Privacy Policy

 

ModernThink respects your privacy. This Privacy Policy informs you of, among other things, the following:

  • our privacy practices;
  • the choices you can make about the way your information is collected both on our website and during our survey and assessment processes;
  • how your information is used;
  • how your information is protected.

ModernThink complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce.  ModernThink has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF, ModernThink commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact ModernThink at:

Karen Kukulka
Director of Operations
info@modernthink.com
302.764.4477

In compliance with the EU-U.S. DPF, ModernThink commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF.

Please note the following:

  • ModernThink is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)
  • Under certain conditions, it is possible for you to invoke binding arbitration
  • ModernThink is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements
  • ModernThink is liable in cases of onward transfers to third parties
  1. Website

    1. Data Collection

      We collect only personally identifiable information that is specifically and voluntarily provided by visitors to ModernThink’s website. We receive limited identifiable information, such as name, title, company address, email address, and telephone and fax numbers, from website visitors. Typically, identifying information is collected to:

          • – Register for certain areas of the site
          • – Inquire for further information
          • – Request a telephone consultation
          • – Request a speaker
          • – Become part of our mailing list
          • – Distribute requested reference materials
          • – Submit resumes

      Demographic information, including gender and race, is not actively sought, but may be submitted when a visitor responds to an online job application. It is ModernThink’s policy to limit the information collected to only the minimum information required to complete a visitor’s request. In any instance where non-mandatory information is sought, the Web site visitor will be notified of this at the point of collection.

      Visitors may have the opportunity to purchase ModernThink publications and or reports either online, by calling toll free numbers, or by faxing order forms. We will collect order information and may collect a customer’s credit card information, where applicable, in order to facilitate shipment and payment for the publications and or reports.

      Visitors are also able to send email through the site. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. Because we use the website as a recruiting tool, a visit to the website may also result in the user sending a resume to an individual within ModernThink.

      ModernThink’s intention is not to seek any sensitive information through our website unless legally required for recruiting purposes. Sensitive information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. We suggest that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, ModernThink accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information. Furthermore, if you submit data on ModernThink’s website, we accept your explicit consent to transmit that information across international borders.

      ModernThink also used the following automatic data collection tools. Click on each topic if you are interested in learning more.

    2. Data Use

      A user may choose to provide personal information in the following examples:

          • – Order reports
          • – Schedule a telephone consultation
          • – Request a speaker
          • – Submit resumes or work history information
          • – Participate in “join our mailing list” initiatives
          • – Participate in bulletin boards, discussion or message forums
          • – Contact us for further information
          • – Enter Quick Surveys, Quiz’s or Benchmarking Surveys
          • – Register for events and conferences

      Information attained by the site is used only for the intended purpose stated at the time that the information is collected. This data is not shared with a third party, unless otherwise disclosed at the point of collection. A visitor may choose to opt out of having their data transferred to a third party by contacting our Help Desk at either helpdesk@modernthink.com or 888.MTHINK8 (888.684.4658).

      Unless you ask us not to, we may contact you in the future to tell you about specials, new products or services, or changes to this privacy policy. If you want to be removed from our contact lists at any time, you can either click the “Unsubscribe” button listed at the bottom of every email we send, or you can contact us at info@modernthink.com.

      ModernThink makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact us at info@modernthink.com to raise any concerns.

    3. Sharing Your Data

      It is ModernThink’s policy only to disclose information to third parties under the following circumstances:

      • – As required by law through subpoena, search warrant or other legal process
      • – When explicitly requested by a visitor
      • – When required to deliver publications, reports, materials or other information requested by a visitor
      • – When required to facilitate conferences or events hosted by a third party

      In circumstances outside of the above list, a visitor may choose to opt out of having their data transferred to a third party by contacting our Help Desk at either helpdesk@modernthink.com or 888.MTHINK8 (888.684.4658).

    4. Data Retention

      Contact information about visitors (such as information generated though registration for access to areas on the site) will be kept as long as the information is required to completely service the contact request or until a user requests that we delete that information. Mailing list information, discussion posts and email are kept for only the period of time considered reasonable to facilitate the visitor’s requests. Resumes are disposed of when they are either no longer under consideration, or are considered dated by our Human Resources departments.

    5. Your Choices

      As a policy, visitors are not required to register to gain access to areas of ModernThink’s Web sites. In certain cases in the future, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on premium Web sites.

      Personally identifiable information provided to ModernThink through its Web site is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions, on the appropriate Web site area or in communications to our visitors; or a visitor may contact us at info@modernthink.com. A visitor may choose to opt out of having their data transferred to a third party by contacting our Help Desk at either helpdesk@modernthink.com or 888.MTHINK8 (888.684.4658).

    6. Access

      ModernThink is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. User updates of information should be handled by going back through the registration process. When requested and practical, ModernThink will delete identifying information from current operational systems or make appropriate corrections based on the updated information provided by the authenticated visitor. Inquiries about the accuracy of identifying information previously submitted to ModernThink through its Web site, or requests to have outdated information removed, should be directed to: info@modernthink.com.

      When personally identifiable information is retained, ModernThink assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. ModernThink does not assume responsibility for verifying the ongoing accuracy of the content of personal information.

    7. Security

      ModernThink has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All ModernThink employees follow a security policy. Only authorized personnel are provided access to personally identifiable information, and these employees have agreed to ensure confidentiality of this information.

    8. Third Party Links

      There are several places on www.modernthink.com that may link to other Web sites that do not operate under our privacy practices. When you link to other Web sites, ModernThink’s privacy practices no longer apply. We encourage visitors to review each site’s privacy policy before disclosing any personally identifiable information.

  2. Surveys, Focus Groups and Other Data Collection

    1. Data Collection

      ModernThink may be retained by your employer to conduct an employee survey, to facilitate focus groups or to provide a variety of other research and assessment tools. During these survey, research and/or assessment processes, you may be asked on a voluntary basis to submit demographic information that may be considered sensitive. Sensitive information includes a number of types of data including but not limited to information relating to: age; gender; race or ethnic origin; trade union membership. If you do choose to provide sensitive information, ModernThink accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information. Furthermore, if you submit data during a survey, focus group and/or other research or assessment process, we accept your explicit consent to transmit that information across international borders.

      During focus groups and other direct methods of getting data, our facilitators take multiple measures to protect the participants’ anonymity and to create a safe environment where participants will feel comfortable sharing the most candid feedback, even when it is negative. Sample protections include the following: ModernThink is not given the invite list; no sign-in sheets are used; participants are encouraged to take-off their name tags; and no introductions are made.

    2. Data Use

      Organizations typically hire us to help them understand the current state of their employee experience and to help them improve that experience, thereby increasing morale and productivity. Information gathered during our engagements is collected for these purposes and reported back to the employer as explained further below.

      In addition, data collected is added to our benchmarking and best practices database. It is combined with the data collected from organizations throughout the world. These data can then be sorted and reported back by industry, by geography, by company size or by all three. We cite our benchmarking data online and in paper in articles, speeches, reports and the like. We are often compensated for providing such comparative data. We also use this data as needed to further our research of workplace excellence.

    3. Sharing Your Data

      ModernThink is committed to maintaining the confidentiality of the data submitted as part of the survey or other assessment process. In most instances, results are reported back in aggregate form where your results would be combined with others’ results and then reported back overall and also by demographic category. To maintain anonymity, ModernThink will not report any data back for demographic groups where fewer than five people responded. Our surveys typically include open-ended questions where you may write out a response, either on line or on paper. Answers to those open-ended questions are reported back in verbatim form so it is imperative that you do not include any self-identifying data in your responses to the open-ended questions if you want your answers to remain anonymous.

    4. Data Retention


      Because the survey data and other research information is added to our benchmarking and best practices database, it is retained indefinitely. Anonymity is guaranteed by our reporting practices ie. not reporting any data back for demographic groups where fewer than five people responded. But participants can opt out of having their data retained by simply never participating in a study. Every study conducted is voluntary.

      Paper surveys are destroyed within twenty-four months of survey completion.

    5. Your Choices

      Your employer may want you to participate in one of our surveys and/or other assessment processes and may provide us with your name and other information such as email address, job title, etc. so that you can be invited to participate. Ultimately, you have the choice of whether you want to participate at all, and if so, to what extent you want to voluntarily provide us with information. Every study is voluntary, and you are free to opt out of participating. If you prefer not be contacted at all, you can either click the “Unsubscribe” button listed at the bottom of every email we send, or you can contact us at info@modernthink.com. Please feel free to direct any questions or concerns to info@modernthink.com.

    6. Access

      ModernThink is committed to providing reasonable and practical access to employees to allow them the opportunity to identify and correct any inaccuracies. When information is submitted during an employee survey, the employee should make every effort to update and or correct personal information during the period that the survey is live and in-progress. During that time period, user updates of information should be handled by going back through the registration process. Any questions or concerns should be directed to our Help Desk at either helpdesk@modernthink.com or 888.MTHINK8 (888.684.4658).

      When requested and practical, ModernThink will delete identifying information from current operational systems or make appropriate corrections based on the updated information provided by the authenticated visitor. Inquiries about the accuracy of identifying information previously submitted to ModernThink through a survey, or requests to have outdated information removed, should also be directed to our Help Desk at either helpdesk@modernthink.com or 888.MTHINK8 (888.684.4658).

      When personally identifiable information is retained, ModernThink assumes responsibility for keeping an accurate record of the information that a visitor has submitted. ModernThink does not assume responsibility for verifying the ongoing accuracy of the content of personal information.

    7. Security

      ModernThink has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All ModernThink employees follow a security policy. Only authorized personnel are provided access to personally identifiable information, and these employees have agreed to ensure confidentiality of this information.

  3. Children

    ModernThink understands the importance of protecting children’s privacy especially in an online environment. The ModernThink website and survey activities covered by this privacy statement are not intentionally designed for or directed at children 13 years of age or younger. We never knowingly collect or maintain information about anyone under the age of 13.

  4. Changes to this Statement


    ModernThink reserves the right to modify or amend this Statement at any time. To keep visitors informed, ModernThink will notify users of changes to our Privacy Statement by prominently identifying the alteration for a period of not less than two weeks on our global home page at http://www.modernthink.com.

  5. Complaints

    Any complaints that cannot be resolved between ModernThink and a complaining third party will be referred to the United State Council for International Business (USCIB).  Any complaining party must first make a good faith effort to resolve the issue with ModernThink before going to the USCIB.  Please call us toll-free at 888.MTHINK8 (888.684.4658) or email us at info@modernthink.com to discuss a potential dispute.

  6. Contact Us

    We welcome your questions or suggestions. Please call us toll-free at 888.MTHINK8 (888.684.4658) or email us at info@modernthink.com.