Tailored Response Group Inc. and our subsidiaries (“Trgsec” or “we”)are committed to complying with data protection legislation, including the dataprotection regime introduced by the General Data Protection Regulation (EU Regulation2016/679, the “GDPR”), California Consumer Privacy Act of 2018 (the “CCPA”) asamended by the California Privacy Rights Act of 2020, and other applicable USconsumer privacy laws. This privacy notice contains information on whatpersonal data we collect, what we do with that information, and what rights youhave.
We process some personal data in order to run our business. There are alimited number of circumstances where we may share your information with thirdparties (for example, pursuant to a court order, if we are part of a merger, orwith our business partners and service providers who support our business orcollaborate with us). We take the security of your information seriously andtake steps to keep your information secure. Please read the full Privacy andSecurity Statement below and you can always contact us if you have questions.
We respect your privacy and are committed to protecting it through ourcompliance with this Privacy and Security Statement. This Privacy and SecurityStatement (together with our Terms of Use)describes the types of information we may collect from you or that you mayprovide—for example, when you visit any of our websites or contact us—and howwe use, protect, and disclose that information.
This Privacy and Security Statement does not apply to information collectedon any third-party site or application (including advertising) that may link toor be accessible from our websites. We are not responsible for the privacypolicies or data collection, use and disclosure practices of those sites. Weencourage you to review the privacy policies of each site you visit.
Please read this Privacy and Security Statement carefully to understandTrgsec’s policies and practices regarding your information and how we willtreat it. By accessing or using any of our websites or services (includingemail communications), you agree to this Privacy and Security Statement. ThisStatement may change from time to time, and these changes may affect how we usethe information described below, so please check the Privacy and SecurityStatement periodically for updates.
We collect several types of information for our business operations,including but not limited to:
Information you provide to us. When you navigate our websites orcontact us, we may request or you may choose to provide us with certaininformation. This may include information by which you may be personallyidentified (“personal information”), such as name, employer, e-mail address ortelephone number, and records and copies of your correspondence with us. Forsecurity purposes, we may also collect personal information from you if youvisit one of our offices.
Information collected from forms on our websites. This may includeinformation provided at the time of registering to use portions of our websitesor our products and services, posting material, attending or registering toattend our virtual or in-person events, or requesting further services. We mayask you for information when you report a problem with our websites, productsor services.
Usage details, IP addresses and cookies. As you navigate through andinteract with our websites, we may automatically collect certain informationabout your device, including information about your web browser, IP address,time zone, and some of the cookies that are installed on your device, as wellas your browsing actions and patterns using common internet technologies, suchas cookies and Web beacons. This may include details of your visits to ourwebsites, including information about your connectivity, such as your IPaddress and browser information, location and time zone data, logs and othercommunication data, the websites or search terms that referred you to ourwebsites, the resources and pages that you access and use on the websites, andsome of the cookies that are installed on your device. This information helpsus to improve our websites and to deliver better and more personalized contentand services by enabling us to estimate our audience size and usage patterns,to recognize you when you return to our websites, and to enable us or ourthird-party vendors to serve ads tailored to your profile.
Email marketing. We don’t use any type of e-mail marketing.
Email alerts. If you sign up to receive email alerts from Trgsec, wewill retain your name and contact information for as long as you wish tocontinue receiving alerts. You may unsubscribe via the ‘unsubscribe’ link thatappears at the bottom of our emails, or by contacting privacy@Trgsec.com.
General business-related information. We may also receive otherpersonal information from or about you in the ordinary course of our business.
We use information that we collect about you or that you provide to us,including personal information:
· To provide you with information, products orservices that you request from us, or to market our products or services toyou.
· To maintain the integrity and security of ourwebsites, products, and services.
Payment Information. If you are purchasing products or services onour websites, and you submit payment information in the course of yourpurchase, you acknowledge such information will be handled by Stripe accordingto Stripe’s Global Privacy Policy which can be found here, or as may be provided byStripe when you complete your transaction.
Legal basis for the processing. We are not allowed to processpersonal data if we do not have a valid legal ground. Therefore, we will onlyprocess your personal data if:
· the processing is necessary to perform ourcontractual obligations towards you or to take pre-contractual steps at yourrequest, such as when we authenticate your log-in to our services or ensurethat you only have access to the services and data we have agreed to provideyou with;
· the processing is necessary to comply with ourlegal or regulatory obligations, such as tax reporting or regulatoryrequirements;
· the processing is necessary for the legitimateinterests of Trgsec, and does not unduly affect your interests or fundamentalrights and freedoms (see below);
· the processing is necessary for the performanceof a task carried out in the public interest; or
· in some cases, and as may be requested from youfrom time to time, we have obtained prior consent.
To the extent that we process any special categories of data relating toyou, we will do so because:
· the data has been manifestly made public;
· the processing is necessary for theestablishment, exercise or defense of a legal claim;
· the processing is necessary for reasons ofsubstantial public interest; or
· you have given your explicit consent to us toprocess that information (where legally permissible).
Protecting your personal information is important to us and we neither rentnor sell your personal information to anyone. We may disclose or transferpersonal information that we collect or you provide as described in thisPrivacy and Security Statement, including:
· To a buyer or other successor in the event of amerger, acquisition, divestiture, restructuring, reorganization, dissolution orother sale or transfer of some or all of Trgsec’s assets, in which personalinformation held by Trgsec about our websites’ users is among the assetstransferred.
· To our subsidiaries, affiliates, agents,contractors, service providers and other third parties we use to support ourbusiness or collaborate with and who are bound by contractual obligations tokeep personal information confidential and use it only for the purposes ofproviding services for or with us.
· To comply with court order, law or legalprocess, including to respond to government or regulatory requests.
· To enforce or apply our Terms of Use and otheragreements that govern the sale or use of our products and services.
· To protect the rights, property or security ofTrgsec, our employees, our users or others.
We only collect and retain as much personal information as needed forspecific, identified purposes described in this Privacy and Security Policy andwe will not use it in any way that is incompatible with those purposes.
You may have a right to access and to obtain a copy of your personal data asprocessed by Trgsec. If you believe that any information we hold about you isincorrect or incomplete, you may also request the correction of your personaldata.
You may also have the right to:
· object to the processing of your personal data;
· request the erasure of your personal data;
· request restriction on the processing of yourpersonal data; and/or
· withdraw your consent where Trgsec obtained yourconsent to process personal data (without this withdrawal affecting thelawfulness of any processing that took place prior to the withdrawal).
We will honor such requests, withdrawal or objection as required underapplicable data protection rules but these rights are not absolute: they do notalways apply and exemptions may be engaged. We will usually, in response to arequest, ask you to verify your identity and/or provide information that helpsus to better understand your request. If we do not comply with your request, wewill explain why.
To exercise the above rights, you may send an email to data-subject-request@Trgsec.com.If you are not satisfied with how we process your personal data, please let usknow and we will investigate your concern. Please raise any concerns bycontacting our Data Protection Officer at privacy@Trgsec.com.
If you are not satisfied with our response, you have the right to make acomplaint to the data protection authority in the jurisdiction where you liveor work, or in the place where you think an issue in relation to your data hasarisen. The contact details of each Data Protection Authority can be found atthe following website: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
This section provides additional information regarding the CaliforniaConsumer Privacy Act of 2018 (the “CCPA”) as amended by the CaliforniaPrivacy Rights Act of 2020, and supplements the disclosures and informationthroughout this Privacy and Security Statement. The commitments in this sectionapply only to individuals covered by CCPA and are subject to certain statutoryexceptions laid out in the CCPA.
Notice of Collection
The personal information we generally collect, use, and disclose regardingCalifornia residents as a Business (as defined under CCPA) is described abovein the section, “Notice About How We Use and Protect Personal Information” andas follows:
Collection: In the past 12 months, we have collected the followingcategories of personal information enumerated in the CCPA:
· Identifiers, including name, postaladdress, email address, and online identifiers (such as IP address).
· Customer records, including company name,phone number, and company address.
· Characteristics of protected classificationsunder California or federal law, including race, gender, and country ofresidence.
· Commercial or transactions information,including products or services purchased, obtained or considered, or otherpurchasing or consumption histories or preferences.
· Internet activity, including browsinghistory, search history, and your interactions with our websites, emails, applications,and advertisements.
· Employment and education information.
· Inferences drawn from the aboveinformation about your predicted characteristics and preferences.
Sources: We collect the information directly from you, from otherpersons or entities (e.g. if another person or your employer provides yourcontact information in the course of a booking at one of our events), orthird-party providers.
Purposes of Collection: We collect and use these categories ofpersonal information for the business purposes described in the “Use ofInformation” section above.
Disclosure: Any disclosures of such information to third parties overthe preceding 12 months have been in accordance with the permitted categoriesin the “Disclosure of Your Information” section above.
Sale: We are a software company and not a data broker, and we do notsell your personal information in the course of providing our services andproducts to our customers.
This type of disclosure only occurs in limited markets and Californiaconsumers may opt out of the sale of your personal information, whereapplicable, by us to third parties at any time. You may submit a request toopt-out by emailing us at ccpa-requests@Trgsec.com.
California Consumer Rights: The CCPA creates a right for certaincovered individuals to request that a company disclose what, if any, personalinformation that company collects, uses, discloses, and sells about themspecifically, or to request the deletion of personal information the companyhas collected or maintained about them. If you believe you have such a rightunder the CCPA and would like to exercise that right with respect to Trgsec,please completethe form here or submit an email request to ccpa-requests@Trgsec.comwith “California Request to Know” or “California Request to Delete” in thesubject line. For a “Request to Know,” please specify what details you wouldlike to know, including any specific pieces of personal information you wouldlike to access. For a “Request to Delete,” please specify what information youwould like to have deleted (which may be all your information as required by theCCPA). If you submit a request, we may ask for information necessary to verifyyour identity and eligibility to assert this right, and we will respond toverified requests in accordance with the CCPA. You may also utilize anauthorized agent to exercise your CCPA rights on your behalf. You may not bediscriminated against because you exercise any of your rights under the CCPA,and Trgsec is committed to this principle.
We take your security seriously and take reasonable steps to protect and secureyour personal information from unauthorized access, use, and disclosure. Wehave implemented adequate technical and organizational measures to protectpersonal data against unauthorized, accidental or unlawful destruction, loss,alteration, misuse, disclosure or access and against all other unlawful formsof processing. These security measures have been implemented taking intoaccount the state of the art of the technology, their cost of implementation,the risks presented by the processing and the nature of the personal data, withparticular care for sensitive data.
The safety and security of your information also depends on you. Where wehave given you (or where you have chosen) a password for access to certainparts of our websites, products, or services, you are responsible for keepingthis password confidential. Please do not share your password with anyone.
Although we take reasonable security measures to protect your personalinformation, for example, by using Secure Socket Layer encryption when youtransmit your password, we cannot guarantee the security of your personalinformation transmitted to our websites. The transmission of information viathe internet is not 100% secure and we cannot ensure or warrant the security ofany information you transmit to us. We are not responsible for circumvention ofany privacy settings or security measures contained on the websites.
We will only retain personal data for as long as necessary to fulfill thepurpose for which it may lawfully be processed or to comply with legal,regulatory or internal policy requirements.
We may amend this Privacy and Security Statement from time to time. Weencourage you to revisit this page periodically to read the current version ofthis Statement in effect. If you have any concerns or questions about thisStatement or if you would like to lodge a complaint, please contact privacy@Trgsec.com.
Our websites are not intended for children under 13 years of age. If youbecome aware that your child has provided us with personal information withoutyour consent, please contact us at privacy@Trgsec.com andwe will work to delete it. We do not knowingly collect personal informationfrom children under 13.
To communicate with our Data Protection Officer, please email privacy@Trgsec.com.
If you have any questions or comments about this Privacy and SecurityStatement, please contact us by emailing us at privops@trgsec.com
or by writing to us at:
Tailored Response Group Inc. Attention: Legal Department, Privacy StatementIssues 9350 Wilshire Blvd., Beverly Hills, CA 90212
This Statement has been designed to be accessible to people withdisabilities. If you experience any difficulties accessing the informationhere, please contact us at Interoperable