This policy applies to all visitors to our website and customers who have subscribed to the services we offer ('you' and 'your').
We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way we collect, store, use, and protect information that can be associated with a specific natural or juristic person and can be used to identify that person ('personal information'). Personal information:
You must accept all the terms of this policy when you register for or use any of our services. If you do not agree with anything in this policy, then you may not register for and/or use any of the services. You may not access our website or use our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts. By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all its terms.
We may change the terms of this policy at any time. We will notify you of any changes by placing a notice in a prominent place on the website or by email or by having you accept the policy by displaying the updated policy upon next login. If you do not agree with the change you must stop using the services. If you continue to use the services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted such terms.
Once registered on our website, you will no longer be anonymous to us as you would have provided us with your personal information. This personal information will include:
In order to provide the services to you, you will be asked to provide us with additional information on a voluntary basis ('service information').
You may also provide additional information on a voluntary basis. This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, register and subscribe for certain additional services, or otherwise use the optional features and functionality of the website.
Our website may contain electronic image requests (called a 'single-pixel gif' or 'web beacon' request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.
We may use any service information and optional information provided by you for such purposes as indicated to you at the time you agree to provide such service information or optional information. We may use your usage information for the purposes described above and to:
We may send administrative messages and email updates to you regarding the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
We may share your personal information with:
If you contact us regarding your experience with using any of our products, we may disclose your personal information as required by law or governmental audit.
We may disclose personal information if required:
We may disclose aggregate statistics (information about the user population in general terms) about the personal information to business partners.
We may need to disclose personal information to our employees that require the personal information to do their jobs.
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
We protect your information in the manner specified in our security policy. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities.
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes explicitly defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online, by emailing us, or by phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
During the period of retention, we will continue to abide by our non disclosure obligations and will not share or sell your personal information
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites.
Vendors of TTS will implement and maintain appropriate technical and organizational measures and other protections for Client Information, including, without limitation, (w) host and network based intrusion detection systems, penetration tests (conducted through the use of a party other than Vendors), (x) controls against unauthorized access (including, without limitation, viruses and malicious software), (y) encryption of all data in transit electronically, and (z) controls preventing the loading of Personal data on: (a) any laptop computers or USB drives, unless such data is encrypted, or (b) any other portable storage media that can be removed from Vendor's premises, unless approval of the officer of Vendors responsible for such Personal data is obtained and the loading of such data on such portable storage media is necessary for Vendors to perform under this Terms of Business; provided, however, that the technical and organizational measures and other protections to be implemented by Vendors shall at all times conform with the TTS Standard Operating Procedures.
TTS Vendors will promptly and without delay - but in no event later than 48 hours from the occurrence - report to TTS any unauthorized use, loss, or disclosure of Personal data or other Information. Vendors will cooperate fully with TTS in investigating any such unauthorized use, loss, or disclosure, and will take all actions as may be necessary or reasonably requested by TTS to mitigate the problem, including, without limitation, notifying affected individuals and/or governmental entities, minimize any resulting damage, and review TTS written recommendations to enhance its security measures after a forensic investigation or audit (e.g., implementing encryption solutions). Vendors agrees that it will not notify affected individuals and/or governmental entities without contacting TTS first and obtaining written instruction from TTS. Vendors agrees to ensure that any Agent to whom it transfers or discloses TTS Client Information (including, without limitation, Personal data) pursuant to this Terms of Business has implemented and maintains a data privacy incident reporting process for the prompt reporting of any privacy or data security breaches to Vendors, who, in turn, shall promptly report this information to TTS.
Vendors will cooperate fully with TTS's reasonable requests for access to, correction of, and destruction of Personal data in Vendor's possession, which destruction shall be certified to TTS in writing. Furthermore, TTS, its Agents, and any governmental entity with jurisdiction or oversight authority, may, upon prior notice to Vendors, audit Vendor's records of TTS Information, and, to the extent relevant to the security of TTS Information, Vendor's security practices and data Processing activities, and speak with Vendor's personnel who are familiar with such records, practices and activities. Vendors will make all reasonable efforts to comply with all instructions or other requirements provided or issued by TTS from time to time relating to Personal data to the extent Vendors reasonably determines such compliance is appropriate for the performance of its obligations under this Terms of Business and complies with applicable Laws. If Vendors do not believe such compliance is appropriate, it shall promptly notify TTS, and Vendors and TTS will discuss and determine how to proceed.
Vendors shall from time to time (but no less frequently than once every 2 years) conduct an ongoing privacy assessment and security validation of those Affiliates and Agents, if any, to whom it has transferred Personal data or other TTS Information pursuant to this Terms of Business. During the term of this Terms of Business, Vendors shall, wherever possible, provide prior written notice, or, if prior notice is not possible, provide written notice as soon thereafter as practicable, when any Affiliate or Agent that is to assist Vendors in performing the services under this Terms of Business will have access to TTS Information.
TTS vendors acknowledges and agrees that Vendors PERSONAL DATA may be collected, Processed, and/or transferred (each, a 'Transfer') across international boundaries to TTS Systems. To the extent that such Vendors PERSONAL DATA requires consent from such personnel prior to subsequent Transfer by TTS, Vendors agrees that it shall be solely responsible for obtaining legally compliant consent permitting the Transfer of such Vendors PERSONAL DATA.
TTS vendors will (i) Process (as defined below) Personal data only on TTS's written instruction and consistent with this Terms of Business and applicable Law, (ii) not Process Personal data for any other purpose, (iii) only Process Personal data in the jurisdiction in which TTS originally delivered the PERSONAL DATA to Vendors or to which access was granted by TTS unless otherwise approved by TTS in writing, (iv) immediately stop Processing (as defined herein) Personal data upon written request from TTS, and (v) not disclose, transfer or provide access to Personal data to any third party, including its Affiliates or Agents, without TTS's prior written approval.
For purposes of this Terms of Business, 'Process' or 'Processing' means any operation or set of operations which is performed upon Personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, transfer, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
TTS vendors shall comply with all U.S. and international Laws governing or relating to privacy, data protection, data security and the handling of data security breaches when Processing Personal data. When and as required by TTS from time to time, Vendors shall promptly execute and cause its Affiliates and Agents to promptly execute, supplemental security and data protection terms, including controller-to-processor data transfer agreements, on such terms and conditions as shall be mutually agreed upon and as required for the Processing or transfer of Personal data in accordance with the applicable requirements of U.S. or international Law.
To the extent that TTS vendors shall Process any Personal data governed by the local Laws implementing the European Union Data Privacy Directive (95/46/EC) ('EU Privacy Laws'), Vendors shall Process such Personal data (i) in the European Economic Area ('EEA') or in a country considered by the European Commission as providing adequate data privacy protection, or (ii) outside the European Economic Area or a country considered by the European Commission as providing adequate data privacy protection provided Vendors ensures that the transfer of such Personal data outside the EEA and its subsequent Processing is done in compliance with applicable Law by means of (a) Vendor's participation, to TTS's satisfaction, in the U.S.- EU Safe Harbor Framework recognized by decision 2000/520/EC of the European Commission, (b) entering into the appropriate controller-to-processor data transfer agreement approved by the European Commission, and/or (c) other mechanism acceptable to TTS that effectively complies with the applicable requirements under applicable Law.
The parties agree that for any Processing of Personal data in any medium or format governed by EU Privacy Laws, TTS shall be the 'data controller' and the Vendors shall be the 'data processor', as such terms are understood under such Laws.
Vendors shall promptly notify TTS upon receipt of any complaint or request (including 'data subject access' requests) relating to Vendor's obligations under the relevant data protection Law that may impact TTS, and such impact shall be deemed a Loss (as defined in Section 11 hereof). Vendors shall provide cooperation and assistance in relation to such complaint or request as reasonably requested by TTS, including acting timely in accordance with TTS's instructions and timetables. When and as required by TTS, Vendors will assist TTS in identifying, copying, preserving, or producing Personal data that is (i) in the possession of the Vendors, its Affiliates or Agents, or (ii) stored in facilities under management or control of Vendors, its Affiliates or Agents, including for purposes of TTS satisfying the order or request of a governmental entity or a third party with access rights over the Personal data.
All comments, queries and requests regarding our services are welcomed.
Last update : 03 May 2018
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