Your Acceptance Through Use
Categories of Personal Data We Collect
Personal Data is any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, consumer or household. This includes all information about your identity, such as your name, phone number, email address, mailing address or other identifiers described by privacy regulations such as the General Data Protection Regulation (GDPR) or California Consumer Protection Act (CCPA) to name a few. Information that cannot be associated with your identity (e.g., statistical information such as the number of users on the website) is not considered Personal Data.
You may use our website without disclosing your identity or Personal Data. If you wish to request information or apply for a job, however, we will ask for your name and other necessary information. You are free to decide whether or not you will enter this data. We indicate which information is required for the purpose in question (mandatory information). No automated decisions are made based on your Personal Data in connection with the use of our website.
For more information please refer to the link “Use of our website” listed below.
Information We Collect
The chart below identifies the categories of Personal Data that we collect:
||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|Personal information categories such as those listed in (Cal. Civ. Code § 1798.80(e)) or GDPR Article 4(1).
||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. Some personal information included in this category may overlap with other categories.
||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face scans, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|Professional or employment-related information.
||Current or past job history or performance evaluations.
Personal Data does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
We obtain the Personal Data listed in the table above from the following sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.nttdata-solutions.com/us). For example, from submissions through our website portal or website usage details collected automatically.
For more information on the specific types of information we collect see “What information do we collect and for what purpose?” listed below.
Processing of Personal Data
We may use or disclose the Personal Data we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, when a prospective candidate creates an online profile to complete a job application.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Data or as otherwise set forth in this policy.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which Personal Data held by us is among the assets transferred.
We do not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice and complying with the relevant data privacy laws.
We store your data on specially protected servers within the US, EEA and the countries of global affiliates where applicable. These servers are protected by technical and organizational measures designed to prevent the loss of data or destruction, access, modification or distribution of your data by unauthorized persons. Only authorized persons are able to access your Personal Data. These persons are responsible for the technical, commercial or editorial support of the website.
Disclosure of Personal Data
Affiliates and Third Party Service Providers
We work closely with our global affiliates and third party service providers for the provisioning of your contracted services. Our affiliates and third parties are required to have security and data protection standards that are substantially similar to NTT DATA Business Solutions’ standards and procedures. We achieve this through the execution of a Data Processing Agreement (DPA) with Model Clauses for compliance with GDPR, Business Associate Agreement for HIPAA, or other Data Protection Agreement required by law or contractual obligation.
When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed and will continue to disclose the following categories of Personal Data for a business purpose:
- Personal information categories.
- Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Authorized employees and affiliates.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
EU Legal Basis for Data Processing
Your Rights and Choices
State, Federal, and Global privacy regulations provide consumers with specific rights regarding their Personal Data. This section describes your rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Data. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Data we collected about you.
- The categories of sources for the Personal Data we collected about you.
- Our business or commercial purpose for collecting that Personal Data.
- The categories of third parties with whom we share that Personal Data.
- The specific pieces of Personal Data we collected about you (also called a data portability request).
- If we disclosed your Personal Data for a business purpose, identifying the Personal Data categories that each category of recipient obtained.
Data Erasure and Storage Time
You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our third parties to:
- Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Opt-Out of the Sale of Personal Information
We do not sell consumer information and fully support the rights of consumers to opt out of the sale or use of their Personal Data. If you would like to Opt-Out of any potential sale or use of your Personal Data, please contact [email protected].
Do Not Track
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. We do not currently take action in response to those signals. If an industry standard on responding to such signals is established and accepted, we may reassess how to respond to those signals.
Exercising Your Rights
You have extensive rights with respect to the processing of your Personal Data. First, you have a comprehensive right to your information and, where applicable, request correction and/or deletion or blocking of your Personal Data. You may also demand restrictions on the processing of your Personal Data, and you have a right to object to such processing. You also have a right to data portability governing the Personal Data you have provided to us. If you wish to assert one of your rights and/or to receive further information about your rights, please contact privacy office.
Consent that you have granted may be freely revoked at any time with effect for the future. Revocation of consent shall not affect the legality of processing carried out on the basis of your consent prior to revocation.
If the processing of your Personal Data is not based on consent but rather on another legal basis, you may object to this data processing. Your objection will lead to a review and, if necessary, to termination of the data processing. You will be informed of the results of the review and — if data processing is nevertheless to be continued — we will provide you with further details as to why data processing is permissible.
To exercise any of your rights listed above, please submit a verifiable consumer request using the resources listed below.
Questions and Contact Information
- Calling us at 1-(877)-478-2457
- Email us at [email protected]
- Send a verifiable request to:
NTT DATA Business Solutions Inc.
Attention: Privacy Office
10856 Reed Hartman Highway
Cincinnati, OH 45242
Email: [email protected]
Only you or a person authorized to act on your behalf per applicable laws, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of a minor.
You may only make a verifiable consumer request for access or data portability in accordance with applicable privacy laws.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 30-45 business days of its receipt. If we require more time we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Detail that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your privacy rights. Unless permitted by the law, we will not:
- 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.
This Website is not directed at nor targeted to children. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may not use this Website unless necessary parental consent has been obtained. If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove that information.
Changes to Our Privacy Notice
Use of our Homepage
Information about your computer
Each time you access this Website, we collect the following information about your computer: the IP address of your computer, the query from your browser and the time of this query. In addition, we record the status and the amount of data transferred as part of this query. We also collect product and version information about the browser and operating system of the computer used. Furthermore, we record the referring website from which our own site was accessed. The IP address of your computer is only stored for the time of use of the website and is subsequently deleted or made anonymous by shortening it. The remaining data are stored for a limited period of time. We use this data for the operation of the website, in particular to detect and correct errors, to determine the degree of utilization of the website and to make adjustments or improvements. These purposes also form the basis of our legitimate interest in data processing.
Depending on the content involved and storage time required, there are different types of cookies. Most of the cookies we use are so-called “session” cookies, which are deleted when you close your browser window. In addition, there are some persistent cookies that we use to recognize you as a visitor. Many cookies originate directly from us; in addition, some individual cookies (third-party cookies) are also stored and evaluated by service providers.
Most browsers are set to automatically accept cookies, but you may deactivate the storage of cookies or set your browser so that it informs you as soon as cookies are sent. Please note that your use of our website may be restricted in some cases if you refuse the storage of cookies.
Please expand the item below to see full details and review your choice regarding cookies on this site.
Your choice regarding cookies on this site.
The full IP address will be transmitted to a Google server in the United States and shortened there only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
You can prevent cookies from being stored on your computer by selecting the appropriate settings in your browser, but please note that if you do this, your use of the site may be impaired. You can also prevent Google from collecting and processing the data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information can be found at http://tools.google.com/dlpage/gaoptout?hl=en or https://support.google.com/analytics/answer/6004245?hl=en (general information on Google Analytics and data protection). Please note that the code “anonymizeIp();” has been added to Google Analytics for our website to anonymize the IP addresses, which involves the deletion of the last octet.
Use of HubSpot for web analytics purposes
Hubspot, Inc. is headquartered in the USA and is certified to the EU-US Privacy Shield. You will see the up-to-date certificate under https://www.privacyshield.gov/list. Based on this agreement between the USA and the European Commission, the latter has recognized entities certified to the Privacy Shield as those ensuring an adequate level of data protection.
You may object to the collection and storage of data at any time with effect for the future, by storing an opt-out cookie on your end-user device or by using an appropriate browser plugin, e.g. Ghostery which suppresses the operation of the tool.
RollWorks, AdRoll Group
To reach our website visitors on a broader basis, we use RollWorks, an AdRoll Group company, to serve targeted ads across the internet.
AdRoll Group is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. You may use the NAI opt-out tool here, which will allow you to opt-out of seeing personalized ads from AdRoll Group and from other NAI approved member companies.
AdRoll Group also complies with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that AdRoll Group may work with as Advertising Partners via the DAA website here.
Further information on data protection and technologies used can be found on the Wistia website at: https://wistia.com/privacy.
The use of Wistia and the storage of Wisitia cookies is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its web offering and its advertising.
Share Content (Share)
Our website offers the possibility to share individual content with third parties. When the corresponding function is called up, a new window opens in which all the necessary information for the content sharing must be entered. This window is no longer part of our online offer, but is provided by the provider of the social media sites where the content is to be shared or another provider. To this extent, the information on the use of social media channels apply (see below).
We believe that, due to the protective measures taken (anonymization and the option to object), data processing for the optimization of our website is to be regarded as a legitimate interest in data processing in accordance with global privacy regulations.
We offer you the opportunity to apply for a job with the NTT DATA Business Solutions Group directly through our online application form.
Use of Personal Data in the case of an application
All Personal Data from your application and all attachments you provide in your application will only be collected, processed and used by us and our subsidiaries for the purposes of the applicant selection procedure and for internal statistics. Your Personal Data will be stored and processed in accordance with the applicable data protection regulations. The Personal Data is stored on an NTT DATA Business Solutions AG server in the Federal Republic of Germany and shared with our national affiliates where appropriate.
Only those responsible for human resources and, in special cases, selected NTT DATA Business Solutions Group executives, will have access to your Personal Data. Your information will be treated as strictly confidential. No Personal Data will be disclosed to third parties outside the NTT DATA Business Solutions Group unless necessary for the execution of a customer contract or further employment opportunities.
Saving your application
We will store your Personal Data in our system in order to match possible queries and, if applicable, to contact previous applicants in the event of new vacancies. You have the right to object to the processing of your Personal Data with future effect or to request that your Personal Data be updated, corrected, blocked or deleted. Please inform us at any time by sending an email to [email protected].
If you have applied for an advertised position, the documents will automatically be deleted three months after the recruitment process is concluded, provided there are no other legitimate interests that conflict. In the case of an application without reference to an advertised position (unsolicited application), the application is kept for as long as there is the possibility that the application may be of interest. You have the option to request deletion of your application at any time, even before the intended retention periods have expired. In the event of a successful application, the transmitted data will be stored in compliance with legal requirements for the purpose of processing the employment relationship.
Please note that your disclosures are voluntary within the scope of your application.
Communication with NTT DATA Business Solutions
You can contact us in various ways, including through the contact form on our website and the various social media channels. You are also welcome to receive regular issues of our newsletter by email.
If you wish to use the contact form in our website, Personal Data such as name and email address will be requested. We collect and use the data transmitted through the contact form exclusively to enable us to respond to your request or your concern.
You may decide for yourself what information you want to submit to us via the contact form. After we have dealt with the matter, the data will initially be stored in case there are further inquiries. Deletion of the data may be requested at any time; otherwise, data is deleted after complete resolution of the matter. Legal storage requirements continue to apply in any event.
Social media channels
You will find links to social networks on our website. The links can be recognized by the logo of the respective provider.
Clicking on the links will open the corresponding social media pages, to which this data protection policy does not apply. Please see the privacy policies of the individual providers for details of the provisions that apply there; you will find these, for example, at:
No Personal Data is transmitted to the respective providers before the corresponding links are accessed. Access by you of the linked page is simultaneously the basis for data processing by the respective provider.
When registering for our newsletter, your email address will be used for our own advertising purposes until you unsubscribe. If the form of address, first name and last name are also requested, the corresponding data serve as the form of address in the newsletter. These data are not combined with any other data.
If you no longer wish to receive newsletters from us, you may object to this at any time, simply use the unsubscribe link included in each newsletter or send a message in text form to us or to our data protection officer (e.g., email, fax, letter).
What information we collect and for what purpose?
If you provide us with your email address, we will communicate with you by email. We will not disclose your email address to third parties outside the NTT DATA Business Solutions Group. If you no longer wish to receive email from us, you can inform us at any time. When you send us an email, Personal Data may be transmitted automatically, depending on the settings of your email program. We will also treat this as confidential. If you register for services provided by third parties outside of NTT DATA Business Solutions AG, it’s global affiliates and subsidiaries, it may be necessary to provide parts of our registration information to the relevant service provider, including your email address. This is only done if it is necessary within the framework of the service you have requested.
Orders and registration for events
Our website includes order and registration forms that you can fill out to request information, products and services. The data will be stored by us for as long as it is necessary to fulfil the purpose of data collection. In addition, we store this data for the legally prescribed period to fulfil post-contractual obligations and due to commercial and tax retention periods.
Our surveys may ask you for demographic information such as zip codes or your industry. If contact information is collected in the survey, we will use it only to send you further information if you have explicitly consented for us to do so in the context of the survey. Here, too, you have the option of revoking this approval at any time. You may choose what information you provide to us in the context of the online surveys.
Links to other websites
Our website contains links to websites of other providers. We have no influence over whether these providers comply with the applicable data protection regulations. We are not responsible for the data protection practices or content of other websites. We therefore recommend that you also consult the respective data protection policy on other websites.
Use of contact information
Contact data published as part of the legal requirement to provide company information may not be used to send unsolicited advertising or information. The use of such data for this purpose is hereby expressly prohibited. We expressly reserve the right to take legal action in the event that unsolicited advertising is sent, such as through spam email.
We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your Personal Data. Unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us in accordance with the “Questions and Contact Information” section above (note that physical mail notification will delay the time it takes for us to respond to the problem).
Enforcement and Dispute Resolution
Any questions or concerns regarding the use or disclosure of client data should be directed to the NTT DATA Business Solutions Privacy Office listed above.
Updated Effective Date: April 1, 2021
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