Effective Date: 1/22/2021
We appreciate your interest in our websites, services and products (collectively, our “Services”). Privacy protection is very important to us and we are committed to protecting you and respecting your privacy. This Privacy Policy sets out information about how we collect, store, process, transfer and use data that identifies you or makes you identifiable, as a natural person (hereinafter “personal information”). Personal information encompasses all personal data as defined in Art. 4 para 1 of the General Data Protection Regulation (“GDPR”) and as defined by the California Consumer Privacy Act of 2018 (“CCPA”).
This Privacy Policy is designed to be used for our website visitors and users of our Services on a global basis. The Privacy Policy will thus provide various information that is required in specific jurisdictions only. We have in the following marked with “GDPR Notice”, the information applying to our activities only subject to the GDPR and marked otherwise the notices specifically required under other laws
We, that is TTI, Inc., is the data controller. We are responsible for, and control, the processing of your personal information.
If you wish to contact us, you can find our contact details at the end of this Privacy Policy.
When you use our Services, we may collect information about you. This information regularly includes the following.
This personal information is collected from you in many ways, and may include:
GDPR Notice:
The reasons for using your personal information may differ depending on your interaction with us. Regularly we use your information for the following purposes and on the following legal grounds:
We will only use your information for the purposes above. We will not use your information for other purposes. We do not use your personal information for automated individual decision-making.
As required in accordance with how we use it, we will share your personal information with the following third parties:
If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@tti.com.
GDPR Notice:
We will store personal information for as long as necessary to fulfil the purposes for which we collect the personal information in accordance with our legal obligations and legitimate business interests. To ensure that all your data is deleted in accordance with the principle of data minimization, we have developed a data retention policy. The following describes the fundamental principles and outlines essential retention periods contained in this policy.
As a general rule, we keep data necessary for the performance of a contract for six up to ten years depending on the nature and scope of the contract in order to clarify any enquiries or claims after expiry of the contract. We need this information, e.g. in the context of a possible return of your Services and the evaluation of defects or for compliance with statutory retention requirements, for example, tax laws.
We may retain any information that we deem necessary to investigate or defend claims against us, or to prosecute or bring claims against you, us or any third party, for as long as we believe such action may be necessary.
We may retain data collected from you for customer service and marketing purposes, for up to six years after collection, unless you object against the procession of your data for this purpose or you wish the data to be deleted and there are no contractual or statutory storage obligations that prevent this request for deletion.
In regard to business correspondence or documents relevant under commercial code or tax law, statutory retention periods range from six up to ten years. This legal data retention period covers, inter alia, invoices, vendor documents or financial statements.
We may store your device information and other technical information for legitimate business purposes.
We have implemented appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, unauthorized change or damage. All personal information we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by SSL encryption technology.
As we are located in the USA, any information you provide will be processed and stored in the USA. If you are in the European Union or European Economic Areas, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically a resident in.
For this reason, we have entered into guarantees to ensure appropriate safeguards. If we transfer information from the European Union to third parties outside the European Union and in countries or not subject to schemes which are considered as providing for an adequate data protection standard, we will enter into contracts which are based on the EU Standard Contractual Clauses with these parties.
If you wish to inquire further about the safeguards we use, please contact us using the details set out at the end of this Privacy Policy.
We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this Privacy Policy.
We, and our third-party partners, automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. You can usually change the settings of your browser to modify the permissions you give to us and third parties for the storing of and gaining access to cookies on your device.
Category of Personal Information | Collected | Disclosed for Business Purposes | Sold* |
Identifiers, such as name, mailing address, email address, zip code, telephone number, or other similar identifiers | ✔ | ✔ | No Personal Information Sold |
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as date of birth, username and password, company name, job title, business email address, and industry | ✔ | ✔ | |
Commercial Information, such as information about products or services purchased, obtained or considered | ✔ | ✔ | |
Internet/Network Information, such as your browsing history, log and analytics data, information about the device(s) used to access the Services, domain server, search history and information regarding your interaction with our websites or Services and other usage data | ✔ | ✔ | |
Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address | ✔ | ✔ | |
Sensory Information, such as pictures you provide or upload in connection with our services, and the content and audio recordings of phone calls between you and us that we record where permitted by law | ✔ | ✔ | |
Other Personal Information, such as personal information you provide to us in relation to a comment, question, request or inquiry, or information provided to us through social media networks | ✔ | ✔ | |
Inferences, including information generated from your use of our Services reflecting predictions about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes | ✔ | ✔ |
* Note about “Sales”: We do not and will not “sell” personal information as most people think of that term. However, we do utilize third-party providers to engage in online analytics and advertising involving the collection of personal information, including Identifiers, Internet/Network Information, and Geolocation Data, directly from your browser or device through cookies or related technologies when you visit or interact with our online services or otherwise engage with us online. We use these third-party providers to analyze and optimize our online services, provide more relevant content and ads to users of our online services and other third parties, and perform other services related to analytics or advertising consistent with these CA Disclosures and this Privacy Policy. These third-party businesses may use the information they collect directly from you for their own purposes in accordance with their own privacy notices, which may include using this information for services provided to other third parties, including other parties operating in advertising networks.
To the extent that these practices qualify as “sales” under the CCPA, you may have the right to opt out as described in the Your Privacy Rights section below.
Sources of Personal Information
As described in the How do we collect your information section of this Privacy Policy, we collect personal information directly from you when you provide it to us, automatically when you visit our websites and other online services, and from service providers and other third parties. For representatives of our clients, vendors, service providers and other third parties, we also collect personal information directly from you and from the entity you represent.
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the Why and on which legal grounds do we collect and use your personal information section of this Privacy Policy. For representatives of our clients, vendors, service providers and other third parties, we also collect your personal information to maintain an ongoing relationship between us and the entity you represent and to contact you in connection with our relationship with the entity you represent.
Recipients of Personal Information
As described in the With whom and on which legal grounds do we share your personal information section of our Privacy Policy, we share personal information within TTI and with a variety of third parties. For representatives of our clients, vendors, service providers and other third parties, we also share your personal information with the entity you represent.
Your California Privacy Rights:
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
How to Exercise Your California Consumer Rights:
How We Will Verify Your Request to Exercise Your Right to Know or Right to Deletion:
We will need to verify your identity before processing your request and confirm you are a resident of the State of California. In order to verify your identity, we will generally require the matching of at least two data points that you provide with your request, or in response to our request for verification information, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity. This process may require us to request additional personal information about you. Examples of relevant data points may include your name and email address, your zip code or information about products or services that you have purchased from us. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf by:
To Exercise Your Right to Know or Right to Deletion:
To submit a request to exercise your right to know and/or your right to deletion, please send an email to privacy@tti.com , call our toll-free number at 1-866-I-OPT-OUT (1-866-467-8688) ext. 1081 or send a letter addressed to:
TTI Privacy
2441 Northeast Pkwy
Fort Worth, TX USA
76106-1816
To Exercise Your Right to Opt Out of Personal Information Sales:
As described in the Collection, Disclosure and Sale of Personal Information section above, we utilize third-party providers to engage in online analytics and advertising involving the collection of personal information, including Identifiers, Internet/Network Information, and Geolocation Data, directly from your browser or device through cookies or related technologies when you visit or interact with our online services or otherwise engage with us online. We use these third-party providers to analyze and optimize our online services, provide more relevant content and ads to users of our online services and other third parties, and perform other services related to analytics or advertising consistent with these CA Disclosures and our Privacy Policy. These third-party businesses may use the information they collect directly from you for their own purposes in accordance with their own privacy notices, which may include using this information for services provided to other third parties, including other parties operating in advertising networks.
To the extent that these practices qualify as “sales” under the CCPA, you may have the right to opt out as described above. Please see the Online Advertising and Data Collection and Your Choices sections of this Privacy Policy for more information about the choices and opt-out options you may have in relation to those practices.
California’s “Shine the Light” Law
In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to privacy@tti.com.
We will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
Minors Under Age 16:
We do not sell the personal information of consumers we know to be less than 16 years of age. Please contact us at privacy@tti.com to inform us if you, or your minor child, are under the age of 16.
We want you to understand your rights and choices regarding how we may use your personal information. You have specific rights under applicable privacy law in respect of your personal information that we hold, including a right of access and erasure and a right to prevent certain processing activities.
Your Choices: Depending on how you use your information, you may have the following choices:
RIGHT TO OBJECT. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER. |
If you wish to exercise one of these rights, please contact us by using the contact details listed below in the 'How to contact us' section of this Privacy Policy.
In addition to the afore listed rights, if you are living in the EU, you also have the right to lodge a complaint with your local data protection authority. Further information about how to contact your local data protection authority is available at National Data Protection Authorities.
We do not knowingly collect or solicit any information from anyone under the age of 13 on the Services. In the event that we learn that we have inadvertently 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 a child under 13, please contact us at privacy@tti.com.
From children under the age of 16 residing in the EU, we will not process any personal information on the ground of a consent.
If you have any questions or concerns about our Privacy Policy or if you want to exercise your rights, please send an email to privacy@tti.com or write to us at:
TTI, Inc.
Attn: Privacy Team
Ganghoferstr. 34
82216 Maisach-Gernlinden
Germany
For all enquiries regarding TTI’s activities in Europe, you may also want to contact our Data Protection Officer who can be reached at:
Dr. Charlotte Lauser
Maître en droit
Lawyer
Dr.-Gerhard-Hanke-Weg 31
85221 Dachau
Germany
Tel: 0049 8131 338582
Fax: 0049 8131 511619
Email: datenschutz@lauser-nhk.de
The Services may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
We may make changes to our Online Privacy Policy from time to time. Please review our policies regularly as updated policies will apply to your future use of our Services.