Last Updated: February 7, 2020
Booz Allen Hamilton Inc. and Modzy collect your personal information through this website, social media, email and apps as described below. For more detailed information please see below.
- through the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
- through our social media pages and apps (collectively, our “Social Media Pages”);
- Any offline business interactions you may have with us.
Collectively, we refer to the Sites, the Apps and our Social Media Pages, these emails and offline business interactions as the “Services”).
Personal and Other Information We May Collect
“Personal Information” is data and information that can identify you as an individual or relates to an individual, either alone or when combined with other information. The categories of Personal Information we collect include:
- Identifiers such as name and contact Information;
- Personal information, such as credit or debit card number information
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services: We collect Personal Information through the Services, for example, when you sign up for a newsletter, download a publication, register for an event, request access to an available online demonstration, or request information.
- Offline: We collect Personal Information from you offline, e.g., when you attend an event.
- From Other Sources: We receive your Personal Information from other sources, for example:
- publicly available databases
- joint marketing partners, when they share the information with us
- sales channel partners
- demand generation companies;
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Other information we may collect include:
- Browser and device information;
- Information collected through audit logs, cookies, pixel tags, and other technologies;
- Demographic information and other information provided by you;
- Aggregated information.
How We May Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, referring URL, and the name and version of the Services (such as the mobile application) you are using. We use this information to ensure that the Services function properly.
- Through your use of an App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.
- From you: Information such as your preferred means of communication is collected when you voluntarily provide it.
How we use Personal Information
We and our service providers may use Personal Information for legitimate business purposes including:
Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as arranging access to your registered account when applying for a position and providing you with related customer service.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
- To complete your transactions and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies.
- To allow you to send messages to another person if you choose to do so.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you marketing related emails, with information about our Services, new products and other news about our company.
- To facilitate social sharing functionality that you choose to use.
We will engage in this activity because we have a legitimate interest or with your consent (where required).
Analysis of Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
Aggregating and/or anonymizing Personal Information.
We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes and service function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, or modifying our current products and services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
How We May Disclose Personal Information
Your Personal Information may be disclosed:
- You can consult the list and location of our affiliates here.
- To our third-party service providers, to facilitate services they provide to us, including website hosting, data analysis, information technology, payment processing, order fulfillment, customer service, email delivery, auditing, and other services;
- To identify you to anyone to whom you send messages through the Sites.
Other Uses and Disclosures of Personal Information
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations, which may include laws outside your country of residence;
- To respond to requests from public and government authorities, which may include such authorities outside your country of residence;
- To cooperate with law enforcement to enforce our terms and conditions; and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
- In connection with a sale or business transaction. We have a legitimate business interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business assets or stock (including in connection with any bankruptcy or similar proceedings.)
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined. We do not currently respond to browser do-not-track signals.
Third Party Sites
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
Your choices regarding our use of your Personal Information
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the instructions contained in each email. We will try to comply with your request as soon as reasonably practicable. Please note that, if you opt out, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change or suppress your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, you may contact us at [email protected] We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Third Party Advertising
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
Use of the Service by Minors
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from such children.
Unless we request it, we ask that you not send us, and do not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, trade union membership or criminal background) directly to us.
Jurisdiction and Cross-Border Transfer
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and binding corporate rules to protect your Personal Information. You may obtain a copy of these measures by contacting [email protected] or by following this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
Third Party Payment Processing
Additional Information regarding the EEA
You may also:
- Lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
California Privacy Notice
Pursuant to the California Consumer Privacy Act (CCPA), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months. We have collected the following categories of Personal Information:
- Identifiers such as name and contact information; and
- Personal information such as credit or debit card information.
As described above, we collect this Personal Information from you and from other categories of sources: publicly available databases, sales channel partners, demand generation companies and joint marketing partners, when they share the information with us. Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
We may disclose the following Personal Information to third parties for our operational business purposes:
- Identifiers such as name and contact information; and
- Personal information such as credit or debit card information.
We share Personal Information with our affiliates, service providers, and our business partners.
We have not “sold” Personal Information for purposes of the CCPA.
If you are a California resident, you may request that we:
- Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you; and
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
- Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us in accordance with the “Choices and Access” section above. We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA