1. Who We Are
2. What We Do
TRACC is our “product” – a solution that provides an Integrative Improvement System that delivers sustainable business improvement results through best practice and work process improvement. In short, we make manufacturing better.
3. What We mean Mean by “Personal Information’ and “Data Subject”
“Personal Information” refers to any information that is associated with you the “data subject”, such as your name, contact email address, company you work for, job title, work telephone number, work address, etc. “Special Personal Information” refers to your sensitive Personal Information such as medical information or biometric information.
4. Our Websites
- community.traccsolution.com (an online community sharing best practice)
You do not need to register in order to use our websites. As a visitor to our websites, we automatically collect information about your computer hardware and software including IP addresses, browser types, domain names, access times and referring website addresses. We do not associate this with your Personal Information unless you have chosen to share this with us by registering on our website.
If you do choose to share your Personal Information with us, we collect your name, email address, address and phone number.
4.1 What cookies and web beacons are
A cookie is a text file that is placed on your hard disk by a web server when you visit that site (unless you have disabled cookies on your device). Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
When you visit our websites or web-based applications, we may use both a session and a persistent cookie. Such cookies may contain information (such as a unique user ID) that is used to track your usage of our websites or web-based applications. We employ cookies to enable our systems to recognize your browser and tell us how and when pages on our websites and web-based applications are visited and by how many people, and also in order for our server to recognize a return visitor as a unique user. The cookies placed by our servers are readable only by us and cookies cannot access, read or modify any other information on a computer.
4.3 How we use web beacons
We use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails we send you. We may, for example place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our websites. We use web beacons to operate and improve our websites, web-based applications and email communications.
4.4 How to turn off cookies
The “Help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie or how to fully disable cookies. If you leave the cookies activated, they will enable you to take advantage of some of our most attractive features. They may also save you time. When you return to our website, the information you previously provided can be retrieved, so that you can easily access the features that you customized.
If you choose to disable cookies, you may not be able to fully experience the interactive features of our websites or web-based applications.
4.5 Our value- added services
There may be times when you choose to share your Personal Information with us in order to register for certain events or our value-added services, or to request information from us about topics that are of interest to you (“opting-in”). You can do so by visiting community.traccsolution.com and clicking the “register” button to “opt-in”. Thereafter, anything that we share with you will provide you with the opportunity of unsubscribing (or “opting out”) with one click.
Examples of times that you may consent to register for services and/or value-added services (i.e., to “opt-in”) are:
- You want access to our cutting-edge thought leadership publications:
We release thought leadership publications in the form of industry analysis reports, white papers, how-to guides, articles and blog posts. Some of these are only available for download once you have registered with us. We require registration because we’d like to know more about who is interested in our thought leadership, so that we can share with them more of what they are interested in, and so that we can provide a publishing service that is up-to-the-minute and relevant to your needs.
- You want to take part in our surveys, or have us share our research findings with you:
We sometimes conduct industry-relevant surveys around best practices, which you might find interesting. Apart from the feedback we get through the completion of the survey questions by participants, we may require some Personal Information (usually your name and email address) to prevent the processing of duplicate responses.
- You want to be invited to our events:
We host events around the world. Registration for our events usually takes place online, either through our websites or through third-party websites (e.g., a website belonging to a host-hotel or event organizer). Registration for events will require some Personal Information to be filled out on registration forms and this Personal Information will be accessed by us and the host-hotel or event organizer (if there is one). We also sometimes host an exhibition stand at an industry event. At such events, people sometimes choose to leave their information with us so that we can later send them additional information about our products and/or services.
- You want to stay informed about product/version upgrades:
From time to time, we introduce substantial upgrades to our products in order to stay in line with technology trends and best practice. We use Personal Information to help our registered users to upgrade their products.
- TRACC Community:
The “TRACC Community” is an interactive online forum where industry insiders and improvement professionals can register in order to see and discuss best practice examples of “what good looks like”. Registration and participation is voluntary. You may delete your profile, comments and/or submissions at any time.
4.6 Collection of Personal Information from our websites: what is collected and how it is used
We collect and use Personal Information to operate our websites, to deliver on our contractual services (when applicable) and/or to provide you with the value-added services listed above. We may also use this information to inform you of other products or services available from us and our affiliates. We may contact you via voluntary surveys to conduct research on your opinion of current or potential new services. We may send you emails or postal mail, provide customer support services, arrange for deliveries or contact you based on your interest in receiving such communications.
When you post a response to content on our websites (“comment”), or submit a photograph via the TRACC Community submissions page, we will ask you for personally identifiable information. This Personal Information may be used by us to contact or identify you. We will only use your Personal Information for legitimate business purposes in accordance with the terms set out herein, e.g., to respond to your enquiries or to provide the value-added services to you. Your comments will be visible to viewers of our websites.
We also collect other information through your use of our websites (e.g., your user activity, the pages of the website that you visit, time spent on these pages and other statistics) through the use of standard technology such as cookies, web beacons and other web technologies. We analyse this aggregated information in order to improve our services, to plan site enhancements and to measure overall site effectiveness.
5. Use of Our Applications by Our Clients
TRACC device installed (“native”) applications:
- TRACC Reader for Windows
- TRACC Reader for Android
- TRACC Reader for iOS
Only registered TRACC clients with an official organizational email address are able to use our applications. The creation of a TRACC account and access to our applications will be dependent on the Services Agreement between CCi and your organization.
5.1 Collection of Personal Information in applications: what is collected and how it is used
We collect and use information to operate our applications, and deliver on our contractual obligations to you. This information may include your name, business title, your business contact details, including your email address and the name of the organization you work for, your geographical location or the location of your business unit in the organization.
We also collect user activity information within our applications, which we use for analytical and statistical purposes. We do this so that we can provide our clients with reports about their user activity and to improve our product. User information is only shared within the organization you are part of, and is not related to Personal Information (such as name, username or email address).
Our applications may collect other, nonidentifiable information about the use of our applications by way of standard technology such as cookies, web beacons and other web technologies.
Any user information you provide while using our applications (including but not limited to documents, images and videos), is regarded as confidential and proprietary to your organization, and will be secured in terms of the Services Agreement between us and your organization.
6. Sharing of your Your Personal Information
We do not sell, rent or lease your Personal Information to anyone.
We may send your Personal Information to third parties who perform services for us (called “Information Processors” or “Operators”). Where we do this we make sure that:
- They agree to only use your Personal Information for the purposes that we tell them to
- They agree to keep your Personal Information secret and secure
- They agree to tell us as soon as they can if they have any security breach and they help us solve the problem
7. International Personal Information Transfer
As we are a group of companies in several different countries, we will transfer Personal Information to countries outside the one that you are in. You can find these countries in our “contact us” page.
We may also transfer Personal Information to countries within your group of companies in order to comply with our contract with you. We will only do this at the instruction of your company, and it is your company’s responsibility to ensure that the companies we send Personal Information to are complying with information protection legislation.
8. External Websites
9. Retention and Disclosure of Personal Information
In general, we will retain records of all Personal Information we collect and the specific purpose for which it was collected for a period of 18 months from the date on which it was last used.
Information of registrants that are inactive on our websites for a period of 18 months will also be deleted from our websites’ systems.
We will not disclose any Personal Information to any third party unless your prior written agreement is obtained, to protect and/or defend the rights or property of CCi or if we are required to do so by law. If Personal Information is released we will, for a period of one year, retain a record of the Personal Information that was released, the third party to which it was released, the reason for the release and the date of release.
We do not collect or retain any credit card information. Please be aware that event organizers and hotels, which may be associated with our events, have their own payment requirements and devices as well as their own privacy practices and controls.
10. Your Rights
You have the right to:
- Request access to your Personal Information (commonly known as an “information subject access request”). This enables you to receive a copy of the personal information CCi holds about you and to check that we are lawfully processing it.
- Request correction of the Personal Information that CCi holds about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, although we may need to verify the accuracy of the new information you provide to us. You can effect the necessary change on the relevant contact form or by updating your user profile. Any request for a correction must specify both the incorrect information and the proposed correction, and must give reasons for the request.
- Ask us to delete your Personal Information. This enables you to ask us to delete or remove Personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons. If this happens, we will let you know why we have not deleted your information and you can object to this. We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal regulatory, tax, accounting or reporting requirements. (In certain jurisdictions we need to keep certain basic information about our customers – including contact, identity, financial and transactional information – for stipulated periods after they cease being customers for tax or legal purposes.) We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation. In some circumstances, we will anonymize your Personal Information (so that it can no longer be associated with you) for research and statistical purposes, in which case we may use such information without further notice to you.
- Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling, legitimate grounds to process your information.
- Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following situations:
- If you want us to establish the information’s accurac
- Where you need us to hold the Personal Information even if we no longer require it as you need it to establish, exercise or defend legal claims
- If you have objected to our use of your Personal Information, but we need to verify whether we have overriding legitimate grounds to use it
- Request the transfer of your Personal Information to you or to a third party. We will provide you, or a third party you have chosen, with your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information where we used the information to perform our duties in terms of a contract with you.
- Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Free access to your Personal Information. You will not have to pay a fee to access your Personal Information (or to exercise any of the rights mentioned above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in such circumstances.
10.1 Authentication of your requests
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.2 30 calendar days to respond
We will try to respond to all legitimate requests within 30 working days. Occasionally it could take us longer than 30 days if your request is particularly complex or if you have made a number of requests. If this happens, we will let you know.
To exercise your rights or raise any questions you have about our use of your Personal Information, please contact our Privacy Team at firstname.lastname@example.org.
You may also use the above listed contact details if you wish to direct a complaint to us relating to your Personal Information or privacy.
11. Applicable Law
All website-related matters are managed centrally from South Africa, which means that South African law applies and the Responsible Party is Competitive Capabilities International (Pty) Ltd (please see our contact us page for more).
12. Security of Your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure, and these secure servers are only accessed by authorized personnel. When sensitive Personal Information is collected on our websites, web-based applications or native applications and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
Users and/or subscribers are prohibited from releasing their username and/or password to any other person.
13. Persons below the Age of 18 Years
CCi, TRACC and any of our websites or applications mentioned above, including our community pages, are not intended for use by persons under the age of 18 years. Our websites, applications and activities are not designed for or targeted at persons under the age of 18 years. We will not knowingly collect, maintain or process any information about persons under 18 years. Provided it is practical, we will delete the Personal Information of persons under 18 years once we are aware of it.
14. Job Applicants
15. Unsubscribing from CCi
If you have shared your Personal Information with us and “opted-in” or registered for certain events or value-added services such as downloading reports or white papers, etc., you may receive periodic promotional emails and special offers from us, which we feel are relevant to you. You may unsubscribe from these emails at any time using the “Unsubscribe” link at the bottom of each email. Please note, however, that if you have opted out from receiving any future communications from us, we will need to keep your contact details on an “opt-out” list in order to ensure that no further communication is sent to you.
Applicable from: 10 September 2018
Last Updated: 18 October 2018