JURISDICTION OF USE
USER agrees to abide by the applicable laws of the applicable state and US federal law concerning use COMPANY media and any resulting interactions, engagements, or agreements with COMPANY. Any USER accessing COMPANY media from any jurisdiction with laws and regulations governing the use of the Internet, including, personal data collection, use, and disclosure, different from those jurisdictions mentioned above may only use COMPANY media in a manner lawful in their jurisdiction. If USER’S interaction with COMPANY media would be unlawful in USER’S physical jurisdiction, COMPANY requests that USER not interact with COMPANY media.
GATHERING, USE, AND DISCLOSURE OF PERSONAL INFORMATION
Generally, Not Personally Identifying (NPII) information is data that, without the aid of additional information, cannot be directly associated with a specific person. Personally Identifying Information (PII), by contrast, is data such as USER’S name or email address that, without more, can be directly associated with a specific person.
Like most online media operators, COMPANY gathers PI from USERS, including information that various web browsers, depending on settings, may make available.
That information may include USER’S Internet protocol (IP) address, operating system, browser type, media USER interacts with before interacting with COMPANY online media, or media USER interacts with immediately after leaving COMPANY online media. While this is information is not personally identifying, it may be possible for COMPANY to determine from an IP address or USER’S Internet service provider the geographic location of USER’S point of connectivity and other statistical usage data.
NOT PERSONALLY IDENTIFYING INFORMATION (NPII)
COMPANY may analyze NPII gathered from USER to help COMPANY better understand how COMPANY media is being used. This analysis may include identifying patterns, trends, and usage information helpful in COMPANY’S design and optimization of COMPANY media, regarding types of content, USER experience, and ease-of-use. From time to time COMPANY may also release NPII gathered from use of COMPANY media in aggregate; including by publishing a report on trends and usage of the COMPANY media.
ONLINE MEDIA TRACKING – WEB COOKIES
ONLINE MEDIA TRACKING – TRACKING BEACONS
A Tracking Beacon is an object that is embedded in online media or electronically transmitted messages that may or may not be visible to the USER and allows COMPANY to check whether USER has viewed, engaged, or interacted with COMPANY media. COMPANY may use Tracking Beacons on websites, in emails, or other COMPANY online media, to count users, to track a USER’s visits to and interaction with particular content, or to confirm whether a USER viewed emails and to deliver cobranded services.
COMPANY may analyze USER Tracking Beacon data in compilation and / or aggregation in COMPANY development of statistics regarding online media usage. Tracking Beacons collect only a limited set of information, including, web cookie status and details, number and time of media interactions, online media pages or email messages viewed, and a description of the page or email in which the Tracking Beacon resides.
YOU may not be notified when COMPANY begins use of Tracking Beacons on COMPANY media; however they can be rendered ineffective by declining our cookies or modifying your browser to notify you each time COMPANY employs a Tracking Beacon. These settings will permit you to accept or decline COMPANY’S use of Tracking Beacons.
COMPANY may share aggregated NPII collected under any of the above circumstances. COMPANY may share this information with third parties and affiliate companies to develop and deliver targeted marketing, advertising, or public relations communications via any and all COMPANY media channels. This sharing may result, when clearly indicated, in communication with USER by third parties. COMPANY may combine information it collects with additional not personally identifying information from other sources. COMPANY may share aggregated NPII with third parties, including, advertisers, for the purpose of conducting general business analysis. For example, COMPANY may tell advertisers the number of users COMPANY media attracts. This information will not contain any personally PII. NPII may be used to develop COMPANY media or service targeting and / or optimize other promotional vehicles and channels.
PERSONALLY IDENTIFYING INFORMATION (PII)
As defined above, PII is data that can be directly associated with a specific person. COMPANY may collect PII from and about COMPANY media users. Much of the PII collected by COMPANY about users is information provided by users themselves when registering for services or communications, including from COMPANY affiliates and partners, registering for information from our partners, logging in to COMPANY applications.
COMPANY may request information about USER’S interests, activities, gender, age, birthdate, company, title, career focus, mailing address and other contact information, and other demographically relevant information. USERS are under no obligation to provide COMPANY with PII of any kind with the caveat that a USER’S refusal to do so may prevent USER from interacting with certain COMPANY media.
COMPANY may use email addresses, where authorized by USER, to communicate notifications regarding new services and / or partners. COMPANY may also send YOU service-related announcements. USER may opt out of such emails at the time of registration, receipt, or at any time through well-placed unsubscribe resources at included in all COMPANY communications. COMPANY reserves the right to send USER notices about USER’S interaction with COMPANY and COMPANY media even if you do opt out voluntarily from all email notifications.
THIRD PARTY COMMUNICATIONS
Unless USER opts out from receiving marketing communications upon registration, or unsubscribe communication, COMPANY may provide user email information to third parties, where expressly indicated, so that this third parties may directly contact USER about additional products and services.
BUSINESS TRANSFERS AND BANKRUPTCY
CALIFORNIA PRIVACY RIGHTS
California civil code (CVC) Section 1 798.83 also known as the “Shine the Light” law, permits USERS or California residents to request and obtain from us, once per year and free of charge, information about PII we disclose to third parties for direct marketing purposes, in the preceding calendar year. If applicable, this information could include a list of companies, partners, or affiliates that PII was shared with and the names and contact information of those third parties. If YOU are a California resident and would like to make such a request, please contact COMPANY via any of the posted means, including those below.
DO NOT TRACK POLICY
Most web browsers and some mobile operating systems include do not track features or settings YOU can activate to signal your preference not to have data about your online browsing activities monitored, nor collected. COMPANY online media does respond to DNT browser signals or mechanisms.
INFORMATION FOR INDIVIDUALS OUTSIDE THE U.S.A.
COMPANY may collect, organize, process, and store publicly available business information in the United States and other countries. The laws in the U.S. regarding publicly available business information may be different from the laws of your state or country. Any transfers will comply with safeguards as required by relevant law.
FOR INDIVIDUALS IN EEA & SWITZERLAND
Purpose and Legal Basis for Processing:
If you are a resident of the EEA or Switzerland, the following information applies. COMPANY processes publicly available business data in various ways. COMPANY processes publicly available business data on the following legal bases: (1) with consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests where those interests do not override your fundamental rights and freedom related to data privacy. COMPANY’s collection of publicly available business information is fundamental to COMPANY’s legitimate interests to organize, engage, and make available business contact information, given the limited impact of this data on an individual’s private life and that this information, unlike personal contact details, is widely disclosed. COMPANY does no collect, organize, nor process personal information that is not publicly available.
Right to Lodge a Complaint:
Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here (https://ec.europa.eu/info/policies/justice-and-fundamental-rights_en).
The publicly available business information COMPANY collects may be transferred to, and stored and processed in, the United States or any other country in which COMPANY or affiliates or subcontractors maintain facilities. Upon the start of enforcement of the General Data Protection Regulation (GDPR), COMPANY will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR. Please see “Privacy Shield Frameworks” below regarding our compliance with the EU- and Swiss-US Privacy Shields.
If you are a resident of the EEA or Switzerland, you are entitled to the following rights once the GDPR becomes effective. Please note: In order to verify your identity, COMPANY may require you to provide us with personal information prior to accessing any records containing information about you.
Right to Access and Correction.
You have the right to request access to any publicly available business information that COMPANY is storing under your name, at no charge, as well as certain information about our processing activities with respect to your data. You have the right to request correction or completion of your publicly
available business information, if it is inaccurate or incomplete. You have the right to restrict COMPANY’S processing if you contest the accuracy of the data COMPANY holds about you, for as long as it takes to verify its accuracy.
Right to Request Data Erasure.
You have the right to have your publicly available business information erased from COMPANY systems if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
Right to Object to Processing
You have the right to object to COMPANY processing if COMPANY is processing your publicly available business information based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
PRIVACY SHIELD FRAMEWORKS
For information received under the Privacy Shield, COMPANY will require third parties to whom COMPANY discloses publicly available business information to safeguard that publicly available business information consistently with this Policy by contract, obligating those third parties to provide at least the same level of protection as is required by the Privacy Shield Principles. EU citizens may choose to opt-out of such disclosures.
TCI Marketing Services
Attention: Plamen Marinov
1111 Bay Hill Dr., Suite 408 San Bruno, CA 94066
Telephone: +1 (650) 794-3722