EFFECTIVE MAY 25, 2018
2. Information We Collect on Our Own Behalf.
a. Our Services: We may collect personally identifiable information about you, such as your full name, phone number, email address, or similar, when you sign up for a newsletter or download an asset off our Sites. If you choose to purchase services from us, we or our third-party payment processors will collect your payment information. When you use you sign up for a newsletter or download an asset off our Sites or if you visit our Sites, we may receive certain information about you as described below. We may send you service related emails related to your account or promotional emails. If you no longer wish to receive these emails, you may opt out of them by clicking “unsubscribe” in the actual email.
3. Information We Collect on Behalf of Our Customers.
a. Our Services: We collect data on behalf of our customers who use the TCF services on the behavior of visitors of our customers’ websites or mobile applications. When you visit such websites or mobile applications, we may receive certain information about your behavior including ser activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases). If you are located in Europe, your IP address, keystroke activity, and personal information are never stored or shared with any third-parties.
b. Information Related To Data Collected For Our Customers: TCF collects information under the direction of its customers, and has no direct relationship with the individuals whose data it may process. If you are a client of one of our current customers and would no longer like to be tracked by such customer, please contact the respective customer directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
c. Access And Retention Of Data Controlled By Our Customers: An individual who is a current or former TCF customer who seeks access or wishes to correct, amend, or delete inaccurate data should direct his query to firstname.lastname@example.org. An individual who is a client of a current or former TCF customer who seeks access or wishes to correct, amend, or delete inaccurate data should direct his query to the respective customer first and then, if no response is obtained or such response is not satisfactory, should contact email@example.com. If we receive a request under this provision, we will acknowledge it within five (5) business days and handle it promptly.
d. Retention: We will retain personal data we process on behalf of our customers for as long as needed to provide our services. TCF will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
4. Information We Collect on Behalf of Third Parties.
a. Cookies And Tracking Technologies: Technologies such as cookies, beacons, tags, and scripts are used by our partners, affiliates, analytics, or service providers. These technologies may be used in analyzing trends, administering the Sites, tracking your movements around the Sites, and to gather demographic information about our userbase as a whole. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis.
5. How We Use Your Information. We use the information that we collect to operate and maintain our Sites and via the TCF services and to respond to your questions and concerns. If you have given your consent, we use the information that we collect to send you marketing communications in our newsletter. We also use the information that we collect to help our customers improve their website(s). The legal basis is Article 6 the EU General Data Protection Regulation (GDPR).
6. How We Share Your Information.
b. Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain TCF services and those of our partners. Our partners also have the option to publish the results for their websites via the TCF services. Such results consist solely of non-personally identifiable information. If you choose to publish such results via the TCF services or Site (for example, in our results gallery), you understand and agree that this information, along with any personally identifiable information you choose to make available in connection with such results, will be made publicly available. By publishing your results via the TCF services or Site, you agree that you have obtained all necessary consents to make such information public and that doing so will not violate any laws. If you remove information that you have made public via the TCF services or Site, copies may remain viewable in cached and archived pages via the TCF services or Site, or if other users have copied or saved that information. Non-personally identifiable information may be stored indefinitely.
c. Instances Where We Are Required To Share Your Information: TCF will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to:
i. comply with the law and the reasonable requests of law enforcement;
ii. to protect the security or integrity of our services; and/or
iii.to exercise or protect the rights, property, or personal safety of TCF, our users or others.
d. What Happens In The Event Of A Change Of Control: We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the TCF services may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign, or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions, or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
e. Testimonials: We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
7. Storage and Processing. Your information collected via the TCF services may be stored and processed in the United States, Europe, or any other country in which TCF or its subsidiaries, affiliates, or service providers maintain facilities. TCF may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or European Economic Area, please note that we will not transfer information, including personal data, to a country outside of the European Union or European Economic Area.
8. How We Protect Your Information. TCF is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to TCF or guarantee that your information via the TCF services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive information (such as log in credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at email@example.com. We use an outside help platform, and a credit card processing company to bill you if you purchase services. These companies do not retain, share, store, or use personally identifiable information for any other purposes.
9. Privacy Shield. TCF self-certifies compliance with EU-US Privacy Shield at the U.S. Department of Commerce. TCF complies with the EU GDPR framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. TCF has certified that it adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
10. Compromise of Personal Information. In the event that personal information is compromised as a breach of security, TCF will promptly notify our customers in compliance with applicable law.
11. Your Choices About Your Information. For current TCF customers, you can review, correct, update or delete inaccuracies to the information about you that TCF keeps on file by contacting us directly at firstname.lastname@example.org. We will acknowledge your request within five (5) business days and handle it promptly. If you wish to opt-out of being tracked by TCF’s analytics tracking, you can do so by contacting us directly at email@example.com. Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority.
12. Enforcement and Dispute Resolution. In compliance with the EU-US Privacy Shield Principles, TCF commits to resolve complaints about your privacy and our collection or use of your personal information. EU Subjects with questions or concerns about the use of their personal data should contact us at: firstname.lastname@example.org. If your question or concern cannot be satisfied through this process, TCF has further committed to refer unresolved privacy complaints under the EU-US and Privacy Shield Frameworks to BBB EU Privacy Shield, an independent dispute resolution mechanism operated in the United States by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by TCF, EU and Individuals and Data Subjects should go to http://bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of the BBB EU Privacy Shield will be provided at no cost to you. Finally, as a last resort and in limited situations, EU Individuals and Data Subjects may seek redress from the Privacy Shield Panel — a binding arbitration mechanism.
13. Our Retention Of Your Information. If you have an account with TCF, we will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. If you are a visitor to the TCF Sites we will retain your information for as long as necessary but no longer than one (1) year after your last visit to our Sites.
14. Children’s Privacy. Protecting the privacy of young children is especially important. For that reason, TCF does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com.
The Content Factory, LLC
2 Washington Lane
Nottingham, NH 03290