain information from Partner organizations and a variety of other sources, including publicly available sources such as business registries. We require these sources to comply with applicable laws insofar as collecting and transferring pertinent data to us, including ensuring that there is a legal basis for the transfer or anonymizing the data in accordance with applicable laws prior to disclosure of the data to us.
Why do we process Personal Data?
TCC may process your personal data for the following purposes. One or more purposes may apply simultaneously.
Delivery of Platform Services
We may use your personal data to provide you with requested Services via the Platform, to process your requests or to otherwise deliver on the agreement formed between you and TCC when you made a Purchase, extending to you relevant Application functionality in a secure fashion.
Account Management
Some Platform Services may require an Account to help you manage your content and preferences. Depending on the Service, an Account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as name, email address, mailing address, job title, and employer (or: organizational affiliation). You may in some instances voluntarily provide more information about yourself than requested when submitting contact forms and/or when creating a user profile.
Evolving Platform Services
We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular TCC product and/or service with other personal data we may have about your Account, as warranted.
Communications Management
We may use your personal data to communicate with you, as required, in order to inform you that our services have changed or to send you critical alerts or timely notices related to your continued use of our products and/or services.
Marketing & Promotions
We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying TCC and third party content.
What is our legal basis for processing your Personal Data?
Our legal basis for processing your personal data is dependent on the purpose for processing and may vary as described in the Supplement applicable to the product or service you are using. In general, we process your personal data under the following legal bases:
Contract Performance
We process your personal data to perform our obligations under the applicable terms of use for the product or service you are using, whether provided by us or by our partners and affiliates.
Obtaining Consent
We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent, but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our DevelopU Platform Services might be only available based on consent.
Legal Obligations
We process your personal data as needed to ensure delivery of DevelopU Platform Services and compliance with all governing laws and regulations.
Legitimate Interests
We process your personal data to further our legitimate interests, whether in managing, developing, testing, and securing your use of our DevelopU Platform Services, or in limited circumstances marketing, advertising, and making recommendations regarding our DevelopU Platform Services. Any such processing is conducted in such a way that appropriate measures are undertaken to protect your personal data, and are subject to the restrictions set forth in this Policy. Further information or specification of our legitimate interests may be provided in relevant Supplements applicable to the product or service.
Personal Data Retention
We endeavor to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary to achieve such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was initially requested and provided. For example, for your personal data related to managing your Account (such as name, email address, and job title/function) are maintained for as long as they are retained by you within your Account. Additional information may be provided in the Supplement applicable to the product or service you are using. Please email us to obtain additional information about retention of your personal data.
Do we share Personal Data?
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
Your Consent and Social Media Services
We may share your personal data if we have your consent to do so. Some social media services may allow you to share your personal data with other users of the service. Please consider carefully before disclosing any personal data or other information that might be accessible to other users of such services.
Authorized third parties
We may share limited personal data with authorized third parties who process personal data for TCC for the purposes described in this Policy. This may include providing access to DevelopU Platform Services, and conducting research and executing marketing campaigns. When you purchase a TCC product or service, we may need to exchange information with your network service provider to provide you with such DevelopU Platform Services.
We may conduct joint marketing and other communications with our partners. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that TCC has collected with information that the partner has collected where this is permitted by law.
These authorized third parties are not permitted to use your personal data for any other purposes. We bind them contractually, thereby ensuring alignment with this Policy as it concerns the disclosure of your personal information.
Mandatory disclosures
We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend TCC’s legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings.
Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our company and/or the services and products we provide to customers, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and advisors.
How do we address the privacy of children?
TCC DevelopU Platform Services are intended for general audiences and our user population may include minors in some instances. We do not knowingly collect information pertaining to children without the consent of their parents or guardians. We extend the term guardian to include educational institutions, high schools, vocational schools, and other organizations with which we may form agreements for students and educators to utilize our DevelopU Platform Services.
How do we address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data.
We encourage you to access your personal data through your Account from time to time to ensure that it is up to date.
What steps are taken to safeguard Personal Data?
Privacy and security are paramount in the creation and delivery of our DevelopU Platform Services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and responsive risk management, and staff undertakes security and privacy training and assessments annually (or as legal and/or risk circumstances change). We take appropriate steps to address online security, physical security, risk of data loss and other such risks are assessed when considering data protection measures.
How do we use Cookies?
TCC uses cookies and other similar technologies to operate and improve upon its DevelopU Platform Service offerings. We also use cookies for personalization and to display ads on other social sharing platforms, provided the user has authorized such ad displays.
Articles and other content accessible from the DevelopU site include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the same way as when a user visits that associated third party website.
These websites may collect data about you, use cookies, embed additional third-party tracking, or otherwise monitor your interaction with that embedded content.
Leaving a comment opts-in to save your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment.
When you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
What are your rights?
You have a right to know what personal data we hold about you, and to access it. You have a right to have incomplete, incorrect, unnecessary or outdated personal data updated. You have the right to request that your personal data be erased, and to obtain a copy of your data in a machine-readable format. You have the right to object to or restrict processing in certain circumstances, such as where you believe the data is inaccurate or the processing activity is unlawful. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from TCC, critical alerts may still be sent to you as prescribed above.
You may exercise your rights by contacting us or by managing your Account and choices through available profile management tools on your device and/or using tools available within the solution. In some cases, especially if you wish us to delete or stop processing personal data, requests for removal of personal data will mean that we may cannot continue to provide DevelopU Platform Services to your Account. Applicable data protection law may provide certain restrictions on the extent to which these rights may be exercised. If a restriction applies, we will respond to your request with an explanation of what actions are lawful and steps we will take to comply.
Who is the controller of your Personal Data?
TCC 1022 E. 52nd St, Indianapolis, Indiana is the controller of your personal data.
In addition, the TCC affiliates—to the extent that they, too, are providing some portion of the product or service—may also be a controller of your personal data.
Changes to this Privacy Policy
TCC may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, TCC will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.