EFFECTIVE January 1, 2019
We respect the privacy of our users and want to ensure that every measure is taken to protect your personal information in the event we need or are required to collect and store it. This Policy is for that purpose
By visiting and/or using the Platforms, you consent to our collection, use and transfer of your personal and other information for processing in the United States as described in this Policy. The personal and other information that we collect about you is controlled by us in the United States. If you reside or are otherwise located outside of the United States, please note that the information and data we collect will be processed and stored in the United States. Data protection and privacy laws, rules, and regulations in the United States may differ from those in the jurisdiction in which you are located, and may not have the same level of protection as the laws, rules and regulations in the country or territory in which you reside or are located. Your use of the Platforms and the providing of information to us constitutes your consent to the transfer to and processing of your personal information in the United States unless otherwise stated within this Policy.
EUROPEAN UNION RESIDENTS: The Policy outlines the legal basis on which we collect and use your personal and other information and provides all other necessary information in accordance with the General Data Protection Regulation (the “GDPR”)
“Personal information” is information we can use to identify you, directly or indirectly, with or without additional information. This includes, but is not necessarily limited to, your name, email address, mailing address, telephone number, credit card number, other payment information, and certain “cookies.” See our “Cookies Policy” for more information on cookies.
We collect both personal information and non-personal information about Platform users. For purposes of this Policy, “non-personal information” is information that we cannot directly associate with a specific person without the aid of additional information. When we combine non-personal information with personal information, we treat all of the combined information as personal information.
We collect, use, disclose and disseminate personal information in accordance with this Policy in order to, without necessarily any limitation, operate and improve the Platforms; market and advertise our services and products; improve our business and the level of service we strive to offer our customers; and to comply with legal requirements.
How Personal Information is collected
The following are the ways in which we may collect your personal information. The purposes for these uses are discussed in the section that follows, called “How we use the personal and non-personal information that we collect.”
- Registration: In order to subscribe to certain services or use many features offered on our Platforms, you may be required to register by providing certain personal information such as your name, email address, phone number, date of birth, shipping address, and/or payment information.
- Purchases: If you purchase a product or service from us, we require certain personal information from you on our order form. This personal information may include your name, email address, shipping address, and payment information.
- Social Media: Certain of our Platforms are connected to social media platforms such as Facebook, Twitter and Instagram. These social media platforms allow users to submit personal information that may be accessible to other users and/or the general public. You may be required to first register with the social media platform by providing information such as an email address, display name, and password. Registrants also may choose to voluntarily provide additional information, including an avatar image, a biography, and/or information about their location on the social media platforms. And, of course, registrants may disclose personal and other information through their posted content.
- Feedback: Our online contact form also contains a “message” field through which you may submit additional personal information.
- Surveys, Contests, and Promotions: From time to time, we may ask Platform users to participate in surveys, contests, or promotions. Taking part in such surveys, contests or promotions may require you to submit personal information, such as your name, address, email address, and date of birth.
- Tracking technologies: When you use the Platforms, we automatically receive and record certain information from your computer (or other device) and your browser, which may include your IP address and domain name, the pages you visit or the features you use on the Platforms, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Platforms, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), web beacons, device, IDs, advertising IDs, and certain cookie information. To obtain such information, we may use web logs or applications that recognize your computer or device and gather information about its online activity. Click here to read our “Cookies Policy.”
- Third-party online tracking and behavioral advertising: We also may partner with certain third parties to collect, analyze, and use some of the personal information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Platforms or in email communications from us. This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “How we share personal and non-personal information with third parties”).
How we use the personal and non-personal information that we collect
We use the information that we collect as set forth above for a variety of purposes. For instance, we may use it: to respond to your questions or requests concerning the Platforms or other services offered by us; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services and orders for products or otherwise complete a transaction that you initiate; to send you information about our products and/or services, the status of any orders, and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to authenticate billing and identification information; to deliver confirmations, account information, notifications, goods or products, service-related announcements, and similar operational communications; to improve or personalize your user experience; to improve the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.
We use the non-personal information that we collect for such purposes as: counting and recognizing users of the Platforms; analyzing users’ demographics, interests, and behavior, including how they use the Platforms and various Platform features; improving the Platforms and enhancing users’ experiences with the Platforms; researching and creating new products and services or improving our existing products and services; enabling additional website and application analytics and research concerning the Platforms; and managing our business. We may link non-personal information gathered using certain tracking technologies such as cookies and web beacons with personal information. But in that event, we will treat the combined information as personal information.
If you choose to use our referral service to tell a friend about our products or services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Platforms. This personal information may be used to track the success of our referral program. Your friend may contact us at [email protected] to request that we remove this information from our database.
How we share personal and non-personal information with third parties
We share your personal information and non-personal information with other parties for a variety of purposes, as described above in the prior section of this Policy and in the following ways.
Affiliated Divisions and Entities: We may disclose personal information within our different divisions, and to any affiliates or companies that are owned or controlled by us to improve the Platforms, the products and services that we offer, for marking and advertising purposes, and in general to improve our business.
Service Providers: We may disclose personal information to third parties that provide us with certain services in an effort to improve the Platforms, the products and services that we offer, and in general to improve our business.
Advertising and Marketing: We may disclose personal information to third parties that provide advertising and marketing services on our behalf and on behalf of our service providers, to the extent appropriate. The Platforms also enable third-party tracking mechanisms to collect your non-personal information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Platforms to target online ads for our services to you on websites or services not owned or controlled by us. In addition, our third-party advertising networks might use information about your use of the Platforms to help target advertisements based on your online behavior in general. Please see our “Cookies Policy” for more information on this subject.
Analytics: We may disclose personal information to certain third parties to engage in analysis, auditing, research, and improvement of the Platforms and of the products and services that we offer.
Fulfill legal obligations: We also may share your personal and/or non-personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; and to meet the terms of any agreement that you have with us or our partners.
Direct sharing of personal information through third-party platforms: The Platforms may enable you to directly share personal information with websites or online services operated by third parties. For example, the Platforms contain links to third-party websites, applications, and/or other services. If you choose to use these features, you may disclose your personal information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by us, we are not responsible for the content or practices of those websites or services. The collection, use, dissemination and disclosure of your personal and non-personal information by those third party websites, applications, and/or services, and their plug-ins, will be subject to the policies of the third party websites, applications, or services, and not this Policy. Further, certain features of our Platforms make it possible for you to share comments or feedback publicly with all other users of the Platforms. Please take care when using these features of the Platforms
Legal Purposes: We also may use or share your personal or non-personal information with third parties when we believe, in our sole discretion, that doing so is necessary:
- to comply with applicable law or a court order, subpoena, or other legal process;
- to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- to establish, protect, or exercise our legal rights or defend against legal claims; or
- to facilitate the actual or proposed financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Security: We use commercially reasonable physical, electronic, and procedural safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. When you enter sensitive information (such as a credit card number and/or your social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information.
Our Legal Basis for Processing Your Personal Information
This section applies if you reside outside the United States. It is possible that more than one legal basis may apply. As previously outlined in this Policy, there are several reasons why we may collect and process your personal information. For purposes of this policy, TDS Management, Inc. is the controller of the personal information you provide to us.
Your consent may not be required depending on the circumstances under which your personal information is collected and/or used. Instances where consent is not required include, but are not limited to:
Performance of a contract: To perform our contractual obligations to you, including registration, processing, fulfilling, and shipping orders, contacting you about your order, your use of the Platforms, where we need to provide your personal information to within our different divisions and affiliated companies or companies that are owned or controlled by us and to our service providers, where we need to collect personal information from third party sources and when you access third party products and services, where we collect data from third parties or publicly-available sources, or to aggregate and centralize data.
Legal obligations: To comply with all laws, statutes, codes, rules, regulations, subpoenas, court orders, legal processes or, any other legal obligation.
Legitimate Interests: To operate our business, and provide the products and services offered on the Platforms, other than in performing our contractual obligations owed to you, for our “legitimate interests.” Legitimate interests include, but are not necessarily limited to the following:
- To communicate with you regarding our products, services, Platforms and any changes in the policies outlined herein, and to respond to any communications and/or requests you send to us for any reason.
- To provide you with promotional messages and surveys when you register and otherwise sign up to receive promotional messages and take part in surveys. However, a survey that is commercial in nature will not be sent to you unless you have already given us consent to receive marketing from us.
- To comply with our legal obligations and defend our rights and the rights of others, including providing your personal information to the appropriate authorities to assist in any legal investigation into possible unlawful activity.
- To improve, enhance, or otherwise change our products, services, and the Platforms, and for our own internal purposes geared towards improving our business, which includes research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
- To enforce this Policy or agreements with third parties.
- In connection with the sale or transfer of all or part of our business, which includes the due diligence period of the potential transaction (determining whether to proceed with the transaction).
When Consent is Required
We may need to obtain your consent in order to collect and process your personal information, which may be provided in a number of ways as outlined below. Certain instances where we may request your consent include, but are not necessarily limited to:
- To contact you by email or other electronic means about other offers, products, promotions, or services that we think may be of interest to you and for other marketing purposes.
- To share your personal information with certain third parties that want to offer certain goods, services, offers, promotions, and/or programs. In this case, you will need to contact the third party in accordance with their policies about withdrawing consent.
- To use your personal information for research purposes and to contact you to see if you are interested in taking part in any market research campaigns or programs.
- To use your information to contact you and to connect with us or other third parties on social media.
- To use your personal information for special offers, events, sweepstakes, and other promotions.
Withdrawal of Consent
Withdrawing your consent to use your personal information may be accomplished at any time for any reason. We will not collect or use your personal information in the future once you withdraw your consent, to the extent your consent was necessary in order to collect or use such information. You may withdraw your consent by “opting out” of the purposes for which you had previously authorized us to collect and use your personal information by sending an email to [email protected] with “opt out” in the subject line. You may click on the “unsubscribe” link in any email that contains one, such as promotional emails (which emails will also have instructions for opting out of that type of communication in the future).
We will remove you from our e-mailing list as soon as possible after receiving notification from you that you have chosen to “opt out.”
Please refer to our “Cookies Policy” by clicking here with respect to withdrawing any other form of consent.
Your personal information will be retained by us as long as is necessary pursuant to this Policy. We will delete your personal information when it is no longer needed or required to be maintained by us pursuant to this Policy, and when appropriate and authorized by applicable law.
You also have the right “to be forgotten” and having all of your personal information deleted by submitting a request to us at [email protected] to delete your personal information. We will endeavor to delete your personal information as soon as possible upon receipt of your request.
If you have any questions regarding the deletion or retention of your personal information, please contact us at [email protected]
Changes to this Policy
We reserve the right to amend this policy at any time. We will post all changes to this policy on this website, so you should review the policy periodically. To the extent permitted, we will notify you directly of any changes to this policy in the future. Any such amendments to this policy may apply to information we collect in the future as well as any information we obtained prior to such amendment. If we make a material change to this policy, we will provide appropriate notice as required by law.
Questions or comments
If you have any questions or comments at all regarding this Policy, please contact us at:
1140 Holland Drive
Boca Raton, FL 33487.