Privacy Policy

CCi – Competitive Capabilities International (Pty) Ltd, registration number registration number 64/3315/07 – (also referred to as “we”, “us”, or “our”) is a global organisation – the people behind TRACC. 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.

Therefore, for the purposes of this Privacy Policy, “CCi” refers to the global organisation headquartered in Cape Town, South Africa, with offices in various locations around the world. In this document, “CCi” also refers to our product (TRACC), the TRACC online community, as well as any entities licensed to sell TRACC. This is our group-wide Privacy Policy.

CCi is committed to protecting your privacy. This Statement of Privacy applies to the following CCi websites:

TRACC Community — an online community of best practice where you can see what good looks like

TRACC websites and TRACC software platforms:

By using the CCi websites or services platforms, you are agreeing to the use of your information as set out in this Statement of Privacy. Furthermore, use of our Sites confirms your consent to the contents of this Statement of Privacy, as well as our Terms of Use.

What we mean by “personal information”
“Personal information” refers to any information that can be used to identify you, which you voluntarily share with us upon registering for certain services. For us, personal information usually refers to one or more of the following personal identifiers: your name, contact email address, company you work for, job title, work telephone number, work address, etc. If you would like to chat to us regarding how we process your personal information, please contact us here.

Use of our Sites
You do not need to register in order to use our Site. As a visitor to our Site, we do not collect any personally identifiable information about you, aside from data received because of cookies (see below for more about how cookies work).

However, there may be times that you choose to share your personal information with us in order to register for certain events or value-added services, or request communication about specific areas of interest, etc. In this instance, CCi collects and processes personal information from these registrants. Unsubscribing is as easy as opting-in: anything we send you or share with you will give you the option to unsubscribe with one click.

Examples of times that Users may consent to register for services and/or value-added services:

  1. Users 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 a User has registered with us. We require registration because we’d like to know more about who is interested in our thought leadership, and so that we can share with these people more of what they are interested in, as well as continue to provide a publishing service that is up-to-the-minute and relevant to your needs. A one-click opt-out/unsubscribe function is available on anything we share with you. CCi reserves the right to release these materials only to visitors who register for these services.
  2. Users want to take part in our surveys, or have us share our research findings with them:
    From time to time we may conduct surveys via this Site. Over and above the feedback that you give us when filling out the survey answers, CCi requires some personal information (usually name and email address) so that we can ensure no duplicates of responses are collected, and this in turn ensures accuracy of our results. Furthermore, we sometimes conduct industry-relevant surveys around best practices, the results of which are of interest to our Users.
  3. Users want to be invited to our events:
    We host events around the world, and registration for these usually happens online either through this Site or through a third-party site (such as a host-hotel or event organiser, but these third parties are ones that are directly associated with the event). Registration for events will require some personal information to be filled out on registration forms. Alternatively, we as a company sometimes host an exhibition stand at an industry event. At these events, some Users might choose to leave their information with us so that we can later send them additional information about our product/services.
  4. Users 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.
  5. TRACC Community:
    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. Users may delete their profiles, comments and/or submissions themselves at any time.

If you’d like these services, you must consent to receiving this type of communication from us. You can do so by visiting community.traccsolution.com and clicking the register button. Thereafter, anything that we share with you will provide you with the opportunity of unsubscribing with one click.

International data transfer
From time to time, it may be necessary for your personal data collected on our Sites to be transferred/viewed internally across our global organisation, as well as by our business partners located throughout the world (i.e. in countries other than the one that you reside in).

Additionally, your data, that is stored on a digital database, may be viewed by our authorised personnel in other regions. This will only ever happen in line with services/communication that you have requested; for example, if you apply for a job at a CCi office that is situated in a country other than the one you reside in, our personnel in the other country will need to view your recruitment application. In this instance, your rights towards your personal data and our legal obligations towards your privacy remain regardless.

Collection of personal information: what is collected and how it is used
We collect and use information to operate our website, and deliver on our contractual services and/or to provide you with value-added services as listed above. We may also use this information to inform you of other products or services available from us and our affiliates. CCi may contact you via voluntary surveys to conduct research on your opinion of current or potential new services. You will always have the option to unsubscribe (see “Unsubscribing from CCi” below).

CCi does not sell, rent or lease its customer lists to third parties nor share personally identifiable information except as described in this policy statement. CCi may contact you about a particular offering that may be of interest to you. In addition, CCi may share data with trusted contractual partners to help perform statistical analysis, send you emails or postal mail, provide customer support, arrange for deliveries or contact you based on your interest to receive such communications. Such third parties are prohibited from using your personal information except to provide these services to CCi, and they are required to maintain the confidentiality of your information.

When you post a response to content on our Site (“Comment”) or submit a photograph via the TRACC Community submissions page, we will ask you for personally identifiable information. This is information about you that on its own or in combination with other identifiers (“personal information”) can be used to contact or identify you. Personal information includes, but is not limited to, your name and email address. CCi uses your personal information in accordance with these terms of use in order to facilitate the provision of value-added services (such as sharing thought leadership articles, industry reports, product/version upgrades, event invitations and other information that we feel would be of interest to you) and to administer your enquiries. Your Comments are visible to all viewers of CCi websites.

CCi also collects other information through the use of our Sites (e.g. user activity, the pages of the Site that you visit, time spent on these pages and other statistics), and regularly analyses this aggregated data pertaining to visitor trends, TRACC Community submissions and consumption in order to improve services, plan site enhancements and measure overall site effectiveness. We do this so that we can provide you with more of what you are interested in, and the best possible browsing experience across our Sites.

In order to provide the best possible and most relevant service, this website may collect other, non-identifiable information about the use of this Site by way of standard technology such as cookies, web beacons and other web technologies.

With regards to our email communications to you, we use tracking technologies to ascertain whether the emails we send to you are being read, clicked on or forwarded. We do this so that we can understand which content/communications are most relevant to you, as well as to review aggregated statistics on which of our communications are most relevant to most Users.

CCi will not use the personal information submitted for any other purpose other than the efficient provision of services. This website will keep records of all personal information collected and the specific purpose for which it was collected for a period of 18 months from the date on which it was last used; this website will not disclose any personal information regarding a User to any third party unless the prior written agreement of the User is obtained or the website is required or permitted to do so by law; if information is released with the User’s consent, this website will retain a record of the information released, the third party to which it was released, the reason for the release and the date of release for a period of one year; information collected about Users through their use of this website is the property of CCi.

No credit card information is retained or stored by CCi. In the event where Users input credit card details to pay for event or hotel bookings, the event organiser or hotel will supply their own payment devices and privacy controls, and these are not linked to CCi in any way.

Links to other websites
CCi has no control over and accepts no responsibility for the privacy practices of any third-party sites to which hyperlinks may have been provided, and we strongly recommend that you review the privacy policy of any site you visit before using it further. This disclaimer extends to social media websites such as YouTube, Instagram, Facebook or LinkedIn, where, although we host our own user profile/page on these sites, our pages there are still governed by each site’s own privacy policies. Please familiarise yourself with the respective terms of use and privacy policies of these sites to understand how they use your information.

Respecting your privacy is important to us
All CCi employees receive copies of this Privacy Policy as part of employee training. CCi management considers violation of client and user confidentiality to be a serious infringement of our policies. Internal employee education around the Privacy Policy stresses the confidentiality of client’s and user’s data.

In some instances, we make use of external web services to embed content (such as videos which could, for example, be hosted on YouTube). Since this content is hosted on the external site – even though it is displayed on ours – we cannot prevent these sites from collecting information on your use of this specific content.

Cookies and tracking technologies
Tracking technologies
Information about your computer hardware and software is automatically collected by CCi. This information can include your IP addresses, browser types, domain names, access times and referring website addresses. This information is used by CCi for the operation of its service, to maintain quality of the service and to provide general statistics regarding use of the CCi website. For these purposes, CCi links this automatically collected data to personally identifiable information such as name, email address, address and phone number only where you have shared this personally identifiable information with us.

Cookies and web beacons
The CCi website uses “cookies” to help personalise your online experience. 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.

A “session cookie” expires immediately when you end your session (i.e. close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. A web beacon is a small string of code that represents a clear graphic image, a redirect URL or JavaScript and is used in conjunction with a cookie.

When you visit the Site, CCi may use both a session and a persistent cookie. This cookie may contain information (such as a unique user ID) that is used to track your usage of CCi’s Site. CCi employs cookies to enable our systems to recognise your browser and tell us how and when pages on the Site are visited and by how many people, and also in order for our server to recognise a return visitor as a unique User. The cookies placed by the CCi server are readable only by CCi and cookies cannot access, read or modify any other data on a computer. CCi uses web beacons alone or in conjunction with cookies to compile information about your usage of CCi’s Site and interaction with emails from CCi. For example, CCi may place web beacons in marketing emails that notify CCi when you click on a link in the email that directs you to CCi’s Site.

We use web beacons to operate and improve our Site and email communications. 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. However, we strongly recommend that you leave the cookies activated, because they enable you to take advantage of some of CCi’s most attractive features.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalise CCi pages or register on the CCi Site or with CCi services, a cookie helps CCi to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as your username, email address and so on. When you return to our website, the information you previously provided can be retrieved, so that you can easily use the features that you customised.

You have the option to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the CCi services or websites you visit. CCi keeps track of the websites and pages you visit within our Sites, in order to determine which services and content are the most popular. This data is used to deliver customised content and advertising to Users whose behaviour indicates that they are interested in a particular subject area.

Flash cookies and other third-party tracking technologies such as Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface from the one provided by your web browser. This technology creates locally stored objects that are often referred to as “Flash cookies”. However, CCi’s software platform may create pages on the CCi platform that employ Adobe Flash cookies. CCi does not have access or control over Flash cookies, but you may access your Flash management tools from Adobe’s website directly.

Disclosure
CCi does not make personal information or client data available to third parties; does not sell lists, accept advertising or generate any third-party revenue from the data that is generated from its Site; and does not share data from any Client with other Clients.

CCi websites will only disclose your personal information if required to do so by law or in the reasonable belief that such action is necessary to:
• conform to the requirements of the law or comply with any legal process served on CCi
• protect and defend the rights or property of CCi
• act under exigent circumstances to protect the personal safety of Users of CCi or the public
• ensure the uninterrupted provision of services, so, for instance, our vendors that supply bolt-on web services on our website. These vendors have signed privacy agreements with us and are bound by this Privacy Policy.

Access to personal data and your rights to erasure
CCi collects personally identifiable information, such as email address, name, company name, or work address and/or telephone number. If you believe that your personal information held by us is outdated or incorrect, you may request that such personal data be corrected, or you can do so yourself on the relevant contact form or by updating your user profile. Any request for a correction must specify both the incorrect data and the proposed correction, and must give reasons for the request.
You can also request access to personal data held by us as required by law and where such access is necessary for you to exercise and/or protect any of your rights.

To access your personal information held by us, please contact our Privacy Team at privacy@ccitracc.com CCi will respond to all access requests within 30 days. In some cases, CCi may not be able to remove your personal information, in which case CCi will let you know as well as the reason for this.

Any data subject has the right to have their data erased from our systems. If you request that your user information be deleted from CCi records, there may be a brief delay in CCi’s processing that request while CCi verifies that the request is valid and originates from you as opposed to an unauthorised third party. If you request that your information be deleted, CCi reserves the right to terminate and/or limit your access to the CCi website.

Data of registrants that are inactive for a period of 18 months will also be deleted from our system.

If you provide CCi with information, you have the following rights with respect to that information:
• To review the information supplied
• To request that CCi corrects any errors, outdated information or omissions in information supplied
• To request that your information not be used to contact you
• To request that your information be removed from any solicitation list or website that CCi may use
• To request that your information be deleted from CCi records

To exercise any of these rights, please contact CCi at: privacy@ccitracc.com

Security of your personal information
No method of safeguarding information is 100% secure. CCi uses a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. CCi secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure, and this secure server is only accessed by authorised personnel. When sensitive personal information is collected on the Site 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.

Children
CCi, TRACC and any of our websites mentioned above, including our community pages, are not intended for use by children under the age of 16 years. Our website and activities are not designed for or targeted at children under the age of 16. We will not knowingly collect, maintain or process any information about children under 16 years of age.

Changes and/or updates to our Privacy Policy22 May 2018 (Last Updated)
CCi reserves the right to amend or update this Statement of Privacy at any time. When such a change is made, CCi will update the “Last Updated” date above. Users will always remain responsible for ensuring that they are aware of the current version of this Privacy Policy whenever accessing this website, and continued use of the website constitutes Users’ acceptance of the Privacy Policy as amended. Please check back here from time to time to keep abreast of changes to this policy.

Unsubscribing from CCi
If you have shared your personal information with us and opted-in/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 CCi that 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 communications are sent to you in error.

Job applicants
Visitors to our Sites can apply for jobs through our careers page. The Careers section of our websites is governed by an additional set of privacy clauses. This is because in the instance of applying for a job, it may be necessary for you to supply us with information that is of a more sensitive nature, in accordance with a specific country’s laws (these laws are often around inclusiveness and diversity). Your rights remain the same and we are bound by the same set of laws when it comes to your personal information. Please familiarise yourself with our Recruitment Privacy Policy.

TRACC Community
TRACC Community is an interactive online forum where industry insiders and improvement professionals can register in order to view, compare and discuss best practice examples of what good improvement and operational excellence looks like. Registration and participation is voluntary.

Logging in:
TRACC Community Members may log in using the username and password chosen by them on registration. The service will authenticate the Member’s identity and provide the Member with an option to share certain personal information within the service, such as an email address and other personal information.

By providing your email address, you will automatically be opted in to receive invitations to certain events or value-added services, such as an invitation to download cutting-edge industry reports, thought leadership articles or white papers that we feel are of relevance to you. Should you not wish to receive such information, please unsubscribe as indicated at the bottom of email communications.

CCi Marketing and Account Managers and Site Administrators can provide new TRACC Community submission alerts, newsletters, white papers and product/event updates based only on a User’s opt-in request for services. To ensure accurate TRACC Community content, management and administrative employees can review the contents in TRACC Community submission data and user registration data.

Social media (features) and widgets
CCi’s TRACC Community website includes social media features, such as “Like” buttons, widgets, and the “Share This” button. These features may collect your IP address, which page you are visiting on the Site, and may set a cookie to enable the feature to function properly. These particular social media features and widgets are hosted directly on CCi’s Site and can only be seen by other registered and logged-in Users of the TRACC Community website.

Testimonials and Comments
Your Comments and testimonials will be displayed for all registered Members of the TRACC Community service and may be removed as CCi sees fit. Instances where Comments might be removed include inappropriate, offensive or profane Comments. Comments and testimonials will not be made available outside of the TRACC Community without your consent.

Member only access
Our TRACC Community website’s message boards, blogs and community forums are available strictly to registered Members only. All Member registrations go through a screening process upon registration. CCi reserves the right to deny any prospective User access to its web services. CCi moderates all online communications.

Contact information
CCi welcomes your Comments regarding this Statement of Privacy. If you believe that we have not adhered to this Statement, please contact CCi at: privacy@ccitracc.com CCi will use commercially reasonable efforts to determine and rectify the problem promptly.

Job applicants
Our recruitment process is bound by an additional set of Privacy Policies. Please click here to view our Recruitment Privacy Policy.

Recruitment Privacy Policy
Over and above our general Privacy Policy, we have additional privacy clauses that pertain specifically to recruitment within CCi. CCi is a privacy conscious organisation and as such we are committed to protecting your privacy.

This Recruitment Privacy Statement explains what information we gather about you as part of our recruitment activities and how it is used.

The information that we collect as part of the recruitment process
As part of the recruitment process, we will collect or obtain personal information about you such as your name, contact details (email address, telephone number and home address), details about your work experience and academic qualifications, gender, date of birth, etc. We will obtain this information either because you gave it to us by way of uploading/emailing your CV or resume on our Site, or you filled in a web form on our website that requested these fields of information, or because it is publicly available on a careers or networking site (such as Linkedin.com).

In some instances, you may have applied for a specific job that we have advertised, and in other instances, you may have made a general enquiry with us to see if there are any jobs available that suit your preferences and work experience. In both cases, you have the option for us to keep your information on file in case any jobs become available in the future that we feel could be a good fit. In this instance, we will contact you using the contact details you have supplied us during your application, and you have the right to respond, not respond, decline but request that we continue to send you applicable job updates, or request that we remove your details from our system. Whilst your job application or enquiry data is stored with us, it will be bound by all the same privacy laws as are set out in our Privacy Policy. Furthermore, your rights pertaining to this personal information remain the same as are set out in our Privacy Policy. We will store this job application/enquiry data for no more than six months after it is last used. If more than six months have lapsed since we communicated with you regarding possible job opportunities, you will need to re-enquire or re-apply.

Generally, we do not seek to collect sensitive information about you (such as race, ethnic origin, religious/spiritual beliefs, political beliefs, criminal record, health records or sexual/life orientation). However, we might collect this information about you either because you have volunteered it in your CV/Resume/Job application, or because we are required to do so by law because of diversity and inclusiveness quotas in certain countries.

We will only process sensitive information about you because:
– you have given us your explicit consent to process the information
– the processing is, by law, necessary to carry out our obligations
– the processing is necessary for the establishment, exercise or defence of legal claims
– you have made the information public

Children
CCi, TRACC and any of our websites mentioned above, including our community pages, are not intended for use by children under the age of 16 years. Our recruitment activities are only targeted at people that are 18 years of age or older. We will not knowingly collect, maintain or process any recruitment-related information about any person under the age of 18.

Cookies and tracking technologies
Please review our general Privacy Policy for information relating to cookies and tracking technologies.

How we use the information you supplied us with as part of the recruitment process
Information that we collect about you as part of the recruitment process will be used so that we can build a relationship with you, understand your career interests and goals in order to find a position best suited to you.

If your application for a specific job is unsuccessful, we may contact you – where you have indicated that you would like us to – about other job opportunities within our network that we feel may be applicable to you. If at any time you wish for us to stop sending you recruitment-related opportunities or information, you may request this at any time by emailing recruitment@ccitracc.com

We might also use your personal information for the purposes of or in connection with the following:
• If we are required to do so by law or some other regulatory requirement
• To protect your or our legitimate interests
• Where we receive requests from competent authorities
• In order to protect our rights and/or property

Disclosure
CCi does not make personal information available to third parties; does not sell lists, accept advertising or generate any third-party revenue from the data that is generated from its Site.

CCi websites will only disclose your personal information if required to do so by law or in the reasonable belief that such action is necessary to:
• search for recruitment opportunities for you (within our network) in the countries where we have offices and that you have indicated you’d be interested in working in
• conform to the requirements of the law or comply with any legal process served on CCi
• protect and defend the rights or property of CCi
• act under exigent circumstances to protect the personal safety of Users of CCi or the public
• ensure the uninterrupted provision of services, so, for instance, our vendors that supply bolt-on web services on our website. These vendors have signed privacy agreements with us and are bound by this Privacy Policy
• other third parties that form part of a corporate transaction such as a merger, acquisition, sale, divesture or reorganisation

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

How long will we keep your information?
We retain personal information only as long as is necessary for the fulfillment of the purposes identified above in the “How we use the information you supplied us with as part of the recruitment process” section above or as otherwise necessary to comply with applicable laws. Where personal information is no longer necessary or relevant for our identified purposes or where you have indicated that you are no longer interested in staying in contact with us, we will securely dispose of your personal information.

What are your rights?
You have various rights in relation to your personal information. In particular, you have the 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 correct such information that you think is inaccurate or incomplete
• ask that we delete personal information that we hold about you, or restrict the way in which we use such information
• object to our processing of your personal information

To exercise any of your rights or raise any questions that you have about our use of your personal information for recruitment purposes, please contact our Recruitment Information Protection Officer on rpatel@ccint.net

For any other privacy related queries that do not pertain to the recruitment process, please contact our Information Protection Officer on privacy@ccitracc.com

You may also use the above listed contact details if you wish to make a complaint to us relating to your personal information or privacy.