Privacy Policy

For questions or concerns relating to privacy, contact:
Project: WorldWide, Inc., Attn: Data Privacy Champion, 1914 Taylor Point, Auburn Hills, MI 48324-8326; +1 (248) 475 2500; dataprivacy@project.com
Project Worldwide, Inc. (“Project” or “we”) respects the privacy of its website users. We created this privacy policy (“policy”) to inform you of how we collect, use, share, and protect your personal information when you use our website, located at https://project.com/ (“website”).
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By using or accessing the website, you understand the terms of this policy apply to the policy. If you do not agree to the terms of this policy, do not continue to use the website.

Last modified: [date]

Introduction

This policy applies to information we collect:

• On this website;
• In email, text, and other electronic messages between you and this website; and
• When you interact with our advertising and applications on third-party websites and services, if those third-party websites, applications, or advertising that include a link to this policy.

It does not apply to information collected by:

• Us offline or through any other means; or 
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through this website.

This policy may change from time to time (see Changes to this Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Children Under the Age of 18

Our website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on this website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us using the information at the top of this policy.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your Privacy Rights for more information.

Information We Collect About You and How We Collect It

When you use this website, you may choose to provide Project with certain personally identifiable information about yourself (“PII”). We may also collect other information about your use of this website that is not PII (“Aggregate Information”). Below is a list of the categories of PII we collect and some examples of the information that would fall into each category, not everything listed in the examples is PII. Except for your IP address, we only collect PII you voluntarily provide to us.

We collect several types of information from and about users of our website, including information:

• By which you may be personally identified, such as name, employer, IP address, postal address, email address, and telephone number (all of which is PII);
• That is about you but individually does not identify you, such as web browser, and webpages visited on our website; and/or
• Regarding an inquiry, such as information about your attendance at or inquiry about an event, inquiry about our services or contacting us through our website with other inquiries.

We collect this information:

• Directly from you when you provide it to us. We obtain your PII, except your IP address, when you voluntarily provide it to us; and  
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

The information we collect automatically (Aggregate Information) does not include personal information, except your IP address. It is intended to helps us to improve our website and to deliver a better and more personalized service, including by enabling us to: (i) estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our website according to your individual interests; (iii) speed up your searches; and (iv) recognize you when you return to our website. The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by applying the appropriate setting on your browser. If you choose to have your browser refuse cookies, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. 
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages or opened an email as well as for other related website statistics. 

This website utilizes Google Analytics, a service from Google, Inc. (Google) that uses cookies. The information collected by the cookies (which includes your IP address) is transferred to Google who stores and processes the information in the United States. Google uses the information to provide us with an analysis of your use of this website, overall use of and traffic on this website and other related services. You can opt out of Google Analytics by utilizing the Google Analytics Opt-out Browser Add-on. 

Our website has collected the following categories of information from consumers within the last 12 months: 

Category	Examples	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	No
PII categories listed in the California Customer Records statute	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	No
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data	Physical location or movements.	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
Professional or employment-related information	Current or past job history or performance evaluations.	No
Non-public education information (under the Family Educational Rights and Privacy Act)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences drawn from PII	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

How We Use and Disclose Your Information

We may use and/or disclose PII that we collect about you:

• To present and administer our website.
• To provide you with information, products, or services that you request from us.
• To contractors, service providers, and other third parties we use to support our business or provide the products and services we provide, such as our website.
• To our corporate family (such as subsidiaries and affiliates).
• To fulfill any other purpose for which you provide it.
• To contact you or provide information about products and services. 
• To recruit.
• To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collection.
• To the extent required by law, to comply with any court order, law, regulation, or legal process, including to respond to any government or regulatory request.
• To facilitate or in relation to a corporate transaction.
• To the extent necessary or appropriate to protect the rights, property, or safety of our customers or others.
• To notify you about changes to our website or any products or services we offer or provide though it.
• In any other way we describe when you provide the PII.
• For any other purpose with your consent.

We may use and/or disclose Aggregated Information without restriction. 

The following chart shows whether we have disclosed for business purposes or sold PII in the preceding 12 months.

PII Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
Identifiers	None	None
California Customer Records PII categories	None	None
Protected classification characteristics under California or federal law	None	None
Commercial information	None	None
Biometric information	None	None
Internet or other similar network activity	None	None
Geolocation data	None	None
Sensory data	None	None
Professional or employment-related information	None	None
Non-public education information	None	None
Inferences drawn from PII	None	None

Do Not Track Signals and Requests

‍Do not track signals and requests are sent from your browser to websites you visit indicating you do not want to be tracked or monitored. In most circumstances you need to affirmatively elect to turn on the do not track signals or requests.  Websites are not required to accept these signals or requests, and many do not. Currently, this website does not honor do not track signals or requests.

Linked Websites

We provide links to other websites and applications (“Linked Websites”) for informational purposes, for your convenience, or to offer additional services through separate websites. Linked Websites are independent from our website and are not governed by this policy. We do not review, have control over their content or endorse Linked Websites or the information, software, products or services available on the Linked Websites. We also have no control over the privacy policy of Linked Websites. If you decide to access any of the Linked Websites, you do so at your own risk.

Your Privacy Rights

Any PII collected by or through our website will be used only for the purpose it was provided and as described in this policy. Once PII is no longer necessary, we will destroy the PII in accordance with our record retention and destruction policy.

Some jurisdictions (state, federal, national and international), such as California (through the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”)), Canada, Colorado, Connecticut, the European Economic Area (through the General Data Protection Regulation (“GDPR”)), Texas, and Virginia, provide individuals with certain rights regarding their PII. To exercise any rights your jurisdiction may provide, contact us at dataprivacy@project.com. The following are examples of privacy rights. Your specific privacy rights will depend on where you reside.

• ‍Being informed about your PII and how we control or process it.
• Confirm whether we process your PII.
• Viewing and obtaining a copy of the PII we maintain about you.
• Correct or amending inaccuracies in their personal information, accounting for the nature of the PII and our processing purpose. 
• Having the PII we keep about you erased (the right to be forgotten).
• Opting-out of or objecting to the use of your PII for direct marketing, targeted advertising, or sales.
• Opting-out of or objecting to our use (including the sale) of the PII we maintain about you. We do not currently sell PII. 
• Transferring the PII we maintain about you to another entity.
• Opting-out or objecting to our use of the PII we maintain about you.
• Opting-out or objecting to automated decision making or automated profiling.
• Knowing from where we obtained your PII.
• To receive the same products or services (to the extent possible) at the same price regardless of whether you exercise your privacy rights under this policy.
• Withdraw your previously provided consent (this right may only be available on a prospective basis).
• Filing a complaint with us or the appropriate governmental entity.

Some jurisdictions provide their residents with rights about their personal information or PII. Please provide the following information so that we may process your request. The PII you provide on this form will be subject to this privacy policy. Please note that this right may be subject to exceptions, and, in responding to your request, there may be circumstances in which the law does not require or permit us to honor your request (for example, to delete or correct your information). If you are an authorized agent making a request on behalf of a consumer, please check the appropriate box.

Additional information for California residents

You have the right to request we disclose information to you about our collection and use of your PII over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you: 

• The categories of PII we collected about you.
• The categories of sources for the PII we collected about you.
• Our business or commercial purpose for collecting or selling that PII.
• The categories of third parties with whom we share your PII.
• If we sold or disclosed your PII for a business purpose, lists disclosing sales, identifying the PII categories that each category of recipient purchased and disclosures for a business purpose, identifying the PII categories that each category of recipient obtained.
• The specific PII we collected about you.

You have the right to request that we delete your PII we collected from you, subject to the following exceptions. Once we receive your request and confirm your identity, we will review your request and determine if an exception allowing us to retain the PII. We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

• Complete the transaction or provide the services or products for which we collected the PII and to take actions reasonably anticipated within the context of our relationship with you, or otherwise perform our agreement with you.
• Detect and/or assess security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and/or prosecute those responsible for such activities.
• Correct products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest adhering to all applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses reasonably aligned with consumer expectations based on our relationship.
• Comply with a legal obligation or restrictions.
• Make other internal and lawful uses that are compatible with the context in which you provided it. 

We will delete or deidentify PII not subject to one of these exceptions from our records and will direct service providers to do the same. 

International Transfers and Processing of PII

We store information received through or by our Website in the United States. If you are providing the information from another country, you understand that the information will be transferred, stored, and used in the United States.

EU-US, Swiss-US and UK-US Data Privacy Framework 

We comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. We have 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 and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  We have certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint.  The services of JAMS are provided at no cost to you.
An individual may, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any other means. For information visit https://go.adr.org/dpf-annexi-fund.html. 

The Federal Trade Commission has jurisdiction over our compliance with the DPF.

We are committed to resolve complaints about our collection or use of your PII. Those with inquiries or complaints should contact us using the information at the top of this policy or at dataprivacy@project.com, attn: Data Privacy Framework. 

Data Security

We have put in place reasonable physical, electronic, and administrative (managerial) procedures to safeguard the information we collect that are compliant with applicable law. We take reasonable steps and regularly assess our privacy and security policies and procedures and comply with laws designed to protect the privacy and security of your PII. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your PII, we cannot guarantee the security of PII transmitted to our website. Any transmission of PII is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on this website.

Changes to Our Privacy Policy

We reserve the right to amend this policy at any time and at our sole discretion. If we plan to use PII in a way that materially differs from what is described in this policy, we may will post a notice on the homepage of this website and/or email you (if we have a valid email address on file). Your continued use of the Website following the posting of any changes to this Notice means you accept those changes. The date the privacy policy was last revised is identified at the top of the page.