365 Modernization Toolkit Privacy Policy dated 2021.03.29

Overview

Total Solutions collects data from you, through our interactions with you and through our products and services. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our products. The data we collect depends on the context of your interactions with Total Solutions and the choices you make, including your privacy settings and the products and features you use. We also obtain data about you from third parties.

If you represent an organization, such as a business or school, that utilizes products and/or services from Total Solutions, please see the products section of this privacy statement to learn how we process your data. If you are an end user of a Total Solutions product or a Total Solutions account provided by your organization, please see the “Products and Services provided by your organization – Notice to End Users” section for more information.

You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Many of our products require some personal data to provide you with a service. If you choose not to provide data required to provide you with a product or feature, you may not be able to use that product or feature.

Likewise, where we need to collect personal data required by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time.

Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you. This statement is true for all Total Solutions provided products including: 365 Modernization Toolkit, 365 Navigation, 365 Analytics, 365 Web Part Builder, 365 Global Styler; and KickApper.

How we use personal data

Total Solutions uses the data we collect to provide you with rich, interactive experiences. In particular, we use data to:

• Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
• Control the licenses to our software and assure only authorized access is allowed to those products.
• Improve and develop our products.
• Personalize our products and make recommendations.
• Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two Total Solutions products) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do.

To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For example, we manually review short snippets of a small sampling of voice data we have taken steps to de-identify to improve our speech services, such as recognition and translation.

Reasons we share personal data

We share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized. We also share data with Total Solutions-controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights and property of Total Solutions and its customers.

How to access and control your personal data

You can make choices about the collection and use of your data by Total Solutions. You can control your personal data that Total Solutions has obtained, and exercise your data protection rights, by contacting Total Solutions. In some cases, your ability to access or control your personal data will be limited, as required and/or permitted by applicable law. How you can access or control your personal data will also depend on which products you use.

If you want to access or control personal data processed by Total Solutions, you can always contact Total Solutions at the address in the How to contact us section on our website.

Cookies and similar technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, providing interest-based advertising, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes.

We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. Note that blocking of cookies or other browser-based restriction may affect the features and functions that are available for your use.

Products and Services provided by your organization—Notice to End Users

If you use a Total Solutions product with an account provided by an organization you are affiliated with, such as your work or school account, that organization can:

• Control and administer your Total Solutions product and product account, including controlling privacy-related settings of the product or product account.
• Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your Total Solutions product and product accounts.

If you lose access to your work or school account (in event of change of employment, for example), you may lose access to products and the content associated with those products, including those you acquired on your own behalf, if you used your work or school account to sign in to such products.

Many Total Solutions products are intended for use by organizations, such as schools and businesses. Please see the  products section of this privacy statement. If your organization provides you with access to Total Solutions products, your use of the Total Solutions products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. When you use social features in Total Solutions products, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the Total Solutions product. Total Solutions is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.

When you use a Total Solutions product provided by your organization, Total Solutions processing of your personal data in connection with that product is governed by a contract between Total Solutions and your organization. Total Solutions processes your personal data to provide the product to your organization and you, and for Total Solutions legitimate business operations related to providing the product as described in the products section. As mentioned above, if you have questions about Total Solutions processing of your personal data in connection with providing products to your organization, please contact your organization.

If you are using Total Solutions service provided by your organization, Total Solutions processing of your personal data in connection with that service is governed by a contract between Total Solutions and your organization., If you have questions about Total Solutions legitimate business operations in connection with providing services to your organization as provided in the standard Total Solutions Professional Services Agreement (PSA), please contact Total Solutions as described in the How to contact us section. For more information on our legitimate business operations, please see the products section.

For Total Solutions products provided by your K-12 school, Total Solutions will:

• not collect or use student personal data beyond that needed for authorized educational or school purposes;
• not sell or rent student personal data;
• not use or share student personal data for advertising or similar commercial purposes, such as behavioral targeting of advertisements to students;
• not build a personal profile of a student, other than for supporting authorized educational or school purposes or as authorized by the parent, guardian, or student of appropriate age; and
• require that our vendors with whom student personal data is shared to deliver the educational service, if any, are obligated to implement these same commitments for student personal data.

Total Solutions account

With a Total Solutions account, you can sign-in to Total Solutions products, as well as those of select Total Solutions partners. Personal data associated with your Total Solutions account includes credentials, name and contact data, payment data, device and usage data, your contacts, information about your activities, and your interests and favorites. Signing in to your Total Solutions account enables personalization and consistent experiences across products and devices, permits you to use cloud data storage, allows you to make payments using payment instruments stored in your Total Solutions account, and enables other features.

There are three types of Total Solutions account:

• When you create your own Total Solutions account tied to your personal email address, we refer to that account as a personal Total Solutions account.
• When you or your organization (such as an employer or your school) create your Total Solutions account tied to your email address provided by that organization, we refer to that account as a work or school account.
• When you or your service provider (such as a cable or internet service provider) create your Total Solutions account tied to your email address with your service provider’s domain, we refer to that account as a third-party account.

Products section

Total Solutions products and related software offered to and designed primarily for use by organizations and developers. They include:

• Subscription products, such as 365 Modernization Toolkit, 365 Navigation, 365 Analytics, and 365 Global Styler, for which an organization (our customer) contracts with Total Solutions for products.
• Developer oriented products such as KickApper, KickApper Run-Time, or KickApper Monitor.
• Usage based products such as the TSI License Manager, Cert Builder, or Submission Builder.

When a customer tries, purchases, uses, or subscribes to Total Solutions products, or obtains support for or professional services with such products, Total Solutions receives data from you and collects and generates data to provide the service (including improving, securing, and updating the service), conduct our legitimate business operations, and communicate with the customer. For example:

• When a customer engages with a Total Solutions sales representative, we collect the customer’s name and contact data, along with information about the customer’s organization, to support that engagement.
• When a customer interacts with a Total Solutions support professional, we collect device and usage data or error reports to diagnose and resolve problems.
• When a customer pays for products, we collect contact and payment data to process the payment.
• When Total Solutions sends communications to a customer, we use data to personalize the content of the communication.
• When a customer engages with Total Solutions for professional services, we collect the name and contact data of the customer’s designated point of contact and use information provided by the customer to perform the services that the customer has requested.

In the event of a conflict between this Total Solutions privacy statement and the terms of any agreement(s) between a customer and Total Solutions, the terms of those agreement(s) will control.