- the information we collect about you;
- how that information may be used;
- with whom the information may be shared;
- how you may update the information you provide us;
- how you may contact us; and
- your choices about the information.
COLLECTION AND USE OF USER INFORMATION
We collect Personal Information from you through our Platform, or through any other digital or personal communication between you and us. Personal Information collected by us may include your name, e-mail address, billing address, general usage metrics of the Platform, your financial payment information, your profile, email communication history with Tpinfosec, anything you submit to or post on the Sites, and other information associated with you or your organization, as well as other information that may or may not specifically identify you. The information collected through the Platform may be stored at servers, computers, or other media located in the United States. We may also collect general information about your technology interfaces or preferences and the websites you visit. We may use a third party provider to process financial and payment information.
We may obtain information about you from third-party sources, such as Google or Apple. This information may be utilized, analyzed, and/or compared with information that Tpinfosec has collected from you or that you have submitted to the Platform. If Tpinfosec obtains information from third-party sources, you agree that your sole legal remedy for any harm associated with that information is against the third-party that provided the information to us, and that you will not assert any cause of action, claim or demand against us other than requesting we delete any erroneous information.
For the avoidance of doubt, Tpinfosec shall be entitled to collect anonymous and/or aggregated data across its various products and services provided that no individual natural person can be identified from such data (“Aggregate Data”). The Aggregate Data will be used for various purposes, including without limitation to analyze behavior, trends, and website interaction, and to improve, and enhance our services and for other development, creation of new features, diagnostic and corrective purposes in connection with our services. Tpinfosec shall own all right, title and interest in and to the Aggregate Data and this is not considered personal data.
INFORMATION COLLECTION TECHNOLOGY
For each visitor to our Sites, we may use various technologies, including “cookies” to automatically gather certain information pursuant to your use of the Sites, from your electronic device about your activities using the Sites. We may collect and store non-personally identifying information through cookies, and third-parties to profile user activity and preferences. Technical and specification information about your device and settings may be collected when you use the Sites. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, the content of previously accepted “cookies” from us, and clickstream data. We collect and store this information on an individual basis and in combined form. We also collect both user-specific and aggregate information on what pages visitors access or visit.
A cookie is data stored on your device that tracks non-personal information about you. When using the Sites, we may assign your device one or more cookies that enable us to improve the quality of the Sites and to personalize your experience. Cookies allow us to automatically collect information about your activity on the Websites, such as the content you access while using the Sites, the links you click, and other activity you conduct while using the Sites. You may choose to modify your device setting to disable cookies or limit their use. If you choose to disable or limit cookies, or otherwise limit your device permissions to the Sites, you may experience diminished performance from the Sites and/or may be prevented from using some or all features of the Sites. Our cookies generally fall into one of four categories: Essential, Functional, Analytics and Target.
Our Platform may contain web beacons (also known as “clear gifs”) or similar technologies that gather non-personally identifiable information about your use of our Platform. Such technology may also be contained in e-mail messages or newsletters from us that allow us to determine whether messages have been accessed. The purpose of our use of this technology is so that we may analyze the effectiveness of our marketing efforts and the quality of our Platform.
The following section only applies if you use one of our mobile software applications (the “Software”). The Software requires certain permissions on your mobile device in order to work as intended. You can either allow or deny the Software access to the permissions. In some cases it is necessary for you to grant the Software permissions to take full advantage of features or functionality of the Software. If you disallow some or all permissions, the Software may not function properly. Some of the permissions needed may include access to your device’s: camera; calendar; location; phone; sensor; SMS; and storage. Additional permissions may be requested as new features are added in the future.
CHILDREN UNDER THE AGE OF 13
In accordance with COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our Site and Platform are not designed for children, and we do not knowingly collect information from any person under the age of 13. If you are the parent or legal guardian of someone under the age of 13 who may have provided Tpinfosec with information without your knowledge or consent, please contact us as provided below to have this information removed.
SHARING USER INFORMATION
We do not share your personal data with any third-party advertisers or ad networks for their advertising purposes.
We may use and share your information for any legally permissible purpose. We may match, use, and share any of the information we collect from you to any personally identifiable information we obtain through third-parties. The ways we may use or share information that we collect about you include:
- providing you with use of the Sites and Platform;
- providing you with products or services, whether from Tpinfosec, or any -related organizations, entities, or affiliates;
- providing you with customized content and services;
- providing technical or customer support;
- performing research and analysis to gauge the use of the Sites and Platform;
- communicating with you by e-mail, postal mail, telephone, text message, and/or mobile devices about products or services that may be of interest to you from Tpinfosec, any affiliates, sponsors or other third-parties;
- with our partners and affiliates who may market their own products and services to you;
- where we have another legitimate interest in doing so;
- in connection with any possible sale merger or restructuring of all or any part of our business or assets; and
- performing functions as otherwise described to you at the time of collection.
In order to perform certain services on your behalf, we may publish certain information that you provide. You agree that any testimonial feedback, posts, interactions or other comments provided by you to Tpinfosec through any form of communication including but not limited to through the Sites, becomes the sole and exclusive property of Tpinfosec and that such information may be used for any legally permissible purpose, including, but not limited to marketing and advertising our Platform.
- To our affiliates as permitted by law;
- To third parties who provide information technology services such as website hosting, computer systems maintenance, or data security and privacy services;
In addition, we may share aggregate and sell, non-individual information, incapable of identifying a particular person, with third parties for any lawful purposes.
PROTECTION OF USER INFORMATION
We maintain administrative, physical, and technical safeguards for all user information collected in our Platform. However, given the nature of communications and information technology, and that the use of the Internet has inherent risks, although we regularly monitor for possible vulnerabilities and attack, we cannot warrant or guarantee that information provided to us through the Platform or stored in our systems or otherwise will be absolutely free from unauthorized intrusion by others, nor can we warrant or guarantee that such data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Therefore, although we take reasonable steps to secure your information, we cannot and do not promise or warrant that your information will always remain secure.
EXTERNAL LINKS AND THIRD PARTY PRIVACY PRACTICES
The Platform may link to other websites, including but not limited to health care provider pages, or through advertisements. We disclaim any and all responsibility for the privacy practices of third-parties that may have links to or from our Platform. We encourage you to review the privacy policies and privacy statements of every website that you visit that collects personally identifiable information.
CALIFORNIA PRIVACY RIGHTS
We will not share any personal information about you with other companies if prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law.
If you are a California resident, you may have certain rights with respect to your Personal Information including the following rights:
- the right to “opt-out” of Tpinfosec’s sale of your personal information to any third parties;
- the right, with some exceptions, to have your personal information deleted from Tpinfosec’s possession or control; and
- the right to receive equal service and pricing from Tpinfosec even if you exercise any of your privacy rights.
EU Resident Rights under the GDPR
These disclosures apply only to our processing of Personal Information within the scope of the General Data Protection Regulation (“GDPR”) from one or more of the European Union Member States plus Iceland, Lichtenstein and Norway (together known as the “European Economic Area” or “EEA”).
The GDPR went into effect on May 25, 2018. As a resident of the EU or EEA, you have certain rights with respect to the processing of your personal data, including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
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