POLICY VERSION DATE: February 03, 2019
1. INFORMATION WE COLLECT
1.1 Information Visitors Provide to Us on the Website: Visitors may give Us personal information through Our Website, for example, when Visitors make inquiries about Our products and Services, sign up for a free trial, contact Us for support, obtain a quote or consultation, or to explore career opportunities with Us, or when Visitors sign up for an online account or marketing communications.
We may ask Visitors to provide specific information set out in an online inquiry form (for example, name, contact details, company name, country, monthly email volume, billing information, profile information, etc). Alternatively, Visitors may choose to provide additional information when Visitors communicate with Us or otherwise interact with Us, and We will keep copies of any such communications that Visitors send to Us for Our records.
1.2 Information We Collect Automatically through the Website and Services We may also collect certain information through Our Website and Services by automated means such as IP addresses, browser type and operating system, referring URLs, information about Visitors visit including the URL clickstream to, through and from Our Website, download errors, number of Website visits, and other page interactions. We collect this information automatically through the use of various commonly used information-gathering technologies including cookies and web beacons, to collect information as users and Visitors navigate the Website and use the Services (“Web Site Navigational Information”). We use these technologies to analyze trends, administer Web sites and Services, track users’ and Visitors’ movements around Our Website and Services, serve targeted advertisements and gather demographic information about Our user and Visitor base as a whole.
2. USE OF INFORMATION
We may use the information We collect through Our Website for a range of reasons including to:
- Provide, operate, optimize and maintain the Website;
- Deal with Visitors’ online inquiries and requests, and to provide Visitors with information and access to resources or services that Visitors have requested from Us;
- Manage Our Website and system administration and security;
- Improve the navigation and content of Our Website;
- Identify any server problems or other IT or network issues;
- Process transactions and to set up online accounts;
- Compile aggregated statistics about Site usage and to better understand the preferences of Our Site Visitors;
- Carry out research and development to improve Our products and Services;
Send Visitors information for marketing purposes (where it is in accordance with Visitors’ communication preferences);
- Customize content and layout of the Website;
- Carry out other legitimate business purposes, as well as other lawful purposes about which We will notify Our users, Visitors, and Customers.
Legal Basis for Processing (EEA Individuals Only): If Visitors are from the European Economic Area (“EEA”), Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which We collect it.
However, We will normally collect personal information from Visitors only where We have Visitors’ consent to do so, where We need the personal information to perform a contract with Visitors, or where the processing is in Our legitimate interests and not overriden by Visitors’ data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect the personal information in question.
If We ask Visitors to provide personal information to comply with a legal requirement or to perform a contract with Visitors, We will make this clear at the relevant time and advise Visitors whether the provision of Visitors’ personal information is mandatory or not (as well as of the possible consequences if Visitors do not provide Visitors’ personal information).
Similarly, if We collect and use Visitors’ personal information in reliance on Our or a third party’s legitimate interests and those interests are not already listed above, We will make clear to Visitors at the relevant time what those legitimate interests are.
If Visitors have questions about or need further information concerning the legal basis on which We collect and use Visitors’ personal information, please contact Us using the contact details provided under the “How to Contact Us” section below.
3. INFORMATION WE SHARE
We may share and disclose Visitors’ personal information to third parties in the following circumstances:
- Within the TPS group of companies for the purposes outlined in this Policy.
- To vendors and other third-party service providers who require access to Visitors’ personal information to assist in the provision of the Website, Our products and Services, and other business-related functions such as website analytics providers or Our third-party advertising partners. These vendors and third-party service providers are limited to only accessing or using this data to provide services to Us and must provide reasonable assurances they will appropriately safeguard the data.
- We may also disclose Visitors’ information to third parties: (a) where required by law or regulatory requirement, court order or other judicial authorization, (b) in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements; (c) in connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business; (d) to protect or defend Our rights, interests or property, or that of third parties; (e) to investigate any wrongdoing in connection with the Website or Our Services; or (f) to protect the vital interests of an individual.
- With Visitors’ consent.
4. THIRD-PARTY SITES
On some pages of Our Website, such as Our blog, third parties may provide applications or plug-ins through Our Website which may track Visitors’ use of content, applications or plug-ins, or may customize content, applications and plug-ins for Visitors. For example, when Visitors share a post on Our blog using a social media sharing button (e.g. Facebook, LinkedIn), the social network that has created the button will record that Visitors have done this. If Visitors do not want the social network to collect this information about Visitors, then Visitors are advised to not use this feature.
5. SENSITIVE DATA
TPS does not knowingly solicit or collect, and Visitors should not provide, any information regarding Visitors’ medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other Sensitive Data.
The Website is not directed at children under the age of 18. We do not knowingly solicit or collect personal information from children under the age of 18.
7. VISITOR’ CHOICES AND OPT-OUTS
Visitors can opt-out of receiving marketing emails from Us at any time, or opt out from having Visitors’ contact information shared with third parties for direct marketing purposes. Visitors can opt-out of Our marketing emails by clicking the ‘unsubscribe’ link at the bottom of Our marketing messages.
Also, all opt out requests can be made by emailing Us at email@example.com. Please note that it may take up to 3 days to remove Visitors’ contact information from Our marketing communications lists, so Visitors may receive correspondence from Us for a short time after Visitors make a request.
Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management and Visitors cannot opt out of these messages unless Visitors request to deactivate their TPS account.
8. OTHER DATA RIGHTS
TPS takes reasonable steps to ensure that the data We collect is reliable for its intended use, accurate, complete and up to date. Visitors can email Us at firstname.lastname@example.org if Visitors wish to access, correct, amend or delete any personal information that We hold about Visitors and We will consider Visitors’ request in accordance with applicable laws.
Visitors from certain territories (such as the European Union) may have additional rights under their data protection laws, such as the following:
- Access: Right to request access to and a copy of Visitors’ personal information;
Restriction: Visitors can ask Us to restrict processing of their personal information in certain circumstances;
- Rectification: Visitors can have any inaccuracies in Visitors’ personal information corrected;
- Deletion: Visitors can ask Us to delete their personal information in certain circumstances (e.g. if the information is no longer necessary for the purposes for which it was collected);
- Objection: Visitors can object to further processing their personal information in certain circumstances;
- Withdrawal of consent: Where We rely on Visitors’ consent to process Visitors’ personal information, Visitors have the right to decline consent and/or if provided, to withdraw it at any time. This will not affect the lawfulness of the processing prior to the withdrawal of Visitors’ consent.
- Portability: Visitors can ask Us to provide their personal information in a structured, commonly used and machine-readable format in certain circumstances.
Visitors can exercise the above rights by writing to Us using the contact details in Section 13 below and We will consider such requests in accordance with applicable data protection laws. We may ask Visitors to verify Visitors’ identity before We respond to a Visitors’ request.
Visitors also have the right to raise questions or complaints with Visitors’ data protection authority at any time.
9. RETENTION OF VISITOR’ PERSONAL INFORMATION
We will retain Visitors’ personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes. Where We have no ongoing legitimate business need to process Visitors’ personal information, We will either delete or anonymize it or, if this is not possible (for example, because Visitors’ personal information has been stored in backup archives), then We will securely store Visitors’ personal information and isolate it from any further processing until deletion is possible.
10. UPDATES TO THIS POLICY
We reserve the right to change or update this Policy from time to time. If material changes are made, We will place a prominent notice on Our Website for at least 30 days prior to the change taking effect, and will update the last revised date at the top of this Policy. We encourage Visitors to regularly check back on this page to ensure Visitors are up to date with any changes.
11. HOW TO CONTACT US
If Visitors have any questions or concerns regarding the use or disclosure of Visitors’ personal information, Visitors can contact Us by sending an email to email@example.com, Our Data Protection Officer by sending an email to firstname.lastname@example.org, or by mail at: Aleea Privighetorilor 85, Suite 68, Sector 1, Bucharest, Romania.
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