Privacy Policy

Privacy Policy

TwentyEighty Strategy Execution, Inc., a member of the TwentyEighty, Inc. family of companies, is committed to protecting the privacy of those who visit our websites and with whom we do business. As part of our normal operations, we collect different kinds of information about our website visitors. We have, however, structured our websites so that people have the option to visit without identifying themselves or revealing any personal information.  

The following are things you can do while visiting our website if you prefer NOT to have information about your visit collected.  

  • Disable cookies within your browser before visiting our website (you may also click here to manage your cookie settings with respect to this website);
  • Choose not to submit information via web forms located within our website;
  • Choose not to purchase from our online store (if applicable);
  • Choose not to “opt-in” to certain programs that are available on our websites;
  • Choose not to complete any surveys available on our website. 

COOKIES AND SPOTLIGHT IMAGES OR WEB BEACONS 

We sometimes use session cookies to limit popup windows to a single browser instance. We also use Javascripting in cooperation with cookies and “spotlight images” or “web beacons” to track website traffic and email response. A “spotlight image” or “web beacon” is an electronic image, called a 1-by-1 pixel or clear GIF, that can recognize certain types of information on your computer, such as a cookie number, time and date of a page view and so on. These methods do not collect any personal information, but simply aggregate information that allows us to research patterns of behavior on our site to learn how to better meet our visitors’ needs. Our online store uses cookies to store order information. You may refuse cookies by turning off that feature on your web browser. 

This website uses Marketo Munchkin cookies (“Marketo”). Marketo's cookie allows us to track repeated visits to the website, and link each visit to the information voluntarily provided by the visitor. For example, if the visitor is asked to provide us with name, company name and email address, we will know the identity of the visitor when they visit the site at a later date. We also use Munchkin to track email open rates and click through rates, allowing us to manage the email marketing experience. By using this website you are consenting to the above use of your data. 

For more information on Marketo’s privacy and cookie policy, please visit Marketo privacy policy: http://www.marketo.com/trust/legal/privacy

In addition, we may use or allow third parties to serve cookies on our site – specifically we use Google Analytics in addition to Marketo to help us monitor our website traffic and understand visitor behavior. 

INFORMATION WE COLLECT 

You may be visiting our website for a variety of reasons. For the purpose of this privacy policy, we will classify these reasons as (i) browsing, (ii) submitting forms, (iii) purchasing products and services and (iv) completing surveys. Please note that not all activities may be available on our website at a given time. For each different type of activity, we collect and store different types of data for different reasons. 

Browsing – If you are simply browsing or navigating through our websites, we collect information about your computer and the pages you visit on our website in the aggregate (not individual or personal information). This data is often referred to as clickstream or navigation data. We use this information for research, analysis and reporting so that we can improve our navigation, page structure and page content to help visitors find information more quickly and provide more value when they find what they are looking for on our websites. 

Submitting Forms – Certain pages of our website contain forms that allow you to request information about our services and solutions or to gain access to valuable resources (like white papers and research documents) in exchange for contact information. In completing one of these forms, you may be required to provide contact information, such as your name, phone number and/or email address. 

Purchasing – For purchasing in our online store or registering for events or courses, we will require you to create an account with us. We collect information in this account that enables us to complete your order and/or registration and streamline your purchasing process the next time you order from us. Furthermore, we will give you the ability to view and update this information if you so choose. 

Completing Surveys – For surveys, we collect responses to help us improve various aspects of our business based on aggregate and individual feedback provided. These surveys are sent via opt-in marketing programs or are made available on our website for you to participate if you so choose. 

HOW WE USE AND SHARE YOUR INFORMATION 

If you choose to provide us with your personal data, as contemplated above, in addition to using the data for the express purpose for which it was provided, we may , if permitted by applicable law, use your information to: 

  • Process a payment that you have made
  • Process orders that you have submitted
  • Carry out our obligations arising from any contracts entered into by you and us (or by your employer and us)
  • Seek your views or comments on the services we provide through surveys or otherwise
  • Notify you of changes to our services
  • Send you communications that you have requested or that may be of interest to you, including activities or promotions of our products or services, or those of our affiliates
  • Send you newsletters, event notices and announcements
  • Process a job application    

As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, we have implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries worldwide and transfer it to countries in the world where we do business in accordance with this Privacy Notice.  

Between our controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process personal information on our behalf.  

Where appropriate, we may also share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.  

If we decide to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is our practice to require appropriate protection for personal information in these types of transactions.  

If you do not wish for us to use your data in the ways described above, you may follow the instructions contained in the relevant communication, update your communication preferences in your online account (if applicable), or follow the instructions below, under the heading “YOUR RIGHTS.”   

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect our rights or property, or that of our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected. We may place email links on this site to allow you to contact us directly via email. The information you provide is used to respond directly to your questions or comments. Those comments may be stored to improve the quality of our site and our services.  

In addition, from time to time, we will purchase or rent relevant public mailing lists from reputable agencies that have obtained your prior approval to receive relevant information based on your personal preferences. Any promotional information sent to you by us will contain instructions on how to be removed from a mailing list source. We will also freely provide information about how and from whom your personal details were given to us when requested.  

International Transfers  

Our international footprint may involve the transfer of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information.  Where required, we implement Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties.  

Information Security and Accuracy  

We intend to protect your personal information and to maintain its accuracy. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure.  

Retention Period  

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.  

Because the circumstances may vary depending on the context and the services, the information provided in Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms.  In the event that we process your data for marketing purposes, we will delete your data annually if we have not received any responses to our marketing activities for a period of three years.  

How to contact us  

If you have a question related to this Privacy Notice, please contact us by sending an email to privacy@twentyeighty.com. Your message should include our company name (so that we can identify which TwentyEighty company you are contacting us about) and will be forwarded to the appropriate member of our legal or compliance team.  

For the purposes of the EU General Data Protection Regulation (GDPR), the controller of your personal information is TwentyEighty Strategy Execution,Inc., Attn: Data Privacy Officer, 10901 W. Toller Drive, Suite 202, Littleton, Colorado 80127, United States of America.  

TwentyEighty Strategy Execution, Inc. is not the controller in situations such as personal information processed in connection with a contractual relationship. In this case the controller of personal information is company with which we have contracted (such as your employer) unless otherwise agreed in that contract.  

Your Rights  

You can request to access, update or correct your personal information. You also have the right to object to direct marketing. To make such a request or lodge such an objection, please send an email to privacy@twentyeighty.com.  Please specify our company name (so that we know which company you are contacting us about) and provide details of your request.  We will contact you if we need more information to process your request.  

You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information. You can make these requests by sending an email to privacy@twentyeighty.com, providing the details of your request.  

Right to Lodge a Complaint  

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint directly with us by sending an email to privacy@twentyeighty.com and providing specific details of the complaint, including the name of the company to which it pertains.  You may also be eligible to lodge a complaint with the competent data protection authority.  The names and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

CHILDREN  

We are concerned about the privacy of young children and do not knowingly collect any personal information from a child under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our records and systems.  

SECURITY  

We employ procedural and technical measures that are designed to help protect your personal information from loss, unauthorized access, disclosure, alteration or destruction. However, we cannot guarantee that third parties will not overcome any such measures and gain access to your information for unauthorized purposes. By using the website, you accept the risk that compromise of and unauthorized access to your information is possible. To the fullest extent permitted by law, we disclaim any warranty or guarantee that your information will be protected from misuse, appropriation, alteration, or loss.  

All data submitted in our online store (if any) is submitted using secure transport technologies to provide you with the utmost in protection for your private information.

BLOGS

Our Web site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

NEW TECHNOLOGY

Since the use of new technology including cookies, web beacons, and other technology is rapidly evolving, as is our use of new and evolving technology, we may change or use additional or new technology from time to time. You are encouraged to visit this page for any updates regarding these new technologies.

COUNTRY-SPECIFIC RESTRICTIONS

Any materials published on the Site may refer to products, programs, or services that are not available in your country.

The Site is hosted by TwentyEighty Strategy Execution, Inc. from the United States. If you provide personal information to us, it may be transferred to and processed on computers in the United States and other countries, if permitted by applicable law. Your provision of personal information to us will be handled in accordance with this Privacy Policy and applicable law. Your provision of personal information to us through the Site means that you agree to the terms of this Privacy Policy.

TwentyEighty Strategy Execution, Inc. makes no representation that the Site is appropriate or available for use at other locations outside of the United States. Access to the Site from territories where the Site’s content is illegal is prohibited. If you access the Site from a location outside of the United States, you are responsible for compliance with all applicable laws.    

OTHER INFORMATION  

Links  

This website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.  

Disclosure of Information  

We may disclose or access customer information when we believe in good faith that the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation or civil or administrative authorities in connection with a pending civil case or administrative investigation.  

Terms of Use  

The content on this website is copyrighted material owned by us. It is provided for your general information and use only, and is subject to change without notice. We reserve all rights with respect to the website, including without limitation, copyright and intellectual property rights. The website is provided on an “as is” basis. We make no representations or warranties of any kind, express or implied, with respect to the accuracy, completeness, suitability, timeliness, availability or reliability of the website or the information or materials found or offered on the site. We disclaim all implied warranties, including without limitation, warranties of merchantability, fitness for a particular purpose, accuracy of data and non-infringement.  

Neither we nor any of our affiliated companies, directors, officers, employees, partners, or owners shall be liable for any loss or damage whatsoever related to the use of this website. Any claim or cause of action arising out of or related to the use of the website shall be governed by the laws of the State of Delaware regardless of where the website was accessed or the country of origin of the claimant.  

QUESTIONS ABOUT THE PRIVACY POLICY  

If you have any questions or complaints about this privacy policy, the practices of this site or your interactions with this site, please contact:  

TwentyEighty, Inc.
Attn: Data Privacy Officer
10901 W. Toller Drive, Suite 202
Littleton, Colorado 80127
United States of America
privacy@twentyeighty.com  

Please note that any requests described above to be made to privacy@twentyeighty.com may also be made by sending a letter to the above postal address.  Any such letter should include contact information – preferably an e-mail address - so that we can contact you.  Requests made by standard mail will take longer to process due to the time it takes for correspondence to be exchanged.  

CHANGES TO THIS PRIVACY POLICY  

We reserve the right to update or modify this policy at any time.