This survey is designed to reveal the leadership stance of your managers and potential areas of improvement in order to grow the Agile mindset.
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A. General Information
When does this Privacy Statement apply?
This Privacy Statement applies to information that can be used to identify you (“Personal Data”) and that you provide to ACM or which is derived from the Personal Data as outlined below.
Who is the Data Controller?
The data controller of https://www.agileleadershipinsights.com/ is ACM Agile Consultancy A.Ş. (“ACM”). Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection, but it is in any case displayed on the individual registration form’s privacy statement. ACM’ data protection officer can be reached at [email protected].
What Personal Data does ACM collect?
In the normal course of business, ACM collects Personal Data such as contact information (e.g., name, address, phone number, email address, and your employer) and payment details for customers.
Why does ACM need your Personal Data?
ACM requires your personal data to provide you with access to ACM’ services, to comply with contractual and statutory obligations, including checks required by applicable export laws and to stay in touch with you. Although providing your Personal Data is voluntary, without your Personal Data, ACM cannot provide you with access to its services.
From what types of third parties does ACM obtain Personal Data?
In most cases ACM collects Personal Data from you. ACM might also obtain Personal Data from third parties, if the applicable national law allows ACM to do so. ACM will treat this Personal Data according to this Privacy Statement, plus any additional restrictions imposed by the third party that provided ACM with it or the applicable national law.
How long will ACM store my Personal Data?
ACM will only store your Personal Data for as long as it is required for the performance of contractual obligations, to make its services available to you, for ACM to comply with its statutory obligations resulting from applicable export laws, and to fulfill the purposes outlined in this Privacy Statement.
ACM will also retain your Personal Data for additional periods if applicable laws require it.
Who are recipients of your Personal Data and where will it be processed?
Your personal data will be passed on to the following categories of third parties for processing: companies within the SAP Group; vicarious agents (e.g., third party service providers for consulting services and other additional related services); other services providers (e.g. for the provision of the website); state agencies and bodies if required by law.
As part of a global group of companies operating internationally, ACM has affiliates (the “SAP Group”) and third-party service providers outside of the European Economic Area (the “EEA”) and will transfer your Personal Data to countries outside the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, ACM uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy of such standard contractual clauses by sending a request to [email protected].
What are your data protection rights?
You can request from ACM access at any time to information about which Personal Data ACM processes about you and the correction or deletion of such Personal Data. Please note, however, that ACM can or will delete your Personal Data only if there is no statutory obligation or prevailing right of ACM to retain it. Kindly note further that if you request that ACM deletes your Personal Data, you will not be able to continue to use any ACM service that requires ACM’ use of your Personal Data.
If ACM uses your Personal Data based on your consent or to perform a contract with you, you can further request from ACM a copy of the Personal Data that you have provided to ACM. In this case, please follow the instructions detailed below, and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. ACM will carefully consider your request and discuss with you how it can best fulfill it.
Furthermore, you can request from ACM that ACM restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data ACM has about you is incorrect, subject to the time ACM requires to check the accuracy of the relevant Personal Data; (ii) there is no legal basis for ACM processing your Personal Data and you demand that ACM restricts your Personal Data from further processing; (iii) ACM no longer requires your Personal Data but you state that you require ACM to retain such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) in case you object to the processing of your Personal Data by ACM based on ACM’ legitimate interest (as further set out below), subject to the time ACM requires to determine whether it has a prevailing interest or legal obligation in processing the relevant Personal Data.
For individuals within the USA, you instead have the right:
How can you exercise your data protection rights?
To exercise your data protection rights, please complete the Request Form and fill out the relevant details to start the identity verification process. Alternatively, you can direct your request to “[email protected]” Please indicate the following details: your full name, your country and state of residence and the right(s) you wish to exercise. You can also designate another person to submit requests to exercise your data protection rights on your behalf to ACM.
How will ACM verify requests to exercise data protection rights?
ACM will take steps to verify your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, ACM will match Personal Data provided in your request to exercise your rights with information already maintained by ACM. This could include matching two or more data points that are already maintained by ACM.
ACM will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.
If you take the view that ACM is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where ACM is incorporated.
B. Processing based on a statutory permission
Why does ACM need to use my Personal Data and on what legal basis is ACM using it?
Providing the requested services. ACM requires your Personal Data to deliver services that you order under a contract with ACM, to establish a contract for goods or services between you and ACM, and to send you invoices for ordered services. ACM processes Personal Data to fulfill contractual obligations pursuant to Article 6(1), Subparagraph 1(b) GDPR.
Ensuring compliance. ACM and its products, technologies, and services are subject to the export laws, trade sanctions, and embargoes (“Export Laws”) of various countries including, without limitation, those of the European Union (“EU”) and of the United States of America. Therefore, You acknowledge that, pursuant to the applicable Export Laws issued by these countries, ACM is required to:
(a) take measures to prevent persons, entities, and organizations listed on government-issued sanctioned party lists from accessing certain products, technologies, and services through ACM’s websites or other delivery channels controlled by ACM. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to ACM’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match; and
(b) ensure that no individuals from embargoed countries access its services. Therefore, when an existing user logs into a website, app, or cloud service of ACM from an embargoed country, the user’s registration data and IP address may be used by ACM to block the user’s access and to log access attempts from embargoed countries.
Any such usage of registration data and IP addresses by ACM is necessary for ACM’ compliance with applicable EU Export Laws (Article 6 para. 1 (c) GDPR) and ACM’ legitimate interest to comply with non-EU Export Laws (Article 6 para. 1 (f) GDPR).
ACM can use your Personal Data based on its legitimate interest (Article 6 para. 1 lit. f GDPR) as follows:
You can at any time object to ACM’ use of your Personal Data as set forth above. In this case, ACM will carefully review your objection and cease further use of the relevant information, subject to ACM’ compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if ACM requires the information for the establishment, exercise, or defense of legal claims.
Processing under applicable national laws. If the applicable national law allows ACM to do so, ACM will use information about you for a business purpose, some of which is Personal Data:
In accordance with the disclosure requirements under the CCPA, ACM is exempt from providing a notice to opt-out because it does not and will not sell your Personal Data.
C. Processing based on consent.
In the following cases, ACM would process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6 para. 1 lit. a GDPR).
Children. This offering is not directed to users below the age of 16 years or equivalent minimum age in the relevant jurisdiction. If you are younger than 16, you cannot register with or use this offering.
U.S. Children’s Privacy. ACM does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe that ACM collected information about a child, please contact ACM as described in this Privacy Statement. ACM will take steps to delete the information as soon as possible. Given that ACM services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, ACM does not sell the Personal Data of any minors under 16 years of age.
Marketing. ACM may use your Personal Data to inform you about ACM’ latest products, service offers, and events. Any such use of information is based on the consent you grant hereunder. ACM may use your name, email, and postal address, telephone number, job title, and basic information about your employer (name, address, and industry), as well as an interaction profile based on prior interactions with ACM (prior purchases, participation in webinars, seminars or events, or the use of (web) services in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about ACM or SAP Group’s software and services (including marketing-related newsletters) as well as events of ACM or SAP Group and in order to display relevant content on ACM or its affiliates websites. In connection with these marketing-related activities, ACM will provide a hashed user ID to third-party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own databases in order to display to you more relevant information.
ACM events.
Event profiling. If you register for an event, seminar, or webinar of ACM, ACM shares basic registration information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.
Tracking during an event. ACM requires your Personal Data including any occasion where you allowed your event badge to be scanned, to evaluate behavioral aspects by means of tracking during the relevant event. ACM might process tracking data in the context of ACM events for purposes of tracking attendance, determine the attendees’ interests in certain topics, and identify drivers for the attendees’ satisfaction and dissatisfaction to optimize planning and investments for future events. Any such use of information is based on the consent you grant.
Processing Special Categories of Personal Data. When you register for or request access to an event or seminar, ACM may ask whether you require any accommodations because of your health or dietary restrictions. Any such use of information is based on the consent you grant. Kindly note that if you do not provide ACM with information regarding what accommodations you require, ACM will not be able to accommodate for it.
Photograph before or during the event. You may be asked to provide ACM with your current photograph via e-mail or ACM could ask to take a picture of you when you arrive at the event. By sending ACM your photograph or allowing a photo of you to be taken, you acknowledge that ACM will use your picture for the purposes described in this Privacy Statement.
Withdrawal of consent. You may withdraw your consent for ACM to process your Personal Data as stated in this Privacy Statement at any time. Once you assert this right, ACM will not process your Personal Data any longer unless legally required to do so. However, any withdrawal has no effect on past processing by ACM up to the point in time of your withdrawal.
D. IP Address Collection
When a ACM’ customer sends a survey to an individual, ACM may collect IP addresses from survey respondents. The purpose of collecting this information is to prevent and protect against fraud and malicious activity, and to ensure the security of the website, app or cloud service of ACM.