Effective Date: May 2019

TSHJ and its affiliates are committed to protecting your information. Please read this Privacy Policy (“the Policy“) carefully as it sets out important information relating to how we handle your personal information.

TSHJ companies issuing the Policy

In this Policy, references to “we,” “us,” or “TSHJ” are references to TSHJ, LLC. Certain TSHJ products and/or services which may be linked through www.TSHJ.net with different business models have their own applicable privacy policies, and this Policy does not apply to them.

TSHJ will have access to information on individuals covered by this Policy.

How to Contact Us

Questions, comments and requests regarding this Privacy Policy should be addressed to our Legal Department via email at [email protected] or regular mail at:

TSHJ, LLC
Legal Department
10450 Turkey Lake Rd #690272
Orlando, FL 32819-8027
USA

Introduction

This Policy sets out how we collect and use personal information, and your choices and rights regarding our use of your personal information.

This Policy describes our practices when using your information when you: 

1. express an interest in or have signed up for our products and/or services including newsletters, apps, and webinars, or activate your TSHJ user account and/or license; or
2. visit our websites (including our public and/or member-based websites) or social media sites.

This Policy also applies to information we collect from you. You may be shown additional confidentiality notices. Please note that in cases where the terms of any such specific confidentiality notice conflict with any terms in this Policy, the terms of that notice will take precedence over the terms in this Policy. We will not use information we collect to contact you for marketing purposes.

This Policy will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.    

1. INFORMATION THAT WE COLLECT ABOUT YOU

1.1 Data collection and use

Information we collect directly from you or from the following sources: Third party referrals including from within the TSHJ group; Social media sites and other public internet sites, such as LinkedIn; and Public resources such as telephone directories, newspapers, internet sites, commercially available marketing lists, registries or public records.
Categories of information we collect about you include:	Personal information such as name and title, contact details, and company name; Communications with you; Information you provide when posting content on social media sites.
We use this information for certain activities, including:	Facilitating the business through communication with corporate clients and other business contacts, for example, to communicate about vendor briefings or details of conferences or webinars; For internal analysis and research to help us improve our services; To send marketing to business contacts regarding our services and products which may be of interest and to promote our business and brand; Administering our website, investigating any complaints and providing customer service; Monitoring social media content to manage relations with our clients and promote our business and brand.
We use this information because:	It is necessary to perform our obligations or exercise our contractual rights; It is necessary to comply with applicable laws or regulations; We have a legitimate business interest to: Manage and promote our business and brand; Provide and improve our services; Operate our business; and We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.
Information we collect from users of: Our public and member-based websites; Our apps; and TSHJ social media sites such as Facebook or Twitter.
Categories of information we collect about you include:	Information you provide when you enter information on our website, such as when you provide contact details, answer online questionnaires, or feedback forms; Information you provide when you subscribe to email newsletters such as name, email address, job title; Information you provide when registering for an online or member account, including name, business or personal email address, job title, organization, organization’s physical address, direct telephone number, photograph, and biographical details; Where you have an online or member account, log-in credentials and information about your use of and preferences for these services; When you link your TSHJ account with your LinkedIn profile, we collect information from your profile, including your profile photograph;
We use this information for certain activities, including:	Enabling you to access your TSHJ accounts across devices; Personalizing your experience of our website and apps; Administering our website and apps; Enabling peer networking opportunities based on your background and experience; Providing more customized client service; Investigating complaints; Monitoring social media content to manage relations with our clients and promote our business and brand.
We use this information because:	It is necessary to perform our obligations or exercise our contractual rights; It is necessary to comply with applicable laws or regulations; We have a legitimate business interest to: Promote our brand and business through our website and through social media tools; Monitor, investigate and report any attempts to breach the security of our website; Provide and improve our services including, but not limited to our apps; Operate our business; We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.
Information we collect about the use of our website and apps from users.
Categories of information we collect about you include:	Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g URL, browser type, pages visited, date/time of access), geo-location and other device-specific information, Internet connection information; Advertising information (such as size/type of ad, ad impressions, location/format of ad, data about interactions with ad); Behavioral information (such as information on the behavior or presumed interests of individuals which are linked to those individuals and may be used to create a user profile); and Information captured by our cookies (see our Cookie Policy).
We use this information for certain activities, including:	Personalizing the experience of our website; Administering our website; Performing statistical and trend analysis to improve the user experience and performance of our website; Providing better, more customized client service; Investigating any complaints.
We use this information because:	It is necessary to comply with applicable laws or regulations; We have a legitimate business interest to: Monitor, investigate and report any attempts to breach the security of our websites; Improve the performance and user experience of our websites; Customize the client experience.

1.2 Special categories of information

Certain types of personal information are more sensitive than others. This includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometric information or religion. It is voluntary for you to disclose this information, but where we collect and receive these types of information about you, we have identified the type of special information, how we will use it and why we will use it.

1.3 Further information

Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.

Our websites and online services are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18.

In certain circumstances, if you do not provide personal information which is required (for example, in relation to activating your TSHJ license), we will not be able to perform our contractual obligations or provide you with products and services. When this is the case, we will make it clear.

Recorded Communications with TSHJ

We may ask to record calls for training, quality and research purposes. All recordings will be treated as confidential. If you do not want us to record your call, you will be given a chance to opt out. If your call is already in progress, you may ask us to turn off the recording at the start of the call.

Restricted Areas

If you access the Restricted Areas of any of our sites (via browser or a TSHJ app), we may collect information about your access to and use of research materials, decision-support tools, and other online and offline resources we offer.

General Benchmarking and Research Purposes

TSHJ and its affiliates may use information disclosed or otherwise provided to or generated by TSHJ or its Affiliates (collectively “Research Data”) for validation, research and benchmarking purposes and product development. Unless otherwise specified prior to collection, Research Data will be disclosed in the aggregate and presented in anonymous form and will not include (directly or by inference) any information identifying participating organizations or any identifiable individual as the source of such data. Access to Research Data will be restricted to those individuals who need such access to deliver TSHJ products and/or services.

2. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information to third parties as follows:

• To TSHJ group companies in order to process the data for the above mentioned purposes;
• When we have your consent to do so;
• To third parties who work on our behalf to service or maintain business contact databases and other IT systems, e.g., suppliers of the IT systems which we use to process personal information, or who provide other technical services, such as printing;
• To third parties providing services to us or on our behalf who have a need to access your information, e.g., our professional advisors (e.g. auditors and lawyers);
• To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (e.g., disclosing data in appropriate situations for national security or law enforcement purposes);
• Subject to applicable law, in the event that TSHJ is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such a transaction, or for pre-transaction review in relation to such transactions.

Your personal information may be shared if we anonymize and/or aggregate it, as in these circumstances the information will cease to be personal information.

Utilization Information

We may share information with our organizational clients about how their employees use the sites and the resources available to them through the sites (e.g., how employees used certain features of the sites, utilization trends, which features were most popular with the client’s employees).

3. DATA SUBJECT RIGHTS

In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is set out below. To exercise any of these rights, please contact us. Such requests should include information to allow us to verify your identity(e.g., your name, address, email address or other information reasonably required).

Where we receive your request to exercise one of these rights, we will respond without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, e.g., where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances, we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request.

We may ask for additional information to verify your identity before carrying out a request.

Right	How you can exercise the right
Right to access and/or correct your personal information	You have the right to access personal information we hold about you and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.
Right to restrict use of your personal information	You have the right to ask us to restrict processing of your personal information where one of the following applies: The processing is unlawful but you want us to restrict use of the data instead of deleting it; Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information; We no longer require the personal information for the purposes of processing, but are required to keep it in connection with a legal claim; You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.
Right to request deletion of your personal information	You have the right to ask us to delete your personal information in certain circumstances. If you want to opt-out from receiving marketing communications, the best way to do so is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
Right to object to processing of your personal information	You may object to our use of your personal information for marketing purposes. You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.
Right to data portability	In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.
Right to lodge a complaint with a supervisory authority	If you object to our processing of your personal information, you have the right to complain to the data protection authority (“DPA”) in the country where you reside, where you work, or where the alleged infringement of data protection laws has taken place. We agree that any disputes regarding our privacy policies and related actions regarding personal information from data subjects in the EU can be heard by a DPA and we will be subject to the determination of those bodies (as further explained in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA. In certain circumstances after they have first tried to resolve the dispute directly with us and with the DPA, data subjects in the EU may be able to invoke binding arbitration of disputes by the Privacy Shield arbitration panel.

4. INTERNATIONAL TRANSFERS

TSHJ is a global company and we may transfer personal information to other TSHJ group companies or suppliers outside your country. TSHJ will take reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.

TSHJ may transfer and maintain the personal information of individuals covered by this Policy on servers or databases outside the European Economic Area (“EEA”). Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA.

The countries to which we transfer data outside of the EEA may include any of the countries in which TSHJ does business.

All TSHJ entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of information.

Privacy Shield.  TSHJ complies with the EU-US and US-Swiss Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of information from European Union member countries, and is subject to the investigatory and enforcement powers of the United States Federal Trade Commission. TSHJ adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. 

TSHJ’s accountability for information that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the information on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

More information about the Privacy Shield program can be found at https://www.privacyshield.gov/.

5. RETENTION PERIODS

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.  

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

• the period required by tax and company laws and regulations; and
• as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws. 

6. CHOICES ABOUT YOUR INFORMATION

We believe it is important to give you choices about the use of your information. We will use your information as described in this Policy (or any other service-specific Privacy Policy). If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.

Marketing Communications

We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us at the address here. If you gave us your email address to receive marketing communications, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information or information with third parties (other than our subsidiaries or affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please click here.

7. SECURITY

We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access any TSHJ service or account, and you must report suspected unauthorized activity to us.

We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

8. COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences.  For simplicity, we refer to all these technologies as “cookies”.

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

We also include web beacons in e-mail messages or newsletters to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer through the Site. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

More detailed information on how we use cookies and other web technologies can be found here.

9. MISCELLANEOUS

9.1 Links

We provide links to other websites or resources that are not part of the products, programs, or services run by TSHJ. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the Privacy Policies of those sites and not this Policy.

9.2 California Privacy Rights

Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please contact us as specified at the beginning of this Privacy Policy.

9.3 Changes to this Policy

From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on this website. We recommend you regularly review this website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.