Effective date: December 7, 2020
Indtai, Inc. ("us", "we", or "our") operates the Transfer Virginia website located at www.transfervirginia.org ("Site") on behalf of the Virginia Community College System ("Client") and other organizations that Client may invite to participate ("Participating Organizations") in Transfer Virginia. This Site, together with any associated support services provided by Indtai to you, Client and any Participating Organizations, shall be referred to as the "Service".
We use your Personal Data to enable Client and any Participating Organizations to provide you with the Service and improve it.
- Our policies and procedures regarding the collection, use, protection, and disclosure of Personally Identifying Information (PII) and other any other information you choose to provide, collectively "Personal Data", from and during your use of the Service.
- Your rights and choices with respect to your Personal Data, and how you can reach us to update your contact information or get answers to questions you may have about our privacy practices.
Service: is the www.transfervirginia.org website, operated by Indtai, Inc. and any associated services, such as customer support.
Participating Organizations: One or more organizations invited by Client to participate in providing the Service to users.
Personally Identifiable Information (PII): is any information that permits the identity of an individual to be directly or indirectly inferred including any information that is linked or linkable to that individual.
Sensitive PII: Personally Identifiable Information, which if lost, compromised, or disclosed without authorization, could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. Examples of sensitive PII are: full Social Security Number, birth date, driver's license number, passport number, etc. (Definition adopted from "Handbook for Safeguarding Sensitive Personally Identifiable Information", Department of Homeland Security, March 2012.)
Usage Data: is data collected automatically that is either generated by your use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies: are small files stored on your device (computer or mobile device).
2. Personal Data We Collect or Receive
a. Personally Identifiable Information (PII)
While using the Service, we may ask you to provide us with certain PII that can be used to contact or identify you. Such PII may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Military Service information. For users of the Service, who self-identify as having a military background:
- Service Branch,
- Service Status,
- Service start Date,
- Months of Service
- Military Occupation Code (Army MOS, Navy/Coast Guard Rating, Marine Corps MOS, Air Force Specialty Code)
At no point in your use of the Service will you be asked to provide "sensitive" PII such as your birthdate or Social Security Number.
b. Additional Personal Information You May Provide
To fully use the service and the value provided by Client and any Participating Organizations, you may choose to provide additional information about your prior experience, education and training, credentials, awards and honors, etc. to build an e-Portfolio. Such content is related to you and is considered personal information.
You are strongly advised to ensure that any additional personal information you provide when entering data or text or uploading documents during your use of the Service does not contain sensitive PII.
c. Usage Data
We may also collect information, such as log files, on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Google Analytics is used by us to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Do Not Track
Indtai does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use our Service.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies, such as beacons, tags and scripts, may also be used to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
3. Use of Your Data
Indtai, Inc., Client and Participating Organizations do not use your Personal Data for any purposes, such as marketing, advertising etc. except for the purposes described below and in Section 6:
- Establish your account during registration and subsequent maintenance of that account, such as password resets.
- As needed for the functions provided to you by the Service.
- Allow you to participate in interactive features of our Service when you choose to do so.
- Provide customer support.
- Gather analysis or valuable information so that we can improve the Service.
- Monitor and report on the usage of the Service to Client and Participating Organizations.
- Detect, analyze, prevent and address technical issues.
4. Location of Your Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
5. Who May Access Your Personal Data
Except as described below and in Section 6, Indtai does not share, provide, sell or in any manner disclose your data to third parties.
Access by Client and Participating Organizations
The Service provides mechanisms for you to explicitly designate your Personal Data to be accessible to Client and Participating Organizations to meet your objectives for using the Service. Client and Participating Organizations agree to protect and secure your personal data and provide access only to employees or staff with a need to access to it.
You may choose at any time, to use those same mechanisms within the Service, to withdraw your consent. This will the remove your Personal Data from being accessible to Client or any Participating Organizations that you had previously enabled to access your Personal Data.
Service Providers We employ third party companies to facilitate our Service ("Service Providers"), provide the elements of the Service on our behalf, perform Service-related functions or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated by contract and their information security policies to protect and secure your personal data and not disclose, use or provide access to their employees for any other purpose.
6. Disclosure Exceptions
Under certain circumstances, Indtai, Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Indtai, Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation.
- To protect and defend the rights or property of Indtai, Inc.
- To prevent or investigate possible wrongdoing in connection with the Service.
- To protect the personal safety of users of the Service or the public.
- To protect against legal liability.
7. Security of Your Personal Data
Indtai uses industry best practices as well as commercially available physical and electronic security measures to establish a multi-level security posture to protect against the loss, misuse and unauthorized access, disclosure, alteration, and destruction of your Personal Data. Such measures include but are not limited to the use of firewalls, anti-malware and anti-virus measures, intrusion detection, traffic monitoring, encryption technologies, etc. For example, all information you enter is encrypted when it is enroute from your browser to our web servers. Further, your personal data is also encrypted when stored in our database servers ("encrypted at rest").
Transfer Virginia is W3C compliant and performs properly on all major operating system platforms as well as all major modern internet browsers specifically including, but not limited to, Windows, Macintosh, Linux, iOS, Chrome, Safari, Firefox, Edge, Internet Explorer, and the built-in Internet browsers for iOS and Android.
Your account is password protected, and account access is provided only to the account holder who created the password. Access to your Personal Data is also available to credentialed staff at Client and Participating Organizations to whom you have granted permission to access your data, and Indtai employees who require access to operate, administer and maintain the Service or to provide requested customer support.
All Indtai employees who have access to the Personal Data residing in Transfer Virginia have agreed in writing to adhere to Indtai's Information Security policies that protect all such data. Indtai holds employees accountable to a Code of Conduct and Ethics to protect user information. Indtai also trains its employees to protect customer information and only authorizes access for employees have a business need for that information.
The safety and security of your PII also depends on you. You should not include sensitive PII in any content you create or upload or send to us via email. You are also responsible for keeping your account username and password confidential. Please notify us if you become aware that your account information is lost, stolen, or used without your permission; we may disable access to your account in order to prevent an unauthorized third party from accessing your account.
While we employ industry-standard security measures to protect the privacy of your PII, we cannot guarantee that your PII will never be compromised. No Internet or wireless network transmission is ever 100% secure, and no security system can prevent all security breaches. We do not and cannot guarantee that there will be no unintended disclosures of your PII or that unauthorized third parties will not defeat our security measures or use non-public information for improper purposes.
8. Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
9. Children's Privacy
We do not knowingly collect personally identifiable information from anyone under the age of 13 in the US.
If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us and we shall take steps to remove that information from our servers.
11. Contact Us