Privacy Policy

Last Updated Date: June 2021

At The Data Incubator (“TDI”), the privacy and security of our customers and visitors (“you” or “your”) are paramount. TDI is committed to protecting the data you share with us that can be used to directly or indirectly identify you (“Personal Data” or “Data”) when you visit our website and/or websites operated by TDI (“Sites”), and/or participate in our programs. They type of Personal Data we collect, how we use that Personal Data and who we share it with is explained in detail in this Privacy Policy (“Policy”).

All terms not defined in the Privacy Policy will have the meaning set forth in the Terms.

Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number.  We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.


Although we encourage you to read the entire Policy, the following provides a summary of some of the important aspects of this Policy, including the most recent changes:

  • This Policy is applicable to Personal Data we collect from you through our Sites, Programs or Certifications.
  • We may collect both Non-Personal Data and Personal Data from you.
  • Your Personal Data will not be used or shared with third parties except as permitted by this Policy.
  • You can “opt out” of certain uses of your Personal Data or request that your Data be forgotten.
  • We will take reasonable and appropriate measures to secure your Personal Data, but we make no promise that your Personal Data will remain secure in all circumstances.


We collect Personal Information when you:

  • Apply to be a Fellow;
  • use the Site; and
  • communicate with us. 

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Site.

The Data we collect about you through the Site and our Programs and Certifications may include both “Non-Personal Data” and “Personal Data.”

Non-Personal Data” means Data that may not by itself be reasonably associated with, linked to, or used to identify you. For example, general, non user-specific Data regarding your use of the Site or participation in Programs or Certifications.

Personal Data” means Data that may be reasonably associated with, linked to, or used to identify you or allow you to be personally identified or contacted. For example, Personal Data may include Data such as your name, email address, telephone number, address, or credit card number either alone or in combination with other Data.

Sources of Data
From You. We may collect Data about you through the Site, applications, programs, certifications and from a variety of sources. These include from you directly when, for example, you apply to one of our programs, when you visit and use the site, respond to TDI’s surveys, subscribe to our newsletter, or otherwise communicate with us. To apply to be a Fellow, you must provide Personal Information, including your name and email address.  You must also provide your educational history and location.  You may also provide other optional information.  If you participate in the Referral Program, we may also collect Personal Information associated with your email and or payment account.

From Third Parties. We may also obtain Data about you from third parties who provide us with that Data. For example, we may contract to obtain Data about you from third parties that collect or obtain Data about you and have the right to provide that Data to businesses such as ours. We may use any Data about you we receive from a third party in accordance with the terms we establish with that third party. Only if we combine that Data with Data we collect under this Policy will we be required to use that Data in accordance with this Policy.

From the Site. We may collect Data about you automatically when you interact with the Site. For example, Company and our third party service providers may use “cookies” to monitor and collect Data regarding how you access, use, and interact with the Site. “Cookies” are commonly used small files that are stored on your computer or mobile device to help identify you as a unique user of the Site.

We may use cookies that expire once you close your browser or log out of the Site or that persist and stay on your computer until you delete them. Most browsers will allow you to erase cookies from your computer, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more Data.

The computers we use to provide the Site may also automatically record Data about you. For example, our web servers may record the Data you enter when using the Site (including registration Data), the areas of the Site you visit, the services you use through the Site, your IP address, or cookies that are set on your browser. We may use any Data we collect from you automatically through the Site in accordance with this Policy.

Please note that our third party providers may also use cookies, web beacons, or other online tracking technologies in messages displayed on or communicated through the Site (“web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Site that allow you to be recognized when you visit that area of the Site). We do not have access to Data that would confirm all uses of cookies, web beacons, or other online tracking technology by our third party providers.

By using the Site, you are authorizing us to gather, parse, and retain data related to the provision of the Site.

Customer Support.  We may collect Personal Information through your communications with our customer-support team. 

How the company uses your information

Non-Personal Data. We may use and share the Non-Personal Data to develop new programs, services and other offerings.

Personal Data. We may use the Personal Data we collect about you for a variety of purposes, for example:

  • Providing our Program Certifications to you
  • Operating the Site and providing services to you through the Site;
  • Customizing and improving the Site, Programs and Certifications for you;
  • Providing maintenance, support, and customer service for the Site, Programs and Certifications;
  • Providing notices and announcements to you relating to the Company, our Programs and Certification offerings, the Site, or your Data;
  • Providing offers for products, services, or other offerings that we feel may be of interest to you;
  • Contacting you for direct marketing purposes;
  • Processing payments made through the Site or for our Programs;
  • Developing additional products, services and offerings; and
  • Research and analysis.

We may combine and enhance the Personal Data we collect and obtain about you with Data we receive from third parties, provided that we use the combined Data in accordance with this Policy.


How we share data

Affiliates and Subsidiaries. We may share Data with our affiliates and subsidiaries, including companies that we own or control, that own or control us, or that are under common ownership or control with us. We will require that our affiliates and subsidiaries agree to use the Data we share with them in compliance with this Policy.

Service Providers. We may share Data we collect about you with our third party service providers that help us provide the Site and our Programs and Certifications. We require that our third party service providers agree to use the Data we share with them only to perform their obligations to us and to treat all Personal Data they receive from us in compliance with this Policy.

Other Entities. We may share Data with third party companies and entities so that they may develop and offer additional products and services to you that we believe will be of interest to you based on the Data we collect and obtain about you.

Law Enforcement and Processes. We may share Data with law enforcement agencies if we reasonably believe unlawful activities have occurred or the Data may aid in an investigation into unlawful activity. We may also share Data with law enforcement if we determine, in our sole judgment, that you have violated our agreements or policies or that the release of your Data may protect the rights, property, interests, or safety of Company or any third party.

Business Transactions. If we transfer ownership or control of any portion of Company or the Site, Programs or Certifications to a third party, whether or not in the context of an acquisition, merger, or reorganization, we may transfer Data to that third party, provided that the use of any of your Personal Data by that third party remains subject to the terms of this Policy.

We Use Vendors and Service Providers.  We may share any information we receive with vendors and service providers retained in connection with the provision of the Site, including but not limited to any third party we use to make payments through the Referral Program.

Social Networking and Other Websites.  The Site may allow you to share information, including Personal Information, with social networking websites, such as Facebook.  We do not share your Personal Information with them unless you direct the Site to share it.  Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.

Marketing.  We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.  We may allow access to other data collected by the Site to enable the delivery of online advertising on this website, or otherwise facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.

As Required By Law and Similar Disclosures.  We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours’, ours’ or  others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.  We cannot control how such entities may use or disclose such information.

We may also disclose your Personal Information with your permission.


We are committed to protecting and securing your Personal Data. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your Data will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to ensure the safety and security of your Personal Data. This includes using industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Data under our control. For example, our policy is that only those individuals who need your Personal Data to perform a specific job for us are granted access to that Personal Data. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable Data on are kept in a secure environment.

Additional Terms

Children. The Site and our Programs and Certifications are not directed to children under 13 years of age. The Company does not knowingly solicit or collect personal Data from children under 13 years of age.

Do Not Track. Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, we do not modify your experience on the Site or the Data we collect from you through the Site based on whether such a preference is indicated.

Your California Privacy Rights. California law provides that California residents have a right to request that businesses tell them how their personal Data has been shared with third parties for use in direct marketing purposes. There is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s Personal Data to third parties for use in direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Data to third parties for such purposes. We have adopted a policy of allowing you to opt-out of the disclosure of your Personal Data to third parties for direct marketing purposes and thus fall within this exception. 

International Users

By using the Site, you will transfer data to the United States.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

By choosing to visit the Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with Company or the Site will be in accordance with the Terms of Use.

Update your information, pose a question or a suggestion

If you would like to update or correct any information that you have provided to us through your use of the Site or otherwise, or if you have suggestions for improving this Privacy Policy, please contact us.

Changes to our privacy policy and practices

We may revise this Privacy Policy, so review it periodically.

New Uses of Personal Information.  From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy.  If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Posting of Revised Privacy Policy.  We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted.  If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.