Privacy Policy

Last updated: 22nd May 2018

At TCC Global N.V. (“tcc”), we believe privacy is important. We want you to be familiar with the data that we collect, how we use these data and with whom we share them. This privacy policy applies to all personal data we collect in connection with our website, www.tccglobal.com.

 

What personal data we use

tcc uses information that identifies you as an individual, or relates to an identifiable individual (“Personal Data”). tcc uses the following Personal Data in line with the use purposes explained below:

  • Your name and email address
  • Any information you choose to provide when you send us a message using our website

We need to collect Personal Data in order to enable you to send us a message using our website. If you do not provide the information requested, you may not be able to do so. If you disclose any Personal Data relating to other people to us or to our service providers in connection with our website, you represent that you have the authority to do so and to permit us to use the information in accordance with this privacy policy.

 

How we use Personal Data

tcc uses Personal Data to provide a safe, efficient and customized experience. For example, we use Personal Data to:

  • Provide the website’s functionality to you, and fulfil your requests
    • To respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our services.
    • To send administrative information to you, such as changes to our terms, conditions and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Conduct analyses for business reporting.
    • To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services.

We will engage in this activity where we have a legitimate interest.

  • Accomplish our business purposes.
    • For data analysis, for example, to improve the efficiency of our services;
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks ;
    • For developing new products and services;
    • For enhancing, improving, or modifying our current products and services;
    • For identifying usage trends, for example, understanding which parts of our services are of most interest to users;
    • For operating and expanding our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests;

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or where we have a legitimate interest.

 

How long we use Personal Data

We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which they were obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you keep using our services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 

With whom we share your Personal Data

tcc may share the information collected with third parties to provide a safe, efficient and customized experience. Here are some of the details on how we do that:

  • To our affiliates for the purposes described in this privacy policy.
    • You can consult the list and location of our affiliates here
  • To our third party service providers, to facilitate services they provide to us.
    • These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
  • To comply with applicable laws and regulations.
    • This can include laws outside your country of residence.
  • To cooperate with public and government authorities and law enforcement.
    • These can include authorities outside your country of residence.
    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons.
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

 

Logging Practices

tcc‘s web servers automatically record the Internet Protocol (IP) addresses of visitors. The IP address is a unique number assigned to every computer on the internet. Generally, an IP address changes each time you connect to the internet (it is a “dynamic” address). Note, however, that if you have a broadband connection, depending on your individual circumstance, the IP address that we collect may contain information that could be deemed identifiable. This is because, with some broadband connections, your IP address doesn’t change (it is “static”) and could be associated with your personal computer. Where this information qualifies as Personal Data, we will treat it as such, and as set out in this privacy policy.

As well as recording the IP addresses of users, tcc may also keep track of sites that users visited immediately prior to visiting tcc‘s website and the search terms they used to find it. The web server keeps track of the pages visited on tcc‘s website, the amount of time spent on those pages and the types of searches done on them. Your searches remain confidential and anonymous. tcc uses this information only for statistical purposes, to find out which pages users find most useful and to improve the website.

tcc servers also capture and store information that your browser transmits. This includes:

  • Browser type/version
  • Operating system used
  • Media Access Control (MAC) address
  • Screen resolution
  • Date and time of the server request
  • Volume of data transferred
  • Access status (“file transferred,” “file not found” and so on)

This data will be used to generate statistics that help us to further optimize our websites to meet your individual needs.

 

Cookies

Cookies are electronic placeholders that are placed on your computer by websites to track your individual movements on that website over time. Cookies used by tcc are session-based and therefore last only for the duration of the user’s session. Cookies are used by the tcc website to keep track of user sessions to balance the usage of this website on all tcc web servers. They are not tied to a specific identity — in general, no identifiable personal information about you is stored by them. However, where this information qualifies as Personal Data, we will treat it as such, and as set out in this privacy policy.

If you do not want a cookie placed on your computer as a result of using a tcc website, you can disable cookies altogether by modifying the preferences section of your web browser. Note that, if you do so, some aspects of tcc websites may be unavailable to you. If you choose to accept cookies on your hard drive, but wish to be informed of their appearance, you may turn on a warning prompt by modifying the cookie-warning section also located in the preferences section of your web browser.

Depending on your cookie consent selection of settings upon first visiting the website, tcc uses persistent cookies. This type of cookie remains on your hard drive and provides information about the session you are in and waits for the next time you use that site again. This provides useful information to tcc, enabling it to recognize repeat users, facilitate the user’s access to and use of the site, and allow a site to track usage behavior, which lets tcc make content improvements. Such cookies are used only for this purpose, and they are not used to identify users or to track their usage of other sites.

Depending on your cookie consent selection of settings upon first visiting the tcc website, tracking cookies and third-party cookies may be used to process additional information, enable noncore functionalities on the tcc website and enable referenced third-party functions (such as a social media “share” link).

 

Do Not Track (DNT)

There is currently no standard for how DNT consumer browser settings should work on commercial websites. However, the industry has self-regulatory initiatives designed to provide consumers a choice in the types of ads they may see online and to conveniently opt-out from online behavioral ads served by some or all of the companies participating in these programs. Our websites do not respond to DNT consumer browser settings.

 

External Links Disclaimer

Some of tcc‘s websites link to other sites created and maintained by other public- and/or private-sector organizations. tcc provides these links solely for your information and convenience. When you transfer to an outside website, you are leaving the tcc domain, and tcc‘s information management policies no longer apply. tcc encourages you to read the privacy statement of each external website that you visit before you provide any Personal Data.

 

Security

tcc implements commercially reasonable technical and organizational security controls to protect your Personal Data against theft, loss or misuse. Your data will be stored in a secure operating environment that is not accessible without authorization. tcc applies mitigation measures following periodic risk assessments to ensure an adequate level of protection of your Personal Data.

tcc has put in place appropriate physical, technical and administrative procedures to safeguard and secure the information from loss, misuse, unauthorized access, disclosure, alteration or destruction. tcc cannot guarantee the security of information on or transmitted via the internet.

 

Personal Data about minors and children

tcc does not knowingly collect data from or about children under 16. If we learn that we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at data.privacy@tccglobal.com.

 

Sensitive Personal Data

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the website or otherwise to us.

 

Cross-Border Data Transfers

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Additional Information Regarding the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here:  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting data.privacy@tccglobal.com.

 

Your right to access Personal Data

In addition to the information that is available on tcc‘s website, you have the right to access the Personal Data that tcc holds about you, all subject to the exemptions as contained in applicable laws and regulations. If you request the data, then tcc will assist you. Your identity will need to be confirmed before you are provided with access to Personal Data. We ask that you put your request in writing to the address included in the section “Contact us” below, and include the following information:

  1. Your full mailing address
  2. Names of specific files or types of records to which you request access, including specific dates of those records, where possible

Please provide as much detail as possible.

We will respond to your request consistent with applicable law. You will be notified if access to the records you have requested is granted or denied, and which exemptions apply.

 

Your right to correct or amend Personal Data

If you believe there is a mistake in your Personal Data, you have a right to ask for the information to be corrected. We may ask you to provide documentation to show where tcc‘s files are incorrect. We will respond to your request consistent with applicable law, will amend the erroneous data without undue delay, and will notify you once the correction you have requested has been completed.

 

Your right to take Personal Data with you (portability)

You may obtain and reuse the Personal Data held by tcc for your own purposes across different services. tcc allows you to move, copy or transfer Personal Data easily from one IT environment to another in a safe and secure way, without hindrance to usability. This right applies to your Personal Data held by tcc, where the processing was automated and used in the light of our service provision within the contract you have with tcc, or where such processing was based on the consent you gave tcc for it.

Follow the instructions at “Your Right to Access the Personal Data” and indicate that you wish to obtain the information for reuse purposes, indicating your desire to take the Personal Data with you. We will respond to your request consistent with applicable law.

 

Your right to be forgotten

tcc does not store Personal Data without a predefined and documented purpose. We follow laws that require us to delete Personal Data if the reason for its collection and storage no longer exists. If, however, you wish to have your Personal Data deleted at an earlier date, please contact our privacy team at data.privacy@tccglobal.com. We will respond to your request consistent with applicable law.

 

Questions or complaints

We encourage anyone who has questions about our use of Personal Data or interested to raise any concerns about this, to contact us at data.privacy@tccglobal.com or at the address provided in the section “Contact us” below. We will do our best to answer your questions and resolve any complaints and disputes regarding our use of Personal Data. Alternatively, individuals in the EEA have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.  A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

 

Review and ratification

We may occasionally update or modify this privacy policy. To ensure that the importance of this privacy policy is communicated uniformly throughout the enterprise, all members of tcc‘s board of directors will review, update and ratify this privacy policy at least annually.

For material changes to this privacy policy, we will notify you by placing a prominent notice on the home page of our website or, if legally required, by directly sending you a notification. We encourage you to periodically review this privacy policy to stay informed about how we are helping to protect the Personal Data we collect. Your continued use of the service constitutes your agreement to this privacy policy and any updates.

 

Contact us

TCC Global N.V. is the company responsible for the collection, use and disclosure of your Personal Data under this privacy policy. If you have any questions, please contact us at data.privacy@tccglobal.com or:

TCC Global N.V.

Zuidplein 84

1077 XV Amsterdam, Netherlands

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.