Privacy Notice

Information collection

Personal Information refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, or household.

We may collect Personal Information when you interact with the Website or Mobile App or because you give it to us (for example, in a form on our Website or Mobile App). Depending on the specific Communication you are receiving, or the Web page of the Website or Mobile App you are using, such information may consist of: your name; current job title; company name; e-mail address; country of residence; telephone and fax number(s); physical address(es); gender; date of birth; marital status; employment and education details (such as learning history, work experience and skills); geolocation; certificate or license number; account number; photograph, video or audio recording identifiable to an individual; your postings on any blogs, forums, wikis and any other social media applications that we provide; your IP address; your browser type and language; your access times; complaint details; correspondence with you; the newsletters you subscribe to; information relevant to providing services to you; and any other information that you voluntarily provide to us. We may also collect or obtain Personal Information from you because of the way you interact with us or others.

Platform Data (Assessments, Management Tools, and Connected Systems). We may collect Personal Information and business-related information that you provide when you complete assessments, use management tools (including VoC and 5-Why), upload or enter operational information, invite colleagues, or otherwise use the Platform. Where you choose to connect third-party systems (for example, QuickBooks), we may access and process financial information made available through that connection solely to generate summaries, analyses, and reports for your organization, as described in the “Information use” section below.

We do not usually seek to collect ‘sensitive’ or ‘special categories’ of Personal Information (e.g., data relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying the sex life or sexual orientation of an individual) through your use of this Website. The types of ‘special categories’ of Personal Information that we collect may vary depending on how you use this Website. In some rare circumstances, we might gather special categories of Personal Information about you because you volunteer that data to us, or we are required to gather that data as a result of legal requirements imposed on us. We will, where necessary, obtain your explicit consent to collect and use such information.

We understand the importance of protecting children’s privacy. Our Website is not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.

Log information, cookies and web beacons

When you access the Website or Mobile App, we may collect standard Internet log information including your IP address, browser type and language, access times and referring website addresses. To ensure that the Website, Mobile App and Communications are well managed and to facilitate improved navigation, we or our service provider(s) may also use cookies (small text files stored in a user’s browser) or web beacons (electronic images that allow us to count users who have accessed particular content and to access certain cookies) to collect aggregate data. Additional information on how we may use cookies and other tracking technologies and how you can control these can be found in our Cookie Notice.

Information use

Use of Personal Information collected via our Website or Mobile App

• We may use your Personal Information collected:
  • to verify your identity each time you log in to the Website;
  • to manage your account and improve our Website or Mobile App;
  • to manage and promote collaboration and communication;
  • to provide and document training and qualifications;
  • to tailor the content of our Website or Mobile App to provide you with a more personalized experience; and
  • to manage our relationship with you and respond to any request you submit through our Website or Mobile App.

Use of Personal Information collected via our Platform (Assessments, Management Tools, and Reports)

• We may use Personal Information and business-related information collected via the Platform to:
  • provide assessment functionality, management tools, dashboards, and reporting features;
  • generate analytical insights, summaries, benchmarks (where available), and recommendations for business improvement;
  • administer invitations, tokens, user access, and collaboration within an organization; and
  • maintain records of activity needed to operate, secure, and support the Platform.

Financial Data via QuickBooks (and Similar Integrations)

• Where you connect QuickBooks (or another supported provider), we may use information made available through that integration to generate financial analyses and reports for your organization. We do not sell financial information.
• We do not store raw, transaction-level accounting records as part of the Platform’s standard operation. Financial information is processed to produce reports and insights and is not retained as raw accounting records beyond what is reasonably necessary to generate and deliver the requested reports or maintain basic system functionality (e.g., report outputs, audit/security logs, and integration status).
• You may disconnect integrations in accordance with the provider’s settings and your Platform configuration.

AI-Assisted and Automated Report Generation

• We may use automated analytical systems, including artificial intelligence (“AI”), to help generate executive summaries, diagnostic narratives, benchmarks, insights, and recommendations based on information you provide or authorize through the Platform.
• AI-assisted outputs are provided for informational and strategic planning purposes and should be reviewed by you before making business decisions.

Use of Personal Information for other activities that form part of the operation of our business

• In addition to the purposes connected to the operation of our Website and Mobile App above, we may use your Personal Information for the purposes of, or in connection with:
  • applicable legal or regulatory requirements;
  • requests and communications from competent authorities;
  • sending you thought leadership or details of products and services provided by DD9 that may be of interest to you; contacting you to receive feedback on these services; and contacting you for other market or research purposes; and
  • protecting our rights.

Access to the Website or Mobile App may be subject to review, monitoring and recording at any time to help us confirm compliance with applicable Terms of Use and that only authorized parties are accessing the Website.

SMS/MMS Messaging (A2P 10DLC) and Consent

Overview. DD9 may send SMS and/or MMS messages (“text messages”) to the mobile number you provide when you interact with our Website, Mobile App, Platform, or Communications. Depending on what you opted in to receive, these messages may include operational or transactional notices (for example, appointment reminders, service notifications, or account updates) and, where you have separately opted in, promotional or marketing messages.

Message frequency; message & data rates may apply. Message frequency varies based on your engagement, the program you opt into, and your communication preferences. Message and data rates may apply depending on your mobile carrier plan.

Consent is not a condition of purchase. Your consent to receive text messages is not a condition of purchasing any goods or services.

Opt-out and help. You can opt out of text messages at any time by replying STOP. For help, reply HELP. You may also contact us using the details in the “Contact information” section below.

Opt-in methods and required disclosures. We collect text messaging consent using one or more of the following methods. Where required, DD9 maintains records of consent consistent with applicable law and carrier requirements:

• Web form opt-in. When we collect your mobile number via a website form, booking page, landing page, or similar online form, we provide a clear opt-in disclosure and a dedicated SMS consent checkbox (or equivalent affirmative action). This SMS consent mechanism:
  • is not pre-checked;
  • is presented separately from other permissions (for example, separate consent for marketing vs. non-marketing notifications where applicable);
  • clearly identifies the sender/brand as Data Driven 9 Consulting LLC;
  • describes the types of messages you may receive (for example, reminders, notifications, and/or offers);
  • discloses that message frequency varies (or states an expected frequency when applicable);
  • discloses that message & data rates may apply;
  • includes STOP and HELP instructions; and
  • includes links to this Privacy Notice and our applicable Terms and Conditions/Terms of Use.
• Verbal opt-in. If you provide consent verbally (for example, during a call), we will provide the required disclosures at the time of consent and may send a confirmation message afterward.
• Double opt-in (where used). For certain programs, we may send a confirmation message requiring you to confirm your enrollment (for example, by replying “YES”) before you receive recurring messages.

Example opt-in disclosure language. The following is an example of the disclosure we may present at the point of opt-in (this is an example and may be adapted per program):

“I consent to receive SMS/MMS messages from Data Driven 9 Consulting LLC regarding reminders, notifications, and/or marketing. Message frequency varies. Message & data rates may apply. Reply HELP for help and STOP to unsubscribe. By opting in, you agree to our Privacy Notice and Terms.”

Confirmation message. After you opt in, we may send an opt-in confirmation message that includes the brand/program name, customer care information, opt-out instructions (STOP), help instructions (HELP), and the “message & data rates may apply” disclosure.

Use and sharing of mobile numbers. We do not sell your mobile telephone number. We may share your mobile number and related messaging data with service providers (such as messaging platforms and carriers) only as necessary to deliver and manage text messages and consistent with this Privacy Notice and applicable law.

Legal basis for processing information

We are required by law to set out in this Privacy Notice the legal grounds on which we rely in order to process your Personal Information.

We use your Personal Information for the purposes outlined above because of: (a) our legitimate interests in the effective delivery and security of our Website, Mobile App (if applicable), Platform and related services offered to you; (b) our legitimate interests in the effective and lawful operation of our Website, Mobile App and Platform so long as such interests are not outweighed by your interests; (c) the legal and regulatory obligations that we are subject to; and (d) where required, your consent (for example, for certain communications and marketing).

To the extent that we process any sensitive Personal Information relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) the processing is necessary for the establishment, exercise or defense of legal claims; or (iii) you have made the data manifestly public.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can unsubscribe from the Communication.

Disclosure of information to third parties

In connection with one or more of the purposes outlined in the “Information use” section above, we may disclose details about you to: third parties that provide services to us (for example, hosting, analytics, communications, security, messaging providers, and customer support); competent authorities (including courts and regulators) and other third parties that reasonably require access to Personal Information relating to you for one or more of the purposes outlined in the “Information use” section above.

In relation to Mobile Apps, we may also share your usage and Personal Information with mobile carriers and platform providers, as well as any other entities described in any particular Mobile App in connection with the operation of the Mobile App.

In relation to Communications, we may also share your Personal Information with service providers in connection with the delivery of such Communications.

We may also need to disclose your Personal Information if required to do so by law, by a regulator or during legal proceedings.

Service providers and integrations. We may share Personal Information with vendors and service providers that help us operate the Platform (for example, hosting, analytics, communications, security, messaging providers, and customer support). Where you connect third-party systems such as QuickBooks, information may be transmitted between DD9, the integration provider, and your authorized systems as needed to perform the integration and generate reports. We share only what is necessary to provide the requested functionality and do not sell Personal Information.

Please note that some of the recipients of your Personal Information referenced above may be based in countries without data protection laws similar to those in effect in your area of residence. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Information that comply with our legal obligations.

Under applicable law, you may be entitled to request information concerning whether your Personal Information has been disclosed to nonaffiliated third parties for their direct marketing purposes. We do not share your personal information with nonaffiliated third parties for such purposes.

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

Selling of information

We do not sell your personal information.

Blogs, forums, wikis and other social media

The Website or Mobile App may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively referred to as “Social Media Applications”). Any personal information or other information that you contribute to any Social Media Application can be read, collected and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse or misappropriation of any personal information or other information that you contribute to any Social Media Application.

Privacy practices of third parties

This Privacy Notice addresses only the use and disclosure of information we collect through your interaction with the Website or Mobile App and Platform. Other websites or applications that may be accessible through links from the Website or Mobile App have their own privacy notices and personal information collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy notices provided by these other parties prior to providing them with information.

Do not track

“Do Not Track” is a preference you can set in your web browser to let websites and applications you visit know that you do not want them collecting information about you. The Website does not currently respond to a “Do Not Track” or similar signal.

Information security

We use a range of physical, electronic and managerial measures to keep your Personal Information secure, accurate and up to date. These measures include:

• education and training to relevant staff so they are aware of our privacy obligations when handling Personal Information;
• administrative and technical controls to restrict access to Personal Information on a ‘need to know’ basis;
• technological security measures, including fire walls, encryption and anti-virus software; and
• physical security measures, such as staff security passes to access our premises.

Although we use appropriate security measures once we have received your Personal Information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect Personal Information, but we cannot guarantee the security of data transmitted to us or by us over the internet.

Information retention

We will hold your Personal Information on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in respect of the services.

Your rights

Under applicable law, you may have various rights in relation to your Personal Information. In particular, you may have a right to:

• obtain confirmation that we are processing your Personal Information and request a copy of the Personal Information we hold about you;
• ask that we update the Personal Information we hold about you, or ask that we correct such Personal Information that you think is incorrect or incomplete;
• ask that we delete Personal Information that we hold about you, or restrict the way in which we use such Personal Information; and
• object to our processing of your Personal Information.

Where applicable, if you decide that you no longer wish to have your third party social network site account (e.g., LinkedIn, Facebook, or Twitter) linked to your profile on the Website, please change the settings in your third-party social network site account.

If you are unsatisfied with the way in which we have handled your Personal Information or any privacy query or request that you have raised to us, you have a right to complain to the data protection authority in your jurisdiction. For such information, please contact us by using the “Contact information” section below.

Verification of Personal Information requests

For certain personal information requests, we must first verify your identity before processing your request. To do so, we may ask you to provide us with your full name, contact information, and relationship to DD9. Depending on your request, we may ask you to provide additional information. Once we receive this information, we will then review it and determine whether we are able to match it to the information DD9 maintains about you to verify your identity.

Third party requests

If you are submitting a personal information request on behalf of someone other than yourself, please contact us by using the “Contact information” section below and include proof that you are authorized to make the request. This may be in the form of a written authorization signed by the person whom you are acting on behalf of or a valid power of attorney.

Contact information

To exercise your rights or if you have any questions concerning your privacy while using the Website or Platform, please contact us at info@ddnine.com or +1 407 346 5054.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time.

To let you know when we make changes to this Privacy Notice, we will amend the revision date at the top of this page. The new modified or amended Privacy Notice will apply from that revision date. Therefore, we encourage you to periodically review this Privacy Notice to be informed about how we are protecting your information.

This Privacy Notice was written in English (U.S.). To the extent any translated version of this Privacy Notice conflicts with the English version, the English version controls.