Last Updated February 8, 2022.
USER PRIVACY POLICY
Our Privacy Policy for users of our website www.delvetool.com, the Delve web based application (“Delve App”) and related services (collectively “the Services.”)
This Privacy Policy sets out our commitment to protecting the privacy of Personal Information provided to us or otherwise collected by us for our Services. We are committed to high standards for integrity and compliance. Such standards include a commitment to protect Personal Information being processed in the course of our business in accordance with applicable law on privacy & data protection, including the EU General Data Protection Regulation ("GDPR").
This Privacy Policy also forms part of the Terms of Service for using and purchasing our Services.
In this Privacy Policy “you” means any party that provides Personal Information to us and “we,” “us” and “Twenty To Nine” means Twenty To Nine, LLC.
1. Who We Are
Twenty To Nine, LLC is a U.S. based company with headquarters in New York City.
We have developed this Privacy Policy to explain how we collect, store, use, process and disclose your Personal Information.
Please read this Privacy Policy carefully. By providing Personal Information to us, you consent to our collection, holding, use and disclosure of your Personal Information in accordance with this Privacy Policy. Please contact us if you have questions, our contact details are at the end of this Privacy Policy. If you do not wish to provide Personal Information to us, then you do not have to do so, however you may not be able to use our Services.
This Privacy Policy sets out how we protect an individual’s Personal Information and provides information on:
the general categories of Personal Information we collect;
why we collect an individual's Personal Information;
how Personal Information will be used, and who it will be shared with;
how we store, transfer and retain Personal information;
our commitment to security;
privacy and security of User Submitted Information;
your rights in relation to the Personal Information we collect, including rights of EEA data subjects under the GDPR
2. Definitions Used Throughout this Privacy Policy
Personal Information is any information or an opinion about an identified or identifiable natural person (“Data Subject”).
User means any person who uses our Services such as by creating an account, using the Delve App, requesting a demo through our website, contacting us for information, or subscribing to content through our website. A User may also be a person who visits or browses our website.
User Submitted Information means any of the content, information or material that you add or input in your use of the Delve App including the Personal Information of third parties. Twenty To Nine does not own your User Submitted Information; User Submitted information is owned by you. By using the Services, you take full responsibility for obtaining any and all applicable third party consents, securing and safeguarding your User Submitted Information and all other restrictions regarding User Submitted Information as set forth in our Terms and Conditions.
3. What type of Personal Information is collected?
By using our Services you provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Information.") By using the Services you provide us with:
First and Last Name
Email address
Phone number in the event you give it to us to contact you
IP address (may or may not be considered Personal Information depending on the laws of your jurisdiction)
Payment information for the Services should you choose to sign up for a paid plan
Your responses to any surveys, questionnaires, or feedback should you choose to participate
User Submitted Information should you choose to input any in your use of the Delve App
You may choose not to give us your Personal Information. However, without your Personal Information, we may not be able to provide you with the Services or respond to your questions.
4. Visiting our Website
You may also visit or browse our website. As is true of most other websites, when you visit www.delvetool.com (“Website”) we collect information on how you use and access our Website.
Our Website uses Google Analytics and Squarespace Analytics.
Google Analytics uses ‘cookies’ (text files stored in your browser to allow us to analyze how you use our Website). In common with other businesses using Google Analytics the data that is generated by the cookie (including your IP address) is forwarded to a Google server in the USA and stored there.
We use the information collected by Google Analytics. Analytics to help us understand how you use our Website, in order to improve our Website for all visitors.
You can change the settings on your browser to prevent cookies being stored, and you also have the option to stop the capture of data that is generated and processed by Google cookies by downloading and installing this plug-in from Google.
Squarespace Analytics collects Information about your browser, network, and device, Web pages you visited prior to coming to this website and your IP address.
This information may also include details about your use of this Website, including: clicks, internal links, pages visited, scrolling, searches and timestamps.
Squarespace also uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.
Some Squarespace cookies are functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you. Analytics and performance cookies are also used on this site only when you opt in on our cookie banner. We use analytics cookies to view site traffic, activity, and other data.
We share this information with Squarespace to learn about site traffic and activity.
5. How do we use your Personal Information?
We collect and use your information:
To enable you to access and use the Services
To process payments for the Services if you have signed up for our paid plans
To provide you with better customer service
To understand how users use the Services so that can we can make improvements
To contact and communicate with you
To provide you with marketing and advertising from us, including to let you know about our products, services and features
To debug our system and understand errors and crashes
For internal record keeping
6. How do we share your Personal Information and who do we disclose it to?
Twenty To Nine is not in the business of selling your information to advertisers or third parties. We consider this information to be a vital part of our relationship with you. We only share this information for the purposes described below:
Vendors, Data Processors and Related Third Parties: Twenty To Nine, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, processing payments, maintaining databases and improving the Services. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function and they are only authorized to use your information to perform their specific function.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
Legal Requirements: Twenty To Nine may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Twenty To Nine, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
How we store, transfer and retain your Personal Information
Twenty To Nine stores your information on remote servers operated by cloud and database service providers to Twenty To Nine rather than storing it on our own servers. We work with trusted third party vendors and subprocessors for the storage and transfer of Personal Information and enter into data processing agreements and standard contractual clauses whenever feasible. Regardless of where you use our Services or provide information to us, the information may be transferred to and maintained on servers located inside and outside the U.S., including to countries outside the European Economic Area (“EEA”). By using our Services you acknowledge, agree and consent to your information, including your Personal Information, being processed outside your jurisdiction, including in countries and jurisdictions that may not provide the same level of protection. Such transfers will only take place for the specific purposes mentioned in this Privacy Policy, and we will always ensure that appropriate safeguards are in place for such transfer, depending on the specific country.
Twenty To Nine retains your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. You can ask us to delete your Personal Information at any time by contacting us. We will delete all Personal Information including all User Submitted Information associated with you within two weeks of receiving your request. Users who have an account with us may delete User Submitted Information at any time using tools within our Services. Users with accounts may also save their User Submitted Information to their own devices at any time and we encourage you to do so because it is your sole responsibility to make backup copies. When you request that we delete your account, it is your sole responsibility to download, print, or copy any of your User Submitted Information beforehand. Twenty To Nine shall not be liable to the User or any person for the deletion or failure to store any Personal Information including User Submitted Information arising from the account holder’s decision to terminate their account or otherwise.
8. Our Commitment to Data Security
We are committed to ensuring that the information you provide is secure. In order to prevent unauthorized access or disclosure, we have put in place commercially reasonable measures to safeguard and secure your Personal Information and protect it from misuse, interference, loss and unauthorized access, modification and disclosure. For more information about our security measures in relation to User Submitted Information, please see the section below.
No information transmitted over the Internet can be guaranteed to be secure, however. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that Personal Information that we collect and User Submitted Information that you give us will not be disclosed in a manner that is inconsistent with this Privacy Policy.
9. Privacy and Security of User Submitted Information
When you use the Delve App, you may choose to provide us with User Submitted Information. All User Submitted Information is owned by you, and is never sold to 3rd parties. User Submitted Information is only shared with our trusted vendors and subprocessors and only for the purpose of enabling and enhancing your use of the Services. To view a list of our subprocessors and what they do, please visit our Delve Software Subprocessor page.
We store your User Submitted Data with database providers rather than on our own servers. We work with trusted third party vendors and subprocessors for the storage and transfer of User Submitted Information and enter into data processing agreements and standard contractual clauses whenever feasible. Regardless of where you use our Services or provide information to us, the User Submitted Information may be transferred to and maintained on servers located inside and outside the U.S., including to countries outside the European Economic Area (“EEA”).By using our Services you acknowledge, agree and consent to your User Submitted Information being processed outside your jurisdiction, including in countries and jurisdictions that may not provide the same level of protection.
We take the security of your User Submitted Information seriously and we use a variety of security measures to help keep your information safe. Some of these features include encrypted in transit, encrypted at rest, SSL certificates and OA Authentication for user logins. Please contact us for more information on our security features for the Delve App.
10. Your Rights under the General Data Protection Regulation (GDPR)
If you are a “data subject” under applicable data protection law in the European Economic Area (EEA), you will have the following rights in relation to Personal Information that we hold about you:
Right to Access - to request confirmation of whether we process Personal Information relating to you, and if so, to request a copy of that personal data;
Right to Rectification - to request that we rectify or update any Personal Information that is inaccurate, incomplete or outdated;
Right to Erasure - to request that we erase your Personal Information in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
Right to Restriction of Processing - to request that we restrict the use of your Personal Information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your Personal Information;
Right to Withdraw Consent - where you have given us consent to process your Personal Information, to withdraw your consent; and
Right to Data Portability - to request that we provide a copy of your Personal Information to you in a structured, commonly used and machine readable format
To exercise your rights as set out above or please contact our Data Protection Officer (see How to Contact Us below).
Please note that we will ask you to verify your identity for the security of your personal information before responding to such requests.
11. Our legal basis for processing (for EEA Data Subjects)
Twenty To Nine has a legitimate business interest in operating and improving its business and the services it offers and may collect, store, use, process and disclose your Personal Information (and you consent to us doing so) for the following purposes:
To provide you with information, products or Services that you request from us
To improve our Services in order to better serve you
To enable us to respond promptly to your customer service requests
To facilitate payment transactions
To review our services or products
To communicate with you as a follow up to any queries via live chat, email or phone
To provide the Services, information or products you have requested or to carry out the transaction(s) you have authorized (or we may disclose this information to our vendors and processors to undertake this activity on our behalf).
For research and development in order to improve our service and product offerings
12. Children’s Privacy
Twenty To Nine does not knowingly collect Personal Information from children under the age of 16. If you are under the age of 16, please do not use the Services. If you have reason to believe that a child under the age of 16 has used the Services of Twenty To Nine, please contact us, and we will take steps to delete that information from our databases and servers.
13. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our website, and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
14. Who to Contact for Data and Privacy Inquiries and Requests
Twenty To Nine has appointed an internal data protection officer for you to contact if you have any questions or concerns about our Personal Information policies or practices or to exercise your rights under the GDPR. Our data protection officer’s name and contact information are as follows:
Alex Limpaecher
alex@twentytonine.com