This policy describes the types of information we may collect from you or that you may provide when you visit the website at the following URL: https://tmgcore.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- on the Website.
- in email, text, and other electronic messages between you and the Website.
- when you provide information to third parties that may perform services on behalf of the Company.
This policy does not apply to information that we collect offline or through (i) any other means, including on any other website operated by Company or any third party; or (ii) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Website.
We collect, use and are responsible for certain personal information about you. When we do so, we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
- Personal Information We Collect About You. We may collect and use information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”), as shown below:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||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.||YES|
|C. 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|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. 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|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||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|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
This personal information may be required to provide our products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing our products and services to you.
2) How and Why We Use Your Personal Information. We may use your personal information for the following purposes:
- To comply with our legal and regulatory obligations;
- To present our Website and its contents to you;
- To provide you with information, products, or services that you request from us;
- To notify you about changes to our Website or any products or services we offer or provide though it.
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we may use (process) your personal information for and our reasons for doing so:
|Our use of your personal information||Our reasons|
|To provide our products and services to you, or information that you request||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you||For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g., policies covering security and internet use||For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you|
|Statistical analyses to help us manage our business||For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you|
|Updating customer or vendor records||For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party, i.e., making sure that we can keep in touch with our customers about existing orders and new products|
|Marketing our services and those of selected third parties to:
||For our legitimate interests or those of a third party, i.e., to market and promote our business|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services|
3) Promotional Communications. We may use your personal information to send you updates (by email, telephone or posting on the Website) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with third parties, other than third parties that we have contracted to provide services on our behalf.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [email protected];
- using the “unsubscribe” link in emails that you receive from us; or
- updating your marketing preferences by clicking on the communications preferences link in the bottom of an email that you receive from us to manage your communication preferences.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
4) Who We Share Your Personal Information With. We may share your personal information with:
- Our affiliate companies
- Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses and delivery companies
- Other third parties we use to help us run our business, such as marketing agencies or website hosts
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers which provide that they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors at our discretion.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
5) Personal Information We Sold or Disclosed for a Business Purpose. We have not in the preceding 12 months, sold any of your personal information to third parties.
In the preceding 12 months, we have disclosed or may have disclosed (for a business purpose) the categories of personal information identified in Section 1 above to one or more third parties.
6) Where Your Personal Information is Held. Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties may be based inside or outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
7) How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods may apply for different types of personal information.
8) Transferring Your Personal Information Out of the EEA. To deliver services to you within the European Economic Area (EEA), it is sometimes necessary for us to share your personal information outside the EEA, such as:
- With our offices outside the EEA;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA; or
- Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under applicable data protection laws.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Canada, United Kingdom, and Switzerland.
Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please refer to: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en.
If you would like further information, please contact our Data Protection Manager (see “How To Contact Us” below).
9) Your Rights Under the GDPR.
|Right to Access||The right to be provided with a copy of your personal information|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information (in certain situations)|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information in certain circumstances, e.g., if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations)|
|Right to Object|
The right to object:
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, see the guidance on individual rights under the General Data Protection Regulation, available here: https://gdpr.eu/.
10) Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) to exercise free of charge:
|Disclosure of Personal Information We Collect About You|
You have the right to know:
|Personal Information Sold or Used for a Business Purpose|
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, please send an e-mail to [email protected]
|Right to Deletion|
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
|Protection Against Discrimination|
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you, if that difference is reasonably related to the value provided to our business by your personal information.
11) Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We follow industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- Email us at [email protected]
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected personal information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
13) Changes to This Privacy Notice. This privacy notice was published on May [___], 2022.
We may change this privacy notice from time to time–when we do, we will inform you via our Website.
Our contact details are shown below:
Attn: _____________, Security Officer
6815 Communications Parkway
Plano, Texas 75024